A Practical Guide for DNFBPs in the UAE

Designated non-financial businesses and professions (DNFBPs) in the UAE play a critical role in safeguarding the integrity of the financial ecosystem. Although they are not classified as financial institutions, they face high exposure to money laundering and terrorist financing risks. Accordingly, DNFBPs are subject to comprehensive AML/CFT obligations, as mandated by the regulators. With the UAE currently under increased monitoring by the FATF and undergoing an “Enhanced Follow up Process”, DNFBPs are on high alert. Regulatory expectations have intensified, and enforcement is more active than ever.

This places additional pressure on DNFBPs to demonstrate robust compliance frameworks, particularly in areas such ascustomer due diligence (CDD), enhanced due diligence (EDD) for high-risk clients, and ongoing monitoring.In fact, ongoing monitoring is not just a standalone activity, it is a critical component of EDD, ensuring that high-risk customer relationships are continuously assessed for suspicious behavior. Effective ongoing monitoring enables DNFBPs to detect red flags in real-time, escalate concerns swiftly, and maintain detailed audit trails, strengthening both EDD efforts and overall compliance. In short, ongoing monitoring allows businesses to adapt to emerging risks in real-time and maintain compliance without relying solely on manual reviews.

Why Ongoing Monitoring is a Crucial Part of Enhanced Due Diligence (EDD)?

Ongoing monitoring is a fundamental component of Enhanced Due Diligence (EDD). Unlike standard due diligence, which is often limited to the onboarding phase, EDD requires a continuous review of customer activity throughout the business relationship. DNFBPs in the UAE are obligated to conduct enhanced due diligence for high-risk clients. This means regularly reviewing customer profiles, rechecking for sanctions or adverse media, and detecting unusual or suspicious activity over time and not just at onboarding. To support this, through ongoing monitoring businesses ensure that customer profiles remain up to date and aligned with the risk appetite. Key elements of this process include:

• Regular screening of customer profiles against local and global sanctions, adverse media and politically exposed persons (PEPs) lists to identify potential risks timely.
•  Regular checks on client activity to detect any red flags or deviations from expected behavior.
• Continuous assessments to ensure transactions align with the customer’s stated business and risk profile.
• Timely reporting of suspicious activities to the UAE FIU via goAML portal.
• Review of Customer Due Diligence (CDD) documents to ensure information remains accurate and up to date.
• Maintenance of comprehensive customer records for a minimum of five years.
• Periodic internal risk assessments, updated based on business nature and client base.
• Staff training to maintain awareness on AML trends and emerging typologies.

Why is Ongoing Monitoring Important for the DNFBPs?

Ongoing monitoring for the DNFBPs is crucial because risks evolve. A client who was low-risk during onboarding may appear on a sanctions list later, or their activity might begin to deviate from their declared purpose. If a business fails to detect these changes, they may unknowingly facilitate money laundering and might face penalties for non-compliance.

Real-World Use Case Example:

A gold trader onboarded a client last year who regularly bought small amounts of jewellery. With FinchSCAN’s ongoing monitoring feature, the client’s name is regularly rescreened against updated sanctions, watchlists, and adverse media databases. Recently, FinchSCAN flagged the client’s name due to new adverse media reports linked to financial fraud. This alert enables the business to take prompt action, such as conducting further due diligence or filing a suspicious activity or transaction report (SAR/STR), helping prevent potential regulatory violations.

Using Technology as an Enabler: Key Features of an Effective AML Compliance Solution

Some of the DNFBPs operate with limited in-house compliance capabilities, and that is why technology plays a critical role in bridging the gap between regulatory requirements and operational capacity. An effective AML platform should be built to address the unique AML compliance challenges and requirements of the DNFBPs. FinchSCAN offers the following features to assist businesses with enhanced due diligence (EDD):

Automated Name Screening

FinchSCAN automates name screening process during onboarding and due diligence stage, and screens your clients’ names against updated sanctions lists, politically exposed persons (PEPs), adverse media, and both local and global watchlists. The automation makes the process faster without relying on manual checks.

Ongoing Monitoring and Bulk Name Screening

DNFBPs are required to conduct ongoing monitoring of their clients to ensure they remain protected from exposure to high-risk profiles. FinchSCAN simplifies this process through bulk name screening, allowing users to efficiently monitor large client lists. For high-risk clients, the platform enables periodic rescreening of customer batch lists to detect any emerging risks. Automated checks against updated sanctions, PEP, and adverse media databases help reduce the risk of oversight and enhance timely risk detection.

Multi-Language & Transliteration Capabilities

FinchSCAN supports AML compliance operations in multilingual environments through both an Arabic-language dashboard and advanced transliteration capabilities. The FinchSCAN portal can be fully accessed in Arabic, improving usability for native-speaking teams. Meanwhile, FinchSCAN’s transliteration engine supports multiple languages, enabling enhanced name screening and reducing false negatives caused by script variations.

Regulatory/goAML Reporting

FinchSCAN supports the generation of suspicious activity reports (SARs) and suspicious transaction reports (STRs) compatible with goAML portal, helping DNFBPs meet mandatory reporting requirements efficiently.

Record Management & Audit Trails

FinchSCAN supports AML regulations of record-keeping obligations by maintaining a complete digital audit trail. Screening log and audit reports are securely stored on the platform and accessible at any time with an active profile. These records are retained for an unlimited time and eliminating the need for manual systems.

Strengthen your AML Compliance Framework with FinchSCAN

Ongoing monitoring is a regulatory expectation, not a one-time task. For DNFBPs, risk profiles can shift over time, and failure to detect changes may result in compliance breaches, financial penalties, or regulatory action. Effective name screening, timely adverse media detection, and clear audit trails are critical to maintaining a strong compliance framework. FinchSCAN supports DNFBPs by enabling continuous screening of customer profiles, centralized record management, and regulatory-aligned reporting, empowering firms to meet AML obligations with both efficiency and confidence.