A relevant person should develop and implement anti-money laundering (AML) policies, procedures, systems, and controls for the maintenance of relevant AML records as prescribed under Dubai International Financial Centre (DIFC) regulations for a period of six years from the date of the notification or report, completion of transaction or termination of business relationship with the customer, whichever occurs last.

This Practice Note discusses the different types of AML records a relevant person should maintain to ensure compliance with DIFC AML regulations, thereby avoiding hefty penalties.

• AML: Anti-money laundering.

• CDD: Customer due diligence.

• CFT: Combatting the financing of terrorism.

• EDD: Enhanced due diligence.

• Beneficial owners: A natural person who has or exercises effective ultimate control over the customer or the natural person on whose behalf the transactions are carried out, or the person who has effective ultimate control over a legal person or a legal arrangement, whether directly or through a chain of ownership, control or other indirect means.

• Business relationship: Any ongoing business or financial relationship arising between financial institutions or designated non-financial business or professions, and their customer related to the activities or services they provide to them.