CMA Guidance of 2023 · UAE Federal
Sets the minimum content of the semi-annual compliance officer or MLRO report on AML/CFT compliance that securities firms and virtual asset service providers licensed by the Authority must prepare.
The Minimum Standards for the Semi-Annual AML/CFT Report set out what the compliance officer's or MLRO's half-yearly report must contain at securities firms and virtual asset service providers licensed by the Securities and Commodities Authority (now the Capital Market Authority). The report must be approved by the board, or by the owner or partners where there is no board, and filed with the regulator within two months of each period end.
The document rests on the duty in the federal AML legislation for the compliance officer to review the firm's internal rules, assess their consistency with the law and the firm's adherence to them, propose updates, and report semi-annually to senior management, with a copy and management's remarks sent to the supervisor. It cites Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019, since replaced by Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
The report covers the six-month periods ending 30 June and 31 December. It goes to top management and the board, or to the owner or partners where there is no board. A copy, with the board's or owners' comments, must reach the regulator within two months of the period end, which means by the end of August and the end of February. Firms must keep the reports and related correspondence and have a process for answering the regulator's queries.
The prescribed structure has six parts. They are an executive summary; an assessment of the AML/CFT and sanctions programme (governance, enterprise-wide risk assessment, policies, customer risk rating, simplified, standard and enhanced due diligence, ongoing monitoring, screening, PEP monitoring, training and record keeping); an action plan with owners, metrics and a status update on the previous plan; conclusions and recommendations; approval and submission; and appendices with up to fifteen compliance indicators, such as the number of high-risk customers, SARs filed and staff trained.
Securities firms and virtual asset service providers licensed by the Securities and Commodities Authority (now the Capital Market Authority), their compliance officers or MLROs, senior management, and boards of directors or, where there is no board, owners or partners.
English official text in 6 passages. Open the full text or jump to a provision:
| Paragraph – Legal Background | The compliance officer reviews internal AML rules for consistency with the law, proposes updates and prepares semi-annual reports to senior management; a copy with management's remarks goes to the supervisory authority. |
| Paragraph – Roles and Responsibilities | Reports cover six-month periods ending 30 June and 31 December, are reviewed and approved by senior management and the board, and are sent to the regulator with board comments within two months of period end. |
| Section II | The assessment must evaluate governance controls, the enterprise-wide risk assessment, policies, customer risk rating, due diligence levels, ongoing monitoring, screening, PEP monitoring, training and record keeping. |
| Section III | The action plan lists proposed actions with timelines, responsible persons and success metrics, updates progress on the previous plan and explains any delays, and identifies risks to implementation. |
| Section V | Records approval by the board, or the owner or partners where there is no board, and submission of a copy to the regulator with their comments within two months of the period end. |
| Section VI | Appendices may include fifteen indicators, such as high-risk customers and transactions, SARs filed, staff trained, policy updates, regulator interactions, risk assessments conducted and PEPs identified. |
Polaris is not licensed by the CMA and does not act as MLRO for regulated firms. This document affects how we run the company secretarial side for clients that hold, or are applying for, a CMA licence. The semi-annual report needs a board or owners' approval twice a year, so we put the June and December reporting cycles into the client's corporate calendar, prepare the board or shareholder resolutions approving the report, and keep the signed minutes on the corporate record for inspection. The report itself is prepared by the client's MLRO or licensed compliance adviser.
| Cites | AML Implementing Regulation 2019 (repealed) · AML Law 2018 (repealed) |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
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