05/07/2026
Applying the same due diligence to all clients? That is an AML compliance failure.
Basic CDD (standard / low risk): β
Identity verification (passport, Emirates ID) β
Address confirmation β
Business purpose and nature of relationship β
Standard ongoing monitoring
Enhanced CDD triggers (apply when ANY of these exist): π΄ Client is a Politically Exposed Person (PEP) π΄ Client is from or connected to a high-risk country π΄ Complex or opaque ownership structure π΄ Unusually large or structurally complex transactions
Enhanced CDD requirements: π Deeper source of funds and wealth documentation π Senior management approval β documented BEFORE onboarding π More frequent ongoing monitoring π Enhanced transaction monitoring
The missed step: senior management approval must be written, filed, and traceable. A verbal sign-off is not acceptable in an inspection.
At Velmont Crest, we build tiered CDD frameworks that are fully UAE AML compliant.