One more thematic review

ONE MORE THEMATIC REVIEW…

This time, the FSRA: FCCP-Notice No.12 of 2023 regarding the Joint Guidance on common themes observed during the TFS thematic Review of FIs and DNFBPs

Unless you have been living under a rock, you are familiar with the TFS updates that keep hitting your inbox.

Well, all those surveys resulted in a Targeted Financial Sanctions Thematic Review in the UAE.

I know, it may sound a bit dry, but trust me, it's actually pretty interesting! 

Basically, the review was conducted by a group of regulatory authorities, including the Ministry of Justice, Ministry of Economy, DFSA, and FSRA, and it focused on ensuring that Regulated Entities in the UAE are meeting their obligations when it comes to financial sanctions.

So what did they find?

Well, the review identified a number of areas where Regulated Entities could improve their compliance with TFS obligations. For example, they found that senior management should have a closer oversight over Regulated Entities’ Sanctions Risk Framework and should regularly update their Sanction Compliance Programs to ensure they're effective.

Also, TFS screening systems. Firms must have effective screening systems that are appropriate to the nature, size, and risk of their business. They should also conduct quality control checks on a regular basis, screen their client database on an ongoing basis, and remain aware of dual-used goods lists issued by the EOCN.

Is it too technical for me?

Now, I know that all of this might sound a bit technical, but the bottom line is that it's really important for Firms to comply with TFS obligations. If they don't, it could result in enforcement actions by the Supervisory Authorities against them.

Oh shoot. Tell me more. 

So if you're interested in learning more about the Targeted Financial Sanctions Thematic Review in the UAE, I highly recommend checking out the published circular here. And if you're a Regulated Entity such as a LFI or a DNFBP, be sure to take note of the identified weaknesses and gaps, and implement necessary measures to strengthen your TFS framework before 31 July 2023.

That’s in 3 months. So get cracking!