AML/CFT: Whistleblowing Policy
Overview
Designated non-financial businesses and professions (DNFBPs) should develop and implement whistleblowing policies and procedures to enable the whistleblower to report regulatory concerns. The policies and procedures should outline the appropriate reporting process, a mechanism for timely assessment of the reported concerns, protecting the whistleblowers and the record-keeping requirements of the incidents reported.
This Practice Note will discuss whistleblowing policies and procedures to promote the smooth reporting of regulatory concerns and their timeous assessment.
Definitions
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: