05/07/2026
Applying the same due diligence to all clients? That is an AML compliance failure.
Basic CDD (standard / low risk): ✅ Identity verification (passport, Emirates ID) ✅ Address confirmation ✅ Business purpose and nature of relationship ✅ Standard ongoing monitoring
Enhanced CDD triggers (apply when ANY of these exist): 🔴 Client is a Politically Exposed Person (PEP) 🔴 Client is from or connected to a high-risk country 🔴 Complex or opaque ownership structure 🔴 Unusually large or structurally complex transactions
Enhanced CDD requirements: 📋 Deeper source of funds and wealth documentation 📋 Senior management approval — documented BEFORE onboarding 📋 More frequent ongoing monitoring 📋 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.