The Abu Dhabi Global Market ('ADGM') announced, on 30 August 2022, that the Financial Services Regulatory Authority ('FSRA') had imposed a financial penalty of $360,000, reduced from $450,000, on Wise Nuqud Ltd, a licensed financial services provider operating in the ADGM, for its contravention of several applicable anti-money laundering ('AML') requirements under the Anti-Money Laundering and Sanctions Rules and Guidance Rulebook. In particular, the FSRA noted that it had found that Wise did not establish and maintain adequate AML systems and controls to ensure full compliance with its AML obligations, in violation of Rule 4.1.1(2) of the Rulebook, as it had failed to:

• identify and verify the source of funds, and the source of wealth, as part of its Enhanced Customer Due Diligence performed on a category of customers identified as high risk, before undertaking transactions on behalf of those customers, in violation of Rule 8.4.1(c) of the Rulebook;
• properly obtain the approval of senior management to establish business relationships with a category of customers that it had identified as high risk, in violation of Rule 8.4.1(e) of the Rulebook;
• consider customer nationality as part of its risk-based assessment of its customers, in violation of Rule 7.1.1(3)(d) of the Rulebook; and
• obtain and consider adequate information on the intended nature of business for a category of its customers as part of the customer risk assessment and due diligence it performed before establishing a business relationship with the customer, in violation of Rule 8.3.1(1)(c) of the Rulebook.

You can read the press release here and the final notice here.