Page 27 - Focus Group

value equals or exceeds AED 55,000. This may and third parties involved, the country in which
include one or more transactions involving it operates or transacts with size or pattern of
transactions, nature of trade, and business
the same business relationship or customer, relationships.
whether related to a single item or set of 4. Report any suspicious activity: Have policies
items; or it may also include one or more and procedures in place for Suspicious
transactions which, in the judgment of the Transaction Reporting (STR).

dealer, appear to be structured so as to avoid 5. Keep complete records: Keep current,
the established threshold. complete and accurate records of every business
transaction.
Establish a Compliance Program 6. Transaction & Trigger Monitoring: Implement
Businesses dealing with precious metals, jewels a risk-based approach to ongoing monitoring of
and stones are expected to establish the framework transactions, cross-border trades, patterns and
for a risk-based compliance program, comprising business relationships.
of: 7. Cooperate fully with legal and regularity

1. Policy & Procedure Frame work: Develop authorities charged with enforcing anti-money
an AML/CFT program: client identification, laundering laws.
beneficial ownership or third-party business AML/ CFT Compliance is a journey and not a
relationship. destination, fraudsters will always look for new
2. Governance Framework: Putting in place an ways and means to break the system for Money
adequate governance framework for AML/CFT, Laundering (or Terrorism Financing) and the role
including appointing an AML/CFT Compliance of compliance officer is to ensure that he/ she is
Officer, and ensuring adequate staff screening above the curve to understand the pattern and
and training. work toward Control, Monitor, Detect, Prevent
and in an situation the transaction or event passes
3. Know Your Business Partners: Conduct a risk- though, timely report Suspicious Transaction to the
based assessment for exposure by its products, competent authorities.
services, and delivery channels, types of clients

Disclaimer:
This article and/or write ups and/or any of its content shall not be treated as opinion and/or advice in any circumstances of the author(s) and/ or the Chapter. Reader’s to apply their best
judgement in the best interest of their requirement and should seek a formal opinion on any issue.

The Institute of Chartered Accountants of India (Dubai) Chapter NPIO TAX JOURNAL 2020 27