- Licensing and registration — VASPs must obtain the appropriate license from UAE or Dubai authorities before offering services.
- Risk-based AML program — Written AML/CFT policies, periodic risk assessments, and governance structures are required.
- Customer due diligence and KYC — Identity verification, beneficial ownership checks, and enhanced due diligence for PEPs and high-risk clients are mandatory.
- Transaction monitoring and reporting — Real-time monitoring, anomaly detection, and timely suspicious transaction reports to designated authorities are required.
- Record-keeping and audit trails — Retention of transaction records, KYC files, and logs for regulator inspection and forensic review is mandated.
- Sanctions screening and cross-border controls — Filtering against sanctions lists and controls on transfers to high-risk jurisdictions are enforced.
- Technology governance and custody safeguards — Secure key management, wallet custody policies, incident response, and operational resilience controls are required for platforms and custodians
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