October, 2025
1. Introduction ... 3 1.1. Purpose ... 3 1.2. Applicability ... 4 1.3. Legal Basis ... 5 1.4. Acronyms ... 5 2. Scope of the Role-Based AML/CFT/CPF Training ... 6 2.1. UAE Regulatory Requirements, Supervisory Guidance, and Global Standards ... 6 2.2. Internal Policies, Procedures, and Processes ... 8 2.3. LFI's Products, Services, Customers, and Geographic Locations ... 8 3. Role-Based Training ... 9 3.1. Board of Directors/Owners and Senior Management ... 10 3.2. First Line of Defense ... 11 3.3. Second Line of Defense ... 13 3.4. Third Line of Defense ... 14 4. Documenting the AML/CFT/CPF Training Program ... 15 4.1. Training Plan ... 15 4.2. Updates to the AML/CFT/CPF Training Program ... 15 4.3. Methods for Training Delivery ... 17 4.4. Training Records, Documentation, and Assessment ... 18 5. Annexure 1: Synopsis of the Best Practice ... 19
A comprehensive anti-money laundering (“AML”) and combating the financing of terrorism (“CFT”) and countering proliferation financing (“CPF”) training program is critical to the ov...