AML & Compliance

AML/CFT compliance programmes for businesses in Qatar: risk assessment, policies and procedures, customer due diligence, staff training and independent review.

Anti-money laundering and counter-terrorist financing

We help businesses subject to Qatar's anti-money laundering requirements build a risk-based compliance programme, put it into practice and document it in a form they can present to their supervisor.

We provide anti-money laundering and compliance services through AML/CFT compliance programmes: policies and procedures, internal control system design, training and help in building compliance structures, for businesses that the law requires to apply anti-money laundering and counter-terrorist financing measures in the State of Qatar.

Law No. 20 of 2019 on Combating Money Laundering and Terrorism Financing, as amended, and its Executive Regulations issued by Council of Ministers Decision No. 41 of 2019 require financial institutions and designated non-financial businesses and professions to identify, assess and document their risks, adopt a risk-based approach, apply customer due diligence, keep records and report suspicious transactions. We turn these requirements into practical procedures that fit the size and nature of your business.

Responsibility for compliance stays with the business, its management and its compliance officer. Our role is to give them the tools, documents, training and independent review they need; we do not act in place of the supervisor or the Financial Information Unit.

What We Deliver

01

Business risk assessment

Assessing the money laundering and terrorist financing risks linked to your customers, countries, products, services and delivery channels, and documenting them in light of the national risk assessment.

02

Policies, procedures and controls

A written, risk-based compliance manual covering customer acceptance, due diligence, monitoring, internal reporting and record keeping for at least ten years.

03

Customer due diligence and KYC

Procedures to identify and verify customers and their beneficial owners, with enhanced due diligence for high-risk customers and politically exposed persons.

04

Beneficial ownership and statutory registers

Helping commercial companies keep and update their beneficial ownership register and other statutory registers under Minister of Commerce and Industry Decision No. 2 of 2022.

05

Targeted financial sanctions

Procedures for screening customers and counterparties against sanctions lists, with documented steps to follow when a match appears.

06

Compliance structure

Defining the role of the management-level compliance officer, internal routes for reporting suspicion, and screening standards for hiring staff.

07

Staff training

Ongoing training for management and staff on red flags, internal procedures and the prohibition on tipping off customers.

08

Independent review

An independent test of your AML programme that measures how well controls work and identifies gaps, with a report and a proposed remediation plan.

How We Build Your Compliance Programme

01

Understand the business and obligations

We establish whether your activity falls within the businesses and professions covered by the law, who your supervisor is, and which requirements apply to you.

02

Risk assessment

We gather information on customers, products, geographies and channels, then assess and document the risks in a report that can be provided to the supervisor on request.

03

Policies and procedures

We draft policies, procedures and forms suited to the size of your business and review them with management before approval.

04

Implementation and training

We support day-to-day implementation and train staff and the compliance officer to use the procedures.

05

Review and update

We review the programme periodically, or whenever risks or supervisory instructions change, and propose the updates needed.

Core Obligations Under the Law

01

Identify and document risks

Study, assess, document, monitor and keep updating money laundering and terrorist financing risks, and report on them to the supervisor on request.

02

A risk-based approach

Internal policies, procedures and controls proportionate to the nature and size of the business, applied effectively and reviewed and updated when needed.

03

Due diligence

When starting a business relationship, for occasional transactions above the set threshold, whenever there is suspicion, and when identification data seems doubtful or insufficient.

04

Record keeping

Keep transaction records and due diligence documents for at least ten years, in a way that allows any transaction to be reconstructed when needed.

05

Prompt reporting

Report any suspicious transaction, whatever its value, to the Financial Information Unit immediately, without disclosing the report to anyone unauthorised.

06

Targeted financial sanctions

Put suitable systems and preventive measures in place to ensure compliance with targeted financial sanctions.

Qatar's AML/CFT Framework

Alongside financial institutions, the anti-money laundering law covers designated non-financial businesses and professions, including real estate brokers, dealers in precious metals and stones, trust and company service providers, and lawyers, notaries and accountants when they prepare or carry out specified transactions for clients.

The National Anti-Money Laundering and Terrorism Financing Committee, chaired by the Governor, and the Financial Information Unit are both established at Qatar Central Bank; the Unit is operationally independent and serves as the national centre for receiving and analysing suspicious transaction reports. Supervision of compliance is divided by sector:

الاستشارات الادارية

Frequently Asked Questions About AML Compliance

The requirements apply to financial institutions and to designated non-financial businesses and professions, such as real estate brokers, dealers in precious metals and stones, trust and company service providers, and lawyers and accountants when they carry out specified transactions for clients. Commercial companies in general must also keep a register of beneficial owners. We help you establish exactly where your business stands.

The Executive Regulations assign supervisors by sector: Qatar Central Bank for banks, insurers and finance companies; the Qatar Financial Markets Authority for brokerage firms; the Ministry of Justice for lawyers, notaries and real estate brokers; the Ministry of Commerce and Industry for certified public accountants, dealers in precious metals and company service providers; and the QFC Regulatory Authority for firms in the Qatar Financial Centre.

At least ten years from the end of the transaction or business relationship, including due diligence documents, account files, correspondence and the results of any analysis, and they must be made available to the competent authorities without delay on request.

No. Reporting suspicious transactions to the Financial Information Unit is a direct obligation of the business itself, must be done immediately when suspicion arises, and disclosing to any unauthorised person that a report was made is prohibited. Our role is to design the internal reporting procedures and train staff and the compliance officer to recognise red flags.

The natural person who ultimately owns or effectively controls a legal person, or on whose behalf transactions are carried out, even where ownership is registered in someone else’s name. Businesses subject to the law must identify that person and take reasonable steps to verify their identity as part of due diligence.

The Executive Regulations require the AML programme to include an independent audit function to test the system, alongside a management-level compliance officer and ongoing training, proportionate to the risks and size of the business. We provide this review independently, observing the independence restrictions that apply if we are the entity’s external auditor.

Need an AML compliance programme?

Our team is here to help. Contact us to review where your business stands today and what your compliance programme is missing.