Ask once. Get a grounded answer.
Every answer is anchored in your policies, procedures, obligations and controls. When the agent can't be sure, it refers to the compliance officer — with a full trail. The MLRO sees every question and every response.
- Can I onboard a new settlor introduced by a Tier-3 intermediary if the SoW evidence is one bank reference letter?11:42
- RegAlign · grounded
No — not on a single bank reference. Tier-3 intermediary relationships require two independent SoW corroborations under POL-AML §4.6 and the recently uplifted control CTL-SOW-022. A single bank reference is insufficient; pair it with an audited account statement, asset sale document, or tax return covering the relevant period.
AML/CFT Policy §4.6POL-AMLCTL-SOW-022 (Tier-3 SoW)CTL-SOW-022JFSC Handbook §6.3OBL-JFSC-46511:42 - We have a UAE-resident PEP applying through our family office desk. Do we need full board approval or MLRO approval?11:51
- RegAlign · grounded
MLRO approval is required, plus a documented EDD pack signed by the relationship principal. Board approval is required only where the PEP is a foreign Head-of-State / Head-of-Government per POL-PEP §3.2 — UAE family office not in itself. Open the policy below for the full decision matrix.
PEP & EDD Policy §3.2POL-PEPEDD Procedure — Family Office deskPROC-EDD11:51 - Has the JFSC's expectations changed on outsourced AML monitoring providers since the June dear-CEO letter?12:08
- Refer to Compliance
I don't have a grounded answer for this — the dear-CEO letter is in the regulatory inbox but hasn't been ingested into our policy set yet. Refer to Compliance for a definitive view.
12:08
RegAlign answers only from grounded sources. Otherwise it refers.