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:
- Qatar Central Bank: banks, exchange houses, insurers, and finance and investment companies.
- Qatar Financial Markets Authority: brokerage firms and the Qatar Stock Exchange.
- Ministry of Justice: lawyers, authorised notaries and real estate brokers.
- Ministry of Commerce and Industry: certified public accountants, dealers in precious metals and stones, and trust and company service providers.
- QFC Regulatory Authority: businesses established in the Qatar Financial Centre.
- Regulatory Authority for Charitable Activities: non-profit organisations.
Frequently Asked Questions About AML Compliance
Is my business subject to anti-money laundering requirements in Qatar?
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.
Who supervises my sector?
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.
How long must customer and transaction records be kept?
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.
Can you file suspicious transaction reports on our behalf?
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.
What is a beneficial owner?
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.
Is an independent review of the AML programme required?
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.