DUBAI / WAM
The Dubai Financial Services Authority(DFSA) fined two individuals AED205,520 each for failing to act with due skill, care, which caused an Authorised Firm to breach the DFSA’s Anti-Money Laundering(AML) Rules.
Raphael Lilla and Kapparath Muraleedharan were both Licensed Directors and members of the Board of Directors at a DFSA Authorised Firm.
In August 2014, Lilla and Muraleedharan instructed the firm’s Senior Executive Officer and the Compliance and Money Laundering Reporting Officer to open three accounts for clients which had been assessed as “high risk”. Under the DFSA’s AML Rules, the firm was required to carry out Enhanced Customer Due Diligence on these clients before opening the accounts. However, Lilla and Muraleedharan dismissed the advice from the Senior Executive Officer and the Compliance and Money Laundering Reporting Officer that opening the accounts without the completion of Enhanced Customer Due Diligence would contravene the DFSA’s AML Rules.