A relevant person must appoint a competent money laundering reporting officer (MLRO) responsible for developing and implementing a relevant person’s anti-money laundering (AML) policies, procedures, systems, and controls, training the team and promoting the culture of compliance.

This Practice Note specifies who can be appointed as a MLRO and their responsibilities towards AML compliance and managing the risk of a relevant person.

• 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.