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Dubai Financial Services Authority (DFSA): Contents

Dubai Financial Services Authority (DFSA)
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Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML) [VER16/07-19]
AML 7 Customer Due Diligence
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AML 7.3.8 Guidance on politically exposed persons



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9. Individuals who have, or have had, a high political profile, or hold, or have held, public office, can pose a higher money laundering risk to a Relevant PersonG as their position may make them vulnerable to corruption. This risk also extends to members of their families and to known close associates. Politically Exposed PersonG ("PEP") status itself does not, of course, incriminate individuals or entities.
10. Generally, a foreign PEPG presents a higher risk of money laundering because there is a greater risk that such person, if he was committing money laundering, would attempt to place his money offshore where the customer is less likely to be recognised as a PEPG and where it would be more difficult for law enforcement agencies in his home jurisdiction to confiscate or freeze his criminal property.
11. Corruption-related money laundering risk increases when a Relevant PersonG deals with a PEPG . Corruption may involve serious crimes and has become the subject of increasing global concern. Corruption offences are predicate crimes under the Federal AML legislation. A Relevant PersonG should note that customer relationships with family members or close associates of PEPsG involve similar risks to those associated with PEPsG themselves.
12. The DFSAG considers that after leaving office a PEPG may remain a higher risk for money laundering if such person continues to exert political influence or otherwise pose a risk of corruption.
13. The fact that an individual is a PEPG does not automatically mean that the individual must be assessed to be a high risk customer. A Relevant PersonG will need to assess the particular circumstances relating to each PEPG to determine what risk category is appropriate. If the PEPG is assigned a high risk, then the Relevant PersonG will need to undertake the Enhanced Customer Due DiligenceG measures under AML Rule 7.4.1. However, even if a PEPG is not assigned a high risk, the Relevant PersonG is required as a minimum to undertake the additional customer due diligence measures specified in AML Rule 7.3.8(2) and (3) for PEPG s.
Derived from RM117/2013 [VER9/07-13]
[Amended] DFSA RM196/2016 (Made 7th December 2016). [VER13/02-17]
[Amended] DFSA RM231/2018 (Made 6th June 2018) [VER15/07-18]