The relevant person must develop and implement robust anti-money laundering and combatting the financing of terrorism (AML/CFT) policies and procedures, laying down the roles and responsibilities of the senior management towards ensuring compliance with regulatory requirements and maintenance of the appropriate AML/CFT compliance culture within the organisation.

This Practice Note specifies the roles and responsibilities of senior management from an AML perspective.

• 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:

    • The natural persons who ultimately have a controlling ownership interest in the body corporate, whether legal or beneficial, direct or indirect.