LFIs, whether they are primarily Payment Sector participants or have more limited exposure, are expected to take a risk-based approach to mitigating and managing ML/FT risks related to this sector, including the risks arising from the use of NPPS. A risk-based approach means that risk mitigation should begin with, and be based on, an appropriate assessment of the LFI’s payments-related risks. This assessment should in turn be reflected in the design and operation of the LFI’s AML/CFT program, including but not limited to the particular program elements discussed below, so that the LFI devotes greater resources and attention where risks are higher.

The sections below discuss how LFIs can apply specific preventive measures to mitigate and manage their payments-related risk. Sections 3.1-2 and 3.5-7 apply to all LFIs. Section 3.3 describes preventive measures recommended for LFIs that provide PPS directly to customers (including both consumers and merchants, or payers and payees), and section 3.4 for LFIs that provide services to other Payment Sector participants. The controls discussed should be integrated into the LFI’s larger AML/CFT compliance program and supported with appropriate governance and training. It is not an exhaustive discussion of all AML/CFT requirements and LFIs should continuously consult the UAE legal and regulatory framework currently in force.