The Licensed Person must introduce a comprehensive and documented AML/CFT policy, based on its ML/FT risk assessment in accordance with Paragraph 16.2 of this Chapter, which must be the foundation of its compliance function;
16.3.2
The AML/CFT policy must clearly define the roles and responsibilities of the Manager in Charge, Compliance Officers, Compliance Committee and employees in relation to AML/CFT compliance. The AML/CFT policy must also provide for regular and timely reporting to the Board of Directors (or to the Owner/Partners where there is no Board of Directors) regarding ML/FT risks and the culture/values to be adopted within the business of the Licensed Person to prevent money laundering, terrorist financing and related crimes;
16.3.3
The AML/CFT policy must affirm the roles and responsibilities of the Board of Directors (if any) and of the Owner/Partners/Shareholders in relation to implementing a robust AML/CFT Program across the business of the Licensed Person;
16.3.4
Effective AML/CFT procedures must also be implemented for employees to follow while they carry out their day to day responsibilities in order to ensure that ML/FT risks are mitigated in the day to day operations of the Licensed Person;
16.3.5
The AML/CFT policy and procedures must be based on the UAE’s existing AML/CFT Laws, Regulations, Notices and the Standards as well as international best practices and guidance notes from the FATF, MENAFATF, EGMONT Group and other similar bodies;
16.3.6
The AML/CFT policy and procedures must be approved by the Manager in Charge, the Compliance Officer and by the Board of Directors (or by the Owner/Partners where there is no Board of Directors);
16.3.7
The AML/CFT policy and procedures must be reviewed and updated, annually at a minimum, to make it consistent with all applicable Laws, Regulations, Notices, the Standards and other international best practices and to make it effective in mitigating the existing as well as emerging ML/FT risks;
16.3.8
Copies of the AML/CFT policy and procedures must be held in all Licensed Premises and be accessible to all employees at all times;
16.3.9
The AML/CFT policy and procedures must be circulated among all employees upon the completion of periodical reviews; and
16.3.10
The AML/CFT policy and procedures must apply to all branches, subsidiaries and affiliated entities in which the Licensed Person holds a majority interest (i.e, greater than 50%).