Design an appropriate AML/CFT compliance program for the Company to remain compliant with applicable AML/CFT Laws, Regulations, Notices, Standards, Guidelines and international best practice always.
Oversee the development of the Company’s ML/FT/PF risk assessment and ensure its dissemination and updates, as required.
Ensure development of a clear, comprehensive and documented methodology for meeting sanctions screening obligations.
Establish and maintain appropriate AML/CFT policies, procedures, processes and controls.
Ensure day-to-day compliance of the business against internal AML/CFT policies and procedures.
Act as the key contact point regarding all AML/CFT related matters/ queries from the Central Bank, FIU and any other competent authorities and to act, as appropriate, and report to Non-Executive Director accordingly.
Receive suspicious transactions or activity alerts from employees and review/investigate/analyze them to take appropriate decisions to report all suspicious cases/transactions to the FIU.
On-going monitoring of transactions to identify high-risk, unusual and suspicious customers/transactions and ensure that Transaction Monitoring System is appropriate and functioning as designed.
Central point decision taker for filing of all STRs/SARs in the business, to analyze and take appropriate decisions on disclosures for submission to the FIUs in a timely manner or deciding not to submit and keeping records thereof with complete confidentiality. Also, submitting other reports to the FIU is required without any delay.
Submit Fund Freeze Report (FFR) and Partial Name Match Report (PNMR) to the FIU through GoAML portal, as per Executive Office of the Committee for Goods/Materials subjected to Import and Export Control and CBUAE guidelines on Targeted Financial Sanctions and taking action within the stipulated time, as required.
Ensure that there are no delays in clearing of Alerts (False Positives);
Collaborate with the Regulatory Authority and FIU, provide them with all requested data and allow their authorized employees to view the necessary records and documents that will allow them to fulfill their duties/obligations.
Develop and execute AML/CFT training programs for all staff/Non-Executive Director considering all relevant risks of ML/FT/PF/sanctions/financing illicit organizations including the ways/means for addressing them.
Provide necessary reports to the Non-Executive Director on all AML/CFT issues, on a quarterly basis at a minimum.
Arrange to retain all necessary support documents for transactions, KYC, monitoring, suspicious transaction reporting, AML training and related compliance matters for the minimum period for record retention as stipulated in the Standards.
Conduct regular gap analysis between the Company’s existing AML/CFT Procedures and most current Laws, Regulations, Notices, Guidelines and the Standards of the UAE in order to determine the extent of the Exchange’s level of compliance.
Propose actions required to address gaps, if any; and
Prepare Bi-Annual Compliance Reports, submit them to the Non-Executive Director and report to The Central Bank of the UAE along with the comments of Board of Director therein.
Ensuring appropriate AML/CFT controls and monitoring systems are in place to identify high risk or suspicious transactions and to meet all other CBUAE requirements.
Manage, evaluate and arrange for testing all Company's AML/CFT systems, processes and Policies/Procedures on a regular basis to ensure adequacy and relevance to legislation and regulation and to ensure appropriate and timely mitigation of any gaps or issues identified.
Ensuring that any contraventions/gaps identified by internal or external audits or examinations conducted by CBUAE or other third-party auditors on AML/CFT and Sanctions are escalated to Non-Executive Director for appropriate action and remedied in a timely fashion; and
Disseminating to relevant staff/Non-Executive Director all amendments, addendums, resolutions and circulars/guidelines by regulator and other competent authorities related to AML/CFT and sanctions and ensuring compliance thereof.

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Compliance Officer