Authorised firms operating as money service providers must develop a comprehensive anti-money laundering (AML) program covering all jurisdictions, including the operating locations of events. They must monitor the agent’s compliance with this programme to effectively mitigate money laundering (ML) and financing of terrorism (TF) risks associated with the provision of money services.

This Practice Note will provide an overview of how an authorised firm should implement AML measures to be undertaken in relation to the provision of money services, including the controls for managing compliance risk arising through the involvement of agents.

• 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: