ADGM AML and sanctions obligations remain with the regulated firm even when screening tools, introducers, agents, outsourced operations, data providers, or managed services support the process.
Official sources
What teams need to do
- Map third parties involved in onboarding, CDD, sanctions screening, monitoring, escalation, and
recordkeeping.
- Review provider capability, data quality, auditability, confidentiality, and sanctions exposure.
- Document reliance, outsourcing, escalation, quality assurance, exceptions, and remediation.
- Monitor list changes, provider performance, issues, and incidents.
Evidence to maintain
- Provider and reliance inventory.
- AML and sanctions workflow maps.
- Screening, data-quality, escalation, exception, and remediation records.
- Contracts, audit rights, confidentiality, and management reporting.
Common gaps
- Reliance parties and software providers are not distinguished.
- Screening data quality is not reviewed.
- Exceptions and remediation are outside the third-party record.
How Halbarad helps
Halbarad helps financial-crime teams connect providers, workflows, evidence, exceptions, remediation, sanctions changes, and audit trail.
Disclaimer
This guide is for general information only and is not legal advice. Review the official regulation, guidance, and supervisory materials, and consult qualified counsel or compliance advisors for your organization's specific obligations.