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AML/CTF compliance in Qatar

WHAT ARE THE

Money laundering and terrorism financing laws in Qatar?

In Qatar, money laundering and terrorism financing are regulated by the following laws:

  • Law No. (20) of 2019 on Combating Money Laundering and Terrorism Financing: This is the main law that establishes the legal framework for combating money laundering and terrorism financing in Qatar. It provides for the establishment of a national committee to oversee these efforts and details the obligations of financial institutions and other entities.
  • Law No. (4) of 2010 on Combating Terrorism: This law provides the definition of terrorist acts and establishes penalties for engaging in such acts. It also sets out measures for combating the financing of terrorism.
  • Law No. (3) of 2004 on Combating Terrorism: This law was the first comprehensive legal measure against terrorism in Qatar. It has been superseded by Law No. (4) of 2010 but is still relevant as it established the initial legal framework for anti-terrorism efforts.

WHAT ARE THE

Key obligations reporting entities have under Qataris laws?

In Qatar, reporting entities have several key obligations under anti-money laundering and counter-terrorism financing laws. These obligations are designed to prevent these entities from being used for money laundering or the financing of terrorism. They include:

  • Customer Due Diligence (CDD): Reporting entities are required to establish and verify the identity of their customers and to understand the nature of their business. Enhanced due diligence is required for higher-risk customers.

  • Record Keeping: Entities are required to maintain all necessary records on transactions for at least five years. The purpose of this requirement is to provide a trail that can be used in any subsequent investigation by competent authorities.

  • Reporting Suspicious Transactions: If a reporting entity suspects or has reasonable grounds to suspect that funds are the proceeds of a criminal activity, or are related to terrorist financing, it is required to report promptly its suspicions to the Financial Information Unit (FIU).

  • Internal Controls and Procedures: Reporting entities are required to establish internal policies, procedures, and controls to prevent money laundering and terrorist financing, and to communicate these to their employees.

  • Training: Entities must provide their employees with training on AML and CTF laws and procedures.

  • Compliance Officer: Entities are required to appoint a compliance officer at the management level to be responsible for the implementation of the AML/CTF framework.

These obligations are detailed in the Law No. (20) of 2019 on Combating Money Laundering and Terrorism Financing and the related regulations and instructions issued by the Qatar Central Bank and other competent authorities.

WHO ARE THE

ML/TF regulators in Qatar and what functions do they perform?

In Qatar, regulation of money laundering and terrorism financing is primarily the responsibility of the following authorities:

WHAT ARE THE

Industry sectors subject to ML/TF regulations?

In Qatar, the industry sectors regulated under anti-money laundering (AML) and counter-terrorism financing (CTF) laws include:

Banking and Finance

This covers commercial banks, investment banks, finance companies, exchange houses, and money transfer businesses.

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Insurance Companies

Both insurance and reinsurance companies are subject to AML and CTF regulations.

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Securities Dealers

Entities involved in buying, selling, and trading securities are included in the regulated sectors.

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Real Estate

Real estate brokers, agents, and developers must comply with AML/CTF rules.

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Dealers in precious metals and stones

Businesses dealing with transactions in precious metals and stones are regulated.

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Legal professions

This includes lawyers and notaries, particularly when they are involved in financial or real estate transactions.

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Accountants

Accounting professionals, whether independent or part of a firm, are subject to these regulations.

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Trust and Company Service Providers

Entities providing services like company formation, acting as a trustee or nominee shareholder, or providing business addresses for companies, are also regulated.

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WHAT ARE THE

Penalties for non-compliance with AML/CTF laws?

In Qatar, penalties for non-compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) laws are severe, as outlined in Law No. (20) of 2019 on Combating Money Laundering and Terrorism Financing. They include:

  • Fines: Financial penalties can range significantly, with the maximum fine reaching up to QAR 100 million. 
  • Imprisonment: For serious violations, individuals can face prison sentences. The term of imprisonment depends on the severity of the breach, with maximum sentences reaching up to 15 years. 
  • Asset Forfeiture: In cases involving money laundering or terrorist financing, the court may order the confiscation of funds, property, or any other assets associated with the crime. 
  • Business Suspension or Closure: Depending on the severity of the breach, businesses can face temporary suspension or permanent closure. 
  • Reputational Damage: In addition to legal penalties, non-compliance can result in significant damage to an entity's reputation, which can impact business operations.

The penalties are intended to serve as a deterrent and to underscore the seriousness with which Qatar views money laundering and terrorist financing activities.

WHAT ARE THE

Largest fines for non-compliance with AML/CTF laws?

Here are some of the largest fines for non-compliance with AML/CTF laws in Qatar:

Qatar Financial Centre Regulatory Authority (QFCRA)

  • The QFCRA imposed their first significant fine against a business (Guardian Wealth Management Qatar LLC) in April 2018, which resulted in penalties of QAR 3,592,000 for violations of Anti-Money Laundering and Combating Terrorist Financing Rules 2010, coupled with breaches of general regulatory provisions.
  • In 2019, two individuals (Individual 1, Individual 2) at the firm were each subjected to a USD 200,000 fine and a 36-month probation period by the QFCRA. The penalties were due to their failure to adequately oversee the firm's compliance with the Anti-Money Laundering and Combating Terrorist Financing Rules 2010.

  • In 2020, the QFCRA imposed a fine of USD 50,000 on a former CEO at Guardian Wealth Management Qatar LLC for failure to comply with regulatory authority requirements. This enforcement action emphasizes the importance of compliance within the financial sector.

Horizon Crescent Wealth LLC Case (Qatar)

  • In 2022, the Qatar Financial Centre Regulatory Authority (QFCRA) imposed a fine of QAR 548,121 on a former Director at Horizon Crescent Wealth LLC for violations of the Anti-Money Laundering and Combating Terrorist Financing Rules 2010.

  • In 2023, the QFCRA further imposed fines on three individuals associated with Horizon Crescent Wealth LLC for similar violations. The fines amounted to QAR 728,000, QAR 1,092,606, and QAR 546,182. Additionally, two of the individuals were indefinitely prohibited from carrying out any functions for firms in the Qatar Financial Centre.