Not Just for Banks: AML/CFT Controls for Healthcare, Retail & Construction

AML/CFT isn’t a “bank problem.”

The UAE explicitly regulates DNFBPs (Designated Non-Financial Businesses and Professions) and sets expectations on risk assessments, customer/vendor due diligence, sanctions screening, monitoring and recordkeeping.

If your business accepts cash, issues refunds, or uses layered subcontractors, your exposure is real, and regulators increasingly expect proportionate controls with evidence.

Sector risk snapshots (practical, not theoretical)

• Healthcare & clinics: Identity fraud at intake, insurance fraud, cash receipts, complex cross-border lab payments.

• Retail & e-commerce: Chargeback laundering, refund abuse, high-risk goods or marketplace sellers, mule accounts.

• Construction & contracting: Subcontractor chains, inflated invoices, cash wages, and TBML risks on imports.

What the UAE framework expects

• Risk-based approach (RBA): Identify higher-risk clients, products, countries, delivery channels and apply enhanced measures proportionately, document the rationale.

• CDD/KYB/KYV: Capture trade licenses, UBOs, sanctions and adverse media checks; verify bank coordinates; set refresh cadence by risk level.

• Monitoring (fit-for-purpose): Even “lite” rules (e.g., unusual refund patterns, split payments, repeated vendor round-tripping) require a rulebook, thresholds, and exception logging with approvals.

• Records & cooperation: Maintain retrievable records for the statutory period and be able to provide them promptly to competent authorities.

  
  

A proportionate control pack that actually works

1. Onboarding checklists: DNFBP-aligned CDD/KYB/KYV templates; evidence of verification; sanctions logs with time stamps.

2. Payments hygiene: Dual control for refunds, cash thresholds, exception memos with compensating controls.

3. Monitoring rules: E.g., frequent refunds to the same debit card; vendor invoices split within 5% of approval limit; high-risk country shipments with mismatched paperwork.

4. Registers: Incidents, breaches, conflicts; all searchable and exportable.

5. Training: Role-based micro-modules (cashiers, clinic admin, procurement, finance) with pass marks and audit trail.

   
   

What “good” looks like to an auditor

• Clear risk scoring; EDD triggers demonstrably applied.

• Exceptions documented with rationale and sign-off.

• Retrievability: Full investigation file produced within 48h, with attachments (screening exports, approvals, invoices, communications).

How Marensa helps

• Sector Playbooks (Healthcare, Retail, Construction): risk scenarios, red-flags, sample monitoring rules, and escalation thresholds mapped to UAE DNFBP guidance.

• Implementation: Selection and configuration of sanctions/AML tools, vendor scorecards, exception workflows, and a secure evidence vault.

• Assurance: Quarterly “lite” testing + annual independent effectiveness review sized to non-financial sectors.Outcome: A DNFBP-compliant, proportionate AML/CFT program with real artefacts, not overhead.