Designated Non-Financial Businesses and Professions

Designated Non-Financial Businesses and Professions (DNFBPs) are non-financial sectors and professional gatekeepers that are legally subject to Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Anti-Proliferation Financing (APF) regulatory obligations under the standards established by the Financial Action Task Force (FATF).

1. Why DNFBPs Are Regulated

While banks and investment institutions are traditionally the primary focus of financial crime regulation, bad actors often exploit non-bank channels and specialized professionals to launder illicit proceeds, integrate illegal funds into the legitimate economy, or mask beneficial ownership.

Classifying these sectors as DNFBPs ensures they apply the same preventive controls, customer scrutiny, and reporting standards as traditional financial institutions.

2. Sectors and Professions Included as DNFBPs

Under FATF Recommendation 22 and national frameworks, the designated categories typically include:

1. Real Estate Brokers and Agents: When involved in transactions for clients concerning the buying and selling of real estate.
2. Dealers in Precious Metals and Stones (DPMS) & Dealers in High-Value Goods (DiHVG): Businesses dealing in luxury goods, jewelry, precious metals, art, yachts, or high-value motor vehicles—particularly when engaging in cash or high-value transactions above prescribed statutory thresholds.
3. Lawyers, Notaries, and Other Independent Legal Professionals: When preparing or executing transactions for clients involving:
4. Buying and selling real estate.
5. Managing client money, securities, or other assets.
6. Managing bank, savings, or securities accounts.
7. Organizing contributions for the creation, operation, or management of companies.
8. Creating, operating, or managing legal entities or arrangements (e.g., trusts, partnerships).
9. Accountants and Auditors: When providing financial advisory, tax structuring, or transactional support similar to legal professionals.
10. Trust and Company Service Providers (TCSPs / CSPs): Entities (where not otherwise regulated as financial institutions) that provide formation services, registered office addresses, nominee shareholding, or act as directors/trustees.
11. Casinos and Gaming Operators: Including online and land-based casinos when patrons engage in financial transactions above specified monetary thresholds.

3. Core Regulatory Obligations for DNFBPs

Entities operating within DNFBP sectors are required to implement robust risk-based compliance programs, including:

1. Customer Due Diligence (CDD) & KYC: Verifying the identity of clients and identifying the natural persons who are ultimate beneficial owners (UBOs).
2. Risk Assessment & Internal Controls: Conducting institutional risk assessments and maintaining written policies, procedures, and staff training programs.
3. Suspicious Activity Reporting (SAR / STR): Promptly reporting suspicious transactions or red flags to the competent Financial Intelligence Unit (FIU).
4. Record-Keeping: Retaining customer identification, transactional records, and CDD files for the statutory minimum period (typically 5+ years).
5. Sanctions Screening & Ongoing Monitoring: Screening customers against national and international targeted financial sanctions lists (e.g., UN, OFSI, OFAC).

4. Supervision and Oversight

DNFBPs are overseen by designated statutory supervisory authorities or self-regulatory bodies (SRBs) to ensure compliance. Supervisors conduct offsite monitoring, risk evaluations, and onsite compliance inspections.