A relevant person must develop and implement policies, procedures, and controls to manage the business relationship with the customer where a suspicious activity report (SAR) or suspicious transaction report (STR) with the Financial Intelligence Unit (FIU) has been filed.

This Practice Note will elaborate on the procedures and course of action the relevant person should follow to effectively manage the business relationship with the customer after filing a SAR or STR with the FIU.

• AML: Anti-money laundering.

• Authorised person: Authorised firm or an authorised market institution.

• Authorised firm: An authorised person who holds a licence to carry on one or more financial services in or from the DIFC and is not an authorised market institution.

• Authorised market institution: An authorised person operating an exchange, a clearing house or an alternative trading system.

• Beneficial owner: A beneficial owner includes the following:

  • In relation to a customer, means a natural person who ultimately owns or controls the customer or a natural person on whose behalf a transaction is conducted, or a business relationship is established.

  • In relation to a body corporate: