Anti-Money Laundering and Know-Your-Customer Requirements
This domain tests the identification and reporting duties that sit on every licensed intermediary. Scenarios usually present an unusual client, an unusual funding route or an unusual trade pattern, and ask what the firm must do and to whom it reports.
Legal framework
The AML Law of 1386 (2007), as amended in 1397 (2018), its executive regulation, the Financial Intelligence Unit (مرکز اطلاعات مالی) as the receiving authority, and the SEO's AML directive binding securities firms. The CSDI operates SEJAM, the central client identification system used at account opening.
Customer due diligence
Identify and verify the client, whether natural or legal; establish the beneficial owner and look through corporate chains; understand purpose and expected activity; establish source of funds; screen against politically exposed person and sanctions lists; assign a risk rating; apply enhanced due diligence to high-risk cases; refresh data periodically. Anonymous and numbered accounts are prohibited.
Monitoring and reporting
Ongoing transaction monitoring against the client profile; suspicious transaction reports to the FIU filed promptly, without tipping off the client; reporting of large or unusual cash movements per threshold; asset freezing for designated persons; staff training, record retention and independent audit.
Worked example
A company opens an account whose shareholder register shows 60% held by an entity in a free zone, with no further detail. Reasoning: the broker must look through the chain to the controlling natural person, document each layer, screen that person for PEP and sanctions exposure, and rate the relationship higher risk if the ownership remains opaque. Registration in SEJAM alone does not discharge this duty.
Traps that cost marks
Treating SEJAM registration as the whole of CDD; ignoring beneficial ownership for corporate clients; warning the client that a report has been filed; assuming small accounts are exempt from identification.