A relevant person must develop anti-money laundering (AML) policies, procedures, systems, and controls and ensure that they are effectively implemented across all its subsidiaries and branches forming part of the group. The relevant person must implement the necessary policies for exchanging information within the group. Moreover, active oversight of AML policies and procedures at group level must be done by senior management.

This Practice Note will elaborate on implementing group AML policies, procedures to maintain consistency in AML measures across the group and procedures for exchanging information among the group to mitigate money laundering (ML) and financing of terrorism (TF) risks effectively.

• 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: