Although LFIs should judge their own risk tolerance and risk management capabilities, the CBUAE does not expect or encourage LFIs to broadly prohibit or exit customer relationships with the real estate and precious metals and stones sectors. These sectors are important parts of the UAE economy, and they need access to financial services to conduct their legitimate business. The CBUAE does expect, however, that LFIs understand their risk and take effective, risk-based steps to protect themselves from abuse and from illicit actors and transactions. Effective risk mitigation is therefore critical to protecting the LFI, complying with its legal obligations, and meeting supervisory expectations.

The sections below discuss how LFIs can apply specific preventive measures to identify, manage, and mitigate the risks associated with the real estate and precious metals and stones sectors. It is not a comprehensive discussion of all AML/CFT requirements imposed on LFIs. LFIs should consult the UAE legal and regulatory framework currently in force. The controls discussed below should be integrated into the LFI's larger AML/CFT compliance program, and supported with appropriate governance and training.