Apply risk-based CDD and a risk rating to every client, verifying the client and UBOs before or while establishing the relationship or before an occasional transaction; CDD is triggered by new relationships, occasional transactions of AED 3,500 or more (including linked ones), suspicion, doubts about identification or high-risk clients. Verify individuals' identity documents, nationality, address, place of birth and employer, and entities' name, type, attested constitutional documents, place of business and senior managers; PEP relationships need MLRO and senior management approval; verify authorised agents, understand the purpose, ownership (including DAOs) and a business client's own clientele; do not onboard or transact without CDD; remain liable where third parties perform CDD. High-risk or PEP-linked clients need enhanced due diligence including source of funds and wealth, enhanced monitoring, senior management approval, a first payment from an account in their name at a regulated institution, and verified residential address.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.