Anti-money Laundering Officer with Real Estate Exp

6 months ago

Dubai Silicon Oasis, United Arab Emirates Al Awtan Contracting LLC Full time

The primary role of the AML Compliance Officer would include the following:
**-* The Compliance Officer must conduct the **Enterprise-Wide Risk Assessment* to identify and evaluate the company’s possible ML/FT risk exposure. This risk assessment must be aligned with the management-approved risk appetite. It must consider the relevant risk factors, such as the nature of buyers and sellers the company is associated with, the geographies of its operations, the nature of properties involved, the complexity of the transactions, delivery channels used, etc.

The outcome of the EWRA or the overall business risk assessment shall help the AML Compliance Officer understand the AML/CFT measures required to safeguard the company.

- The Compliance Officer (CO) must establish and implement comprehensive internal AML/CFT policies, procedures, and controls customized to its business operations and the assessed risk. The policies must consider the relevant AML regulations, including the specific guidelines, e.g., the Ministry of Economy’s supplemental guidance on AML/CFT for the real estate sector. The CO must periodically review and update the AML/CFT policies and procedures to ensure their relevance and effectiveness.

**-* CO is also responsible for ensuring that the company follows robust **Customer Due Diligence measures* before establishing any business relationship with a customer (whether a buyer, seller, property developer, lessor, or lessee). This should also include designing Know Your Customer forms and implementing adequate **customer risk assessment** methodology to determine the risk each customer poses to the company’s real estate brokerage business.

CO should also ensure that the company has deployed necessary systems and tools to conduct timely screening of the customers, to comply with **sanctions screening requirements** and determine whether the customer is a **Politically Exposed Person (PEP)** or has any adverse media against the person, suggesting involvement in any criminal activities.

In case of customer is identified as high-risk, Compliance Officer must ensure that **Enhanced Due Diligence measures** are applied to manage the increased ML/FT risk, including additional checks and verification related to the customer’s identity, source of their funds and wealth, etc.

**-* Ongoing monitoring is one of the essential aspects of overall AML compliance. The Compliance Officer must implement adequate systems and procedures to **identify suspicious activities* and monitor transactions and business relationships.

**-* The CO is, also known as a **Money Laundering Reporting Officer (MLRO)**, responsible for accurate and timely reporting of suspicious activities and transactions with UAE’s **Financial Intelligence Unit (FIU)*.

**-* Apart from filing **Suspicious Activity Report (SAR)* and **Suspicious Transaction Report (STR)**, the AML Compliance Officer of the real estate broker is accountable for the following additional reporting:

- Filing of the **Real Estate Activity Report (REAR)** on the **goAML portal**, furnishing details of the designated transactions related to the purchase/sale of Freehold real estate property,
- Preparing and submitting a periodic AML/CFT report to the company’s senior management, giving updates on the AML measures applied during the period, any red flags observed, any reports field with FIU, any additional requirements for AML resources, etc.,
- Submitting relevant information and documents to the supervisory authority when requested.

**-* One other essential function of the Compliance Officer is to develop the **AML training program* for the company’s employees, including the senior management, to create awareness around the AML program and promote strong compliance culture.

- The AML Compliance Officer is responsible for ensuring the maintenance of AML/CFT records and information in an organized manner for a minimum period of five (5) years from the end of the business relationship or transaction. However, the period threshold is six (6) years for the real estate agents and brokers operating in or from ADGM’s Financial Service Regulatory Authority (FSRA) or DIFC’s Dubai Financial Service Authority (DFSA).

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