AML Thresholds Across CISI Exams: A Side-by-Side
Every CISI exam in financial services touches AML/CFT — but the testable thresholds differ by regime. UAE FRR uses dirham amounts and SCA-specific timelines; the UK Combating Financial Crime (CFC) exam tests UK Money Laundering Regulations thresholds; ICWIM picks up the international principles. Confusing them costs marks. This guide lines them up side-by-side.
Customer Due Diligence (CDD) trigger thresholds
"At what transaction size does CDD become mandatory?" is the most-tested AML topic. The answer depends on the regime and the transaction type:
Visual takeaway: the OCCASIONAL transaction thresholds across UAE, UK and EU are roughly comparable in GBP terms (~£12–13k). The WIRE TRANSFER thresholds are an order of magnitude lower (~£750–860) — wire transfers are higher AML risk because they cross institutions and jurisdictions quickly.
| Transaction type | UAE (FRR) | UK (CFC / MLR 2017) | EU (5MLD) |
|---|---|---|---|
| Occasional transaction | AED 55,000 (~£12k) | €15,000 | €15,000 |
| Wire transfer | AED 3,500 (~£750) | €1,000 | €1,000 |
| Linked transactions | Same as occasional (aggregated) | Same as occasional (aggregated) | Same as occasional (aggregated) |
| Cash payment (high-value dealers) | Covered separately under DNFBP rules | €10,000 (UK applies €10k cash threshold) | €10,000 |
Note the UAE wire-transfer threshold (AED 3,500) is far lower in nominal terms than the UK/EU €1,000 — but they're roughly comparable in £ terms. The UAE chose the very low local figure to track FATF Recommendation 16 strictly.
Beneficial ownership identification
| Regime | BO threshold | Fallback if no natural person meets it |
|---|---|---|
| UAE FRR | ≥ 25% ownership or controlling interest | Senior managing official |
| UK MLR / CFC | ≥ 25% shareholding or voting rights | Senior person (e.g. director) treated as BO |
| FATF Recommendation 24 | ≥ 25% (the global benchmark) | Senior managing official |
The 25% threshold is one of the few places where the regimes align — driven by FATF's Recommendation 24 acting as a common reference point. If you only remember one BO number across all your exams, it's 25%.
Record retention
| Record type | UAE (FRR) | UK (MLR / CFC) |
|---|---|---|
| CDD & transaction records | ≥ 5 years from transaction completion OR business-relationship end (whichever is later) | ≥ 5 years from end of business relationship or transaction date |
| Standard licensed-body records (non-AML) | ≥ 10 years (Ch 2 of FRR) | Varies by FCA handbook; typically 5–6 years |
| Employee records | 10 years from last update | UK ICO guidance: 6 years post-employment typical |
Penalty regimes
| Offence | UAE FRR | UK MLR |
|---|---|---|
| Standard ML — natural person | ≤ 10 years + AED 100k–5m | Up to 14 years' imprisonment (POCA 2002 s.327-329) |
| Aggravated ML / organised crime | Temporary imprisonment + AED 300k–10m | Long sentences via sentencing council guidelines |
| Terrorism financing | Life or ≥ 10 years + AED 300k–10m | Up to 14 years (TACT 2000) |
| ML — legal person fine | AED 500,000–50,000,000 | Unlimited fine (UK courts) |
| Failure to report STR | Imprisonment + AED 100k–1m | Up to 5 years' imprisonment + unlimited fine |
| Tipping off | ≥ 6 months + AED 100k–500k | Up to 2 years' imprisonment + unlimited fine |
The UAE FRR gives you precise numerical ranges to memorise. The UK CFC tends to test penalty CONCEPTS rather than exact maxima — but you should still know the headline (e.g. "up to 14 years for substantive ML" for POCA).
