Insights
If your STR procedure ends at the moment of lodgement — suspicion formed, MLRO decides, report goes to the financial intelligence unit, file closed, customer handled carefully from then on — it is incomplete for a firm inside the Qatar Financial Centre. The…
Fifteen days apart at the end of 2025, two Saudi financial supervisors each put out a targeted financial sanctions rulebook. The Saudi Central Bank (SAMA) issued its Rules for the Implementation of Targeted Financial Sanctions by circular No. (472035766),…
If your UAE AML policy still cites Cabinet Decision No. (10) of 2019 — the implementing regulation of Decree-Law No. (20) of 2018 — it cites an instrument that no longer exists. The CBUAE Rulebook records its status as Repealed.
Section 14(1) of the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) requires every reporting person or auditor, as soon as he becomes aware of a suspicious transaction, to make a report to the FIU "promptly but not later than 5 working…
Global enforcement actions, regulatory moves & intelligence from the world of AML & financial crime.
Every jurisdiction in this series requires a suspicious transaction report. Two of the six put a number on the deadline. The other four use words: promptly and directly in Saudi Arabia, without delay and directly under UAE federal law, which is what firms in…
The texts in all six jurisdictions start from a similar idea: people who hold important public functions. Each then draws the edges differently: which relatives count, whether a domestic official is treated like a foreign one, and when senior management must…
When a bank or payment firm is asked to bank a virtual asset service provider, the first question is simple: is this firm licensed, and by whom? We checked that question against the regulators' own documents. Some answers come with a public register. One…
Each of our six jurisdictions implements UN targeted financial sanctions, and each also applies a domestic list alongside the UN list: for DIFC and ADGM, the UAE's federal one. Which list, which clock and who you tell afterwards are set locally. This is part…
Beneficial ownership is where customer due diligence meets company law. For an MLRO working across our six jurisdictions, two questions decide how much a register can do for you: where the ownership line is drawn, and whether you are allowed to look.
A working session with your compliance team, then a walkthrough against your own risk appetite: the lifecycle end to end, scoring weights set to your policy, and a review of the audit trail the system produces.
