A relevant person should develop and implement a robust sanctions compliance program to effectively implement targeted financial sanctions (TFS) and ensure that they are appropriately and effectively implemented across the organisation.

This Practice Note discusses developing and implementing an overall sanctions compliance program for complying with TFS.

• 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.