The AML-CFT Decision contains specific, mandatory requirements for managing risks related to PEPs. It is important for LFIs to be aware that the Decision imposes baseline requirements that are higher than for other types of customers. LFIs cannot choose to omit these requirements even when they consider that risks associated with a specific customer or transaction are low. This does not mean, however, that LFIs are not expected to take a risk-based approach to these customers. LFIs should implement the baseline controls described below as well as consider whether additional controls are necessary when even higher risks are present.

Furthermore, the sections below discuss how LFIs can apply the required specific preventive measures to identify, manage, and mitigate the risks associated with PEPs. It is not a comprehensive discussion of all AML/CFT requirements imposed on LFIs. LFIs should consult the legal and regulatory framework currently in force, the Guidelines on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations for Financial Institutions, and the CBUAE issued Guidances for further information². The controls discussed below should at the minimum be integrated into the LFI’s larger AML/CFT compliance program and supported with appropriate governance and training.

² Available at https://www.centralbank.ae/en/cbuae-amlcft