Suspicious activity reporting
| Topic | UAE FRR | UK CFC |
|---|---|---|
| Report name | Suspicious Transaction Report (STR) | Suspicious Activity Report (SAR) |
| Filed with | Financial Intelligence Unit (FIU) | National Crime Agency (NCA), via UKFIU |
| Timing | Immediately / without delay | "As soon as practicable" |
| Tipping off rule | Criminal (≥6 mo + 100k-500k AED) | Criminal (up to 2 yr imprisonment) |
| Defence Against Money Laundering (DAML) | N/A — no UAE equivalent | UK-specific: 7-day notice period + 31-day moratorium |
Watch for the report-name distinction: UAE uses "STR" (transaction-focused); UK uses "SAR" (activity-focused, broader). Both are criminal triggers, but the UK has the additional DAML mechanism for consent-based defences.
PEP rules
| Topic | UAE FRR | UK CFC | FATF |
|---|---|---|---|
| Foreign PEPs | EDD required | EDD required | EDD required (Rec 12) |
| Domestic PEPs | Risk-based | Risk-based (post-Brexit "no automatic EDD") | Risk-based |
| "Stepped down" PEP | Continued EDD for at least 12 months | UK approach: 12 months post-step-down | Recommends 12+ months |
| Senior management approval | Required at establishment / continuation | Required at establishment / continuation | Required |
Compliance officer reporting cadence
| Regime | Minimum cadence | To whom |
|---|---|---|
| UAE FRR | Semi-annually | Senior management / Board |
| UK FCA / MLR | At least annually (MLRO annual report) | Senior management / governing body |
| FATF guidance | Recommends periodic, no fixed minimum | Senior management |
The UAE's semi-annual minimum is stricter than the UK's annual one. If you're sitting both exams, lead with "semi-annual" if the question is in a UAE context.
Quick reference: the "memorise pairs" approach
Across CISI AML curricula, certain trap-pairs come up repeatedly. Pair-drill them:
| Pair | How to remember |
|---|---|
| UAE FRR: AED 55,000 / AED 3,500 | "55 occasional, 3.5 wire" — wire is much lower (FATF Rec 16 anti-funding) |
| UAE FRR: 100k–5m / 500k–50m | Natural vs legal-person ML fines — both digits scale 5× for legal person |
| UAE FRR: 100k–1m / 100k–500k | Failure to report vs tipping off — failure to report has the higher upper bound (more egregious systemically) |
| UAE FRR: 5 yrs / 10 yrs / 10 yrs (last update) | AML records / general licensed-body / employee data — different rules for different categories |
| UAE FRR vs UK MLR: 25% / 25% | BO threshold — same across both (FATF anchor) |
| STR vs SAR | UAE = STR (transaction); UK = SAR (activity) |
Drill these in practice questions
icwim.com has 95 calibrated UAE FRR Chapter 5 (AML/CFT) practice questions with detailed explanations that flag each of these trap-pairs explicitly.
Full UAE FRR access £49 — or get the Cat 5 Pack (ICWIM + UAE FRR) for £79.
For UK candidates: where to focus differently
If you're sitting the UK CISI Combating Financial Crime exam (rather than UAE FRR), the emphasis differs:
- POCA 2002 — the Proceeds of Crime Act provisions on principal ML offences (s.327 concealing, s.328 arranging, s.329 acquisition)
- Money Laundering Regulations 2017 (as amended) — the operational rules including CDD, EDD, and record-keeping
- The DAML mechanism — uniquely UK; UAE has no equivalent. The 7-day notice + 31-day moratorium is a frequent exam topic.
- National Risk Assessment — UK Treasury publishes a regular NRA that informs sector-level risk profiles
- OPBAS — the Office for Professional Body AML Supervision, oversighting the accountancy and legal supervisors
The UAE FRR exam, by contrast, leans heavily on specific SCA decisions, dirham thresholds, and integration with the Federal Penal Code.
Related guides
- UAE FRR thresholds cheat sheet — every testable number in the exam
- What is the UAE Securities & Commodities Authority? — broader UAE regulator primer
- The UAE Cat 5 license guide — full licensing track