AML Policies
Anti-money laundering requirements for ZDFZ entities and transactions.
What is AML?
Anti-Money Laundering (AML) refers to the policies, procedures, and regulations designed to prevent the generation of income through illegal activities and the disguising of that income as legitimate funds.
ZDFZ AML Framework
ZDFZ implements a risk-based AML program aligned with FATF recommendations and international best practices. All residents and entities are subject to appropriate AML requirements based on their activities and risk profile.
Core AML Principles
Know Your Customer
Verify the identity of all customers before establishing business relationships.
Transaction Monitoring
Monitor transactions for suspicious patterns and unusual activity.
Record Keeping
Maintain accurate records of all transactions and customer information.
Suspicious Activity Reporting
Report suspicious transactions to relevant authorities.
Who Must Comply?
AML requirements apply to different entities at different levels:
Financial Services Companies
Full AML program required including dedicated compliance officer.
- ✓ Payment processors and money service businesses
- ✓ Cryptocurrency exchanges and custodians
- ✓ Investment and fund management companies
Designated Non-Financial Businesses
Enhanced due diligence and reporting requirements.
- ✓ Real estate agencies
- ✓ Dealers in precious metals/stones
- ✓ Legal and accounting professionals
All Other Entities
Basic AML awareness and transaction monitoring.
- ✓ Technology and software companies
- ✓ Consulting and professional services
- ✓ E-commerce and digital services
AML Program Components
Financial services companies must implement these program elements:
Written Policies & Procedures
Documented AML policies tailored to your business operations.
Compliance Officer
Designated person responsible for AML compliance oversight.
Employee Training
Regular AML training for all relevant staff members.
Customer Due Diligence
Risk-based CDD procedures for customer onboarding.
Independent Testing
Regular audits to assess program effectiveness.
Transaction Monitoring
Red Flag Indicators
Watch for these suspicious transaction patterns:
- ⚠ Structuring - Breaking large transactions into smaller amounts to avoid reporting thresholds.
- ⚠ Unusual Patterns - Transactions inconsistent with customer's stated business or profile.
- ⚠ Shell Company Activity - Complex corporate structures with no apparent business purpose.
- ⚠ Rapid Movement - Funds quickly moved through accounts without business rationale.
- ⚠ High-Risk Jurisdictions - Transactions involving countries with weak AML controls.
Reporting Requirements
| Report Type | Threshold | Timeline |
|---|---|---|
| Suspicious Activity Report (SAR) | Any suspicious activity | Within 30 days |
| Large Transaction Report | $10,000 USD or equivalent | Within 15 days |
| International Wire Transfer | $3,000 USD or equivalent | Record keeping required |
| Annual AML Report | Financial services only | Within 90 days of year end |
Record Retention
Maintain these records for the specified periods:
Sanctions Screening
🔒 Mandatory Screening
All customers and transactions must be screened against:
- • UN Security Council Consolidated List
- • OFAC Specially Designated Nationals (SDN) List
- • EU Sanctions List
- • PEP (Politically Exposed Persons) databases
Penalties for Non-Compliance
⚠️ Consequences
- • Fines up to $100,000 per violation
- • License suspension or revocation
- • Removal from the Free Zone
- • Criminal prosecution in serious cases
ZDFZ AML Support
ZDFZ provides resources to help maintain compliance:
AML Policy Templates
Customizable templates for your AML program.
Training Resources
Online AML training courses for your team.
Screening Tools
Access to sanctions screening services.