Useful guides and templates

The Supervised Entities shall appoint the Compliance Officer and Deputy-Compliance Officer. In the event of the former is absent, or when the position becomes vacant, the Deputy-Compliance Officer shall temporarily fill in for the Compliance Officer, and shall be bestowed the necessary powers and authorities to perform the assigned role effectively, objectively, and independently (Articles 6 of the AML/CFT implementing Regulations, and Articles 8, 15, and 17 of the MOCI Rules).
The Compliance Officer manages the Supervised Entity’s commitment to Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) obligations, contained in the Law, regulations, and rules. The Compliance Officer shall be the main point of contact between the Supervised Entity, the Financial Information Unit, the Anti-Money Laundering and Terrorism Financing (AML/CFT) Section, and other competent authorities in the State, in all AML/CFT-related matters. (Please see Circular No. (7) of 2021 regarding the responsibilities and tasks of compliance officials and their deputies to auditors, traders of precious metals or precious stones, trust fund service providers, and companies.
An official in the senior management of the Supervised Entity shall fill in a form for the appointment/change of the Compliance Officer and their deputy, such that it be signed by the said official, and addressed to the AML/CFT Section, with the documents specified in the form .

If the Supervised Entity operates within the framework of a commercial company, it must specify at least one Qatar-based natural person, who is authorized to provide all the information contained in the mandatory records, and to provide assistance upon request (Decision of the Minister of Commerce and Industry No. (2) of 2020 on the Implementation of the AML/CFT Requirements related to Commercial Companies).
The legal representative of the company shall file a form appointing/changing the information provider and their deputy, such that the form be signed by the legal representative, and addressed to the Companies Affairs Department and the Commercial Registration and Licenses Department at the Ministry of Commerce and Industry, with the documents specified in the form attached.
For more information, please review the Commercial Companies Compliance Guide with AML/CFT Requirements (coming soon).

The Compliance Officer of the Subject Entity shall submit to the Senior Management an annual report on AML/CFT issues, within four months of the end of each fiscal/tax year of the Subject Entity. The Senior Management would hence be able to carry out AML/CFT requirements, in accordance with the provisions of the Law, the Regulations, and the Obligation Rules.
For more information on the content and means of preparing the Compliance Officer Annual Report, please see Compliance Officer Annual Report: Practical Guidance on Preparing and Submitting Compliance Officer Annual Report on AML/CFT Issues.

Supervised Entities shall immediately inform the Financial Information Unit of any transaction, or an actual/attempted operation, regardless of its value, when suspicious, or having reasonable grounds to suspect that the transaction/operation is linked to the proceeds of a predicate crime, or to the financing of terrorism.
Suspicious operations must be reported by preparing a report of suspicion, in accordance with the form approved by the Financial Information Unit, and the instructions, guidelines, and evidence the Unit issues.
For more guidance on the obligation to report suspicious transactions, please refer to the Financial Information Unit website: http://www.qfiu.gov.qa.

As part of the AML/CFT Section exercising its control competencies over the entities subject to its supervision and follow-up, a Self-assessment Questionnaire shall be sent to the Supervised Entities at the beginning of each year, to guide the Section in preparing the institutional risk classification of the Supervised Entities, and drafting the annual monitoring and inspection plan based on the said classification, as per a risk-based approach.
In accordance with the specified deadlines, the Supervised Entities shall answer the questionnaire, and attach all documents supporting its responses, provided that the AML/CFT Section, through site and field inspections, verifies the correctness of information and support documents provided by the Subject Entity as proof of commitment.
For more information, please see Circular No. (6) of 2022 on Supervised Entity Obligations in Relation to the Self-assessment Questionnaire.

Independent Audit Report:

The AML/CFT Program established by the Subject Entity includes an independent audit unit to conduct continuous and appropriate evaluation, review, and testing, in order to assess the extent of compliance with policies.
The Subject Entity shall ensure the review and testing be conducted at least once every two years by an internal audit unit, or by the Compliance Officer at any other branch of the office/company. The review and testing may be carried out by an external auditor or by an independent person having the necessary competence, qualifications, professional skills, and integrity.
For more information on preparing an independent audit report, please see “Guidelines for Preparing AML/CFT Independent Audit Reports.”.
The Annual Report of Compliance Officer

Instructions for preparing AML/CFT policies for Supervised Entities: (Coming soon)

Supervised Entities shall develop a program that includes the necessary AML/CFT policies, procedures, and internal controls, in a manner that takes into account the Supervised Entities’ nature, the money laundering and terrorist financing risks to which they are vulnerable, as well as the size and complexity of their business.
Guidance regarding the preparation of AML/CFT policies in the Supervised Entity provides the broad outlines and main principles that each Supervised Entity must include in the policies, procedures, systems, and controls it follows, to ensure the adequate and appropriate observation of the requirements of Law No. (20) of 2019 Promulgating the Combating Money Laundering and Terrorism Financing Law, its Bylaws, and MOCI Rules.
These guidelines represent the minimum requirements that must be available in the enacted policies. Each Supervised Entity has to add its own procedures and regulations according to its size, nature of its business, and its business risk-assessment.