Anti-Money Laundering (AML/CFT) Framework for DNFBPs
Official Principle: "Lawyers, accountants, and auditors must implement KYC policies, risk scoring, and screening." — Бухгалтеры, юристы и аудиторы обязаны внедрять процедуры идентификации клиентов и проверки рисков.
📊 Regulatory Parameters & Compliance Table
| Accounting Standard | Target Entity | Key Requirements | Document Retention |
|---|---|---|---|
| Full IFRS | Revenue > AED 50M or QFZP / DIFC | Comprehensive disclosure & audit | 7 years statutory retention |
| IFRS for SMEs | Small & Medium Enterprises in UAE | Simplified recognition & measurement | Mandatory general ledger |
| Statutory Audit | Free Zone renewal & QFZP status | Signed report by licensed UAE auditor | Filed with Free Zone Authority |
| AML / CFT Bookkeeping | Designated Non-Financial Businesses (DNFBP) | Customer Due Diligence (CDD) records | Reported via goAML portal |
✓ Mandatory Compliance Action Steps:
- Implement professional accounting software (Xero, QuickBooks, Zoho) compliant with UAE tax rules
- Reconcile monthly corporate bank statements against sales invoices and purchase bills
- Maintain separate payroll records adhering to UAE Wages Protection System (WPS) guidelines
- Engage an accredited audit firm to prepare annual statutory audit reports
- Archive physical and electronic accounting records in UAE for minimum 7 statutory years
1. Core Statutory Provision & Key Legal Rule
"Lawyers, accountants, and auditors must implement KYC policies, risk scoring, and screening."
"Бухгалтеры, юристы и аудиторы обязаны внедрять процедуры идентификации клиентов и проверки рисков."
2. Practical Application for UAE Businesses
Under the UAE federal tax framework governed by Federal Decree-Law No. 20/2018, all taxable persons registered across Mainland jurisdictions and Free Zones (including Meydan, DMCC, DIFC, IFZA, DAFZA, and JAFZA) must align their accounting policies with this requirement.
- IFRS Accounting Standard: Financial statements must be prepared in accordance with International Financial Reporting Standards (IFRS or IFRS for SMEs).
- Record Retention: Primary accounting records, bank reconciliations, contracts, and tax filings must be archived for a minimum statutory period of 7 years.
- Audit Readiness: The Federal Tax Authority reserves statutory rights to request ledgers and supporting invoices during an official tax audit with a 5-day response window.
3. FTA Administrative Penalties (Cabinet Decision No. 75/2023)
Failure to register, inaccurate return filing, or violation of Federal Decree-Law No. 20/2018 exposes the taxable entity to administrative fines starting from AED 10,000 up to AED 20,000 per incident, plus 1% monthly late-payment penalties.
Solution: Timely registration through the FTA EmaraTax portal and voluntary disclosure (Form 211) before an official audit notice is served.
Have Questions Regarding Anti-Money Laundering (AML/CFT) Framework for DNFBPs?
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