AML/TFS Compliance Gaps Identified by ADGM RA in 2025

In this episode of **The Riffle**, we examine the key findings emerging from the **ADGM Registration Authority’s 2025 DNFBP AML/TFS Onsite Assessments** and their implications for Designated Non-Financial Businesses and Professions (DNFBPs) operating within ADGM. The discussion explores recurring compliance gaps identified across 35 onsite assessments, highlighting the difference between having documented AML/TFS frameworks and effectively implementing them in practice. Topics include deficiencies in Business Risk Assessments (BRAs), Customer Risk Assessments (CRAs), Enhanced Customer Due Diligence (ECDD), governance oversight, and the treatment of Targeted Financial Sanctions (TFS) risks. Further, the episode examines regulatory expectations surrounding risk-based methodologies, ongoing customer monitoring, source of wealth and source of funds verification, senior management approvals for high-risk relationships, and the importance of substantive annual AML/TFS reviews. It also discusses the Registration Authority’s recommended good practices, including independent testing of AML controls, dynamic risk assessments, and strengthened governance frameworks. Special attention is given to the Registration Authority’s expectation that all DNFBPs conduct a risk-based self-assessment, implement remediation plans where necessary, and demonstrate active senior management oversight to address identified weaknesses. A concise briefing for compliance professionals, MLROs, risk officers, legal advisors, auditors, corporate service providers, real estate firms, accounting practices, and other ADGM-regulated DNFBPs seeking to understand the Registration Authority’s supervisory priorities and strengthen the effectiveness of their AML/TFS compliance frameworks. 🎙️ **Presented by 10 Leaves**.