Practice notes are issued by the QFC Regulatory Authority to assist Firms implement their obligations under the relevant legislation and rules. They should be considered as persuasive rather than prescriptive and indicative of best practice.

Licensed Professional Firms- Annual AML/CFT Questionnaire Notice 2009

Licensed Professional Firms (i.e. Licensed Firms subject to the QFCRA AML/CFT Rules) are required to submit an Annual AML/CFT Questionnaire (Form Q19) to the Regulatory Authority. Firms are required to submit the questionnaire on an annual basis for the period ending 31 December, by 31 March the following year.

Firms should clearly articulate responses in the ‘boxes’ on the form to explain or elaborate on answers, as required.

The Regulatory Authority has developed a template report to assist Money Laundering Reporting Officers (“MLRO”) to discharge their reporting obligations as set out under Division 2.3C of the Anti-Money Laundering and Combating Terrorist Financing Rules 2010 (“AML/CFT Rules”).

Firms are reminded the report from the MLRO to Senior Management should enable senior management to discharge its responsibilities under the AML/CFT Law and Rules. Therefore, sufficient information should be articulated in the report that assesses the adequacy and effectiveness of the firm’s AML/CFT policies, procedures, systems and controls in preventing money laundering and terrorist financing.

For Firms that have a Money Laundering Reporting Officer (“MLRO”) non-resident waiver approved by the Regulatory Authority the attached template report should be used by MLROs to assist in discharging reporting obligations as set out in the conditions of the waiver.

The AML/CFT Self Assessment Questionnaire provides a practical method for Firms to focus on the key AML/CFT requirements and to enable them to gauge if they are effectively discharging their legal and regulatory obligations to prevent money laundering, terrorist financing and fraud. The completion of the AML/CFT Self Assessment will assist Firms in determining which policies, procedures, systems and controls need to be strengthened to ensure the Firm has an effective AML/CFT and fraud prevention regime in place.

Further to the enactment of the AML/CFT Law no (4) of 2010, which repealed the AML/CFT Law no (28) of 2002, the Qatar Financial Information Unit (FIU) introduced the “Guide to Money Laundering and Terrorist Financing Suspicious Transaction Reporting’. The guidance is issued to assist financial institutions and DNFBP’s meet their reporting obligations under the AML/CFT Law no (4) of 2010.