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1. AML/CFT Framework Development Establish, implement, and maintain an effective AML/CFT compliance program tailored to the precious metals and stones industry. Develop and maintain the company’s AML/CFT policy manual, risk assessment framework, and Customer Due Diligence (CDD) procedures. Ensure compliance with Federal Decree-Law No. (20) of 2018, Cabinet Decision No. (10) of 2019, and guidance from the UAE Ministry of Economy and FIU. 2. MLRO Duties Act as the appointed MLRO as per UAE law. Receive, investigate, and report Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) to the UAE FIU via the goAML portal. Maintain a secure register of STRs filed and ensure proper record-keeping as per regulatory requirements. 3. Know Your Customer (KYC) & Due Diligence Conduct KYC/CDD and Enhanced Due Diligence (EDD) for high-risk customers, especially for: Cash transactions ≥ AED 55,000 Politically Exposed Persons (PEPs) Complex ownership structures Screen customers against sanctions lists, UN lists, and local blacklists. Ensure proper documentation for all customers and counterparties, especially in trade transactions. 4. Transaction Monitoring & Risk Assessment Monitor transactions for unusual or suspicious patterns (e.g. over/under invoicing, third-party payments). Perform Periodic AML Risk Assessments for business relationships and transactional activity. Identify and escalate red flags associated with Trade-Based Money Laundering (TBML). 5. Training & Awareness Conduct mandatory AML/CFT training sessions for staff at least annually, as required by the Ministry of Economy. Maintain training records and evaluate staff awareness on compliance obligations. 6. Regulatory Liaison & Reporting Serve as the main point of contact for regulators, including the Ministry of Economy, FIU, DMCC, and Central Bank (if applicable). Respond to requests for information or inspections by authorities. File High-Risk Transaction Reports (HRTs) and Large Value Cash Transaction Reports (LVCTRs) when required. 7. Internal Controls & Audits Perform regular internal compliance audits and implement corrective actions. Ensure all records (KYC, STRs, risk assessments) are stored securely for at least 5 years, in line with UAE legal requirements.
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