A relevant person should develop policies and procedures to conduct an ongoing review of business relationships to ensure that the customer due diligence (CDD) information obtained about the customer and the beneficial owners remains accurate and up to date. Moreover, they must outline the circumstances and clear timelines for undertaking the review to mitigate the money laundering (ML) and terrorism financing (TF) risks effectively.

This Practice Note will provide an overview of how a relevant person can conduct effective ongoing monitoring of business relationships.

• 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: