Briefing · 5 min
The DNFBP playbook: AML you can actually evidence
MAVYN Team · 1 min read · 28 September 2026
Real estate, dealers in precious metals, auditors, lawyers and corporate service providers — what MOEC and the FIU expect, in plain language.
DNFBPs face a unique challenge: they must comply with the same AML/CFT framework as banks, but with a fraction of the resources and often without dedicated compliance staff.
The Ministry of Economy and the FIU have made their expectations clear. Every DNFBP needs a documented risk assessment, written policies and procedures, ongoing monitoring, and evidence of staff training.
The key word is 'evidence'. It's not enough to have a policy document. You need to show it's being followed — transaction records, screening logs, training attendance, and suspicious activity reports where warranted.
Start with the basics: know your customer, understand the source of funds, screen against sanctions lists, and report anything suspicious. Document everything.