Effective risk mitigation is critical to protecting the LFI, complying with its legal obligations, and meeting supervisory expectations. When establishing and maintaining relationships with cash-intensive businesses, LFIs should establish policies, procedures, and processes to identify higher-risk relationships, assess AML/CFT risks of the cash-intensive business, conduct due diligence at account opening and throughout the relationship, and monitor these relationships for unusual or potentially suspicious activity. When performing a risk assessment of cash-intensive businesses, LFIs should allocate resources to those accounts that pose the greatest risk of money laundering or financing of terrorism and illegal organisations. To that end, LFIs should understand their risk and take effective, risk-based steps to protect themselves from abuse and from illicit actors and transactions.

The sections below discuss how LFIs can apply specific preventive measures to identify, manage, and mitigate the risks associated with cash-intensive businesses. 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 information.⁶ The controls discussed below should be integrated into the LFI’s larger AML/CFT compliance program and supported with appropriate governance and training.

⁶ Available at https://www.centralbank.ae/en/cbuae-amlcft.