UAE Institutional Banking

Correspondent account:
from license to clearing

Route for banks, EMIs, PSPs and other eligible financial institutions: institutional profile, AML control, currencies, SWIFT/RMA and sustainable operating model.

EDDfor cross-border relationships
Norelationship with shell bank
SWIFT / RMAseparate operational audit
Constantlytransaction monitoring

01

The account is designed for a specific payment function

Correspondent institution provides services to respondent institution for payments from its clients or its own settlements. Before selecting a bank, currencies, products, customer segments, geography, settlement, liquidity and expected message flow are determined.

Nostro / vostro
Currency, destination, ownership of funds and reconciliation
Clearing
Domestic, cross-border, card, trade or treasury payments
RMA
The right to exchange SWIFT messages is not the same as the right to conduct any transactions
Nested relationship
Access of respondent clients and other financial institutions is disclosed and controlled
Not correspondent
An ordinary corporate account of a financial company should not hide client funds

02

Who can be respondent

The candidate must be a truly licensed and supervised financial institution with a physical presence and a functioning control system. The license type must allow services that require correspondent access.

Bank
Full or limited license and clear prudential supervision
EMI / PSP
Permitted payment services, safeguarding and availability of correspondent product
Other FI
Function, license and regulatory classification are verified separately
Shell bank
Relationships are prohibited; also checks to see if respondent grants shell bank access

03

Institutional profile

The correspondent bank evaluates the country, regulator, ownership and management, financial stability, products, clients, geography, AML history and the economic necessity of the relationship.

Regulatory

License, supervisory status, inspection history and permitted services.

Governance

Board, senior management, compliance, MLRO and three lines of defense.

Business

Customers, products, countries, channels, turnover and average tickets.

Financials

Capital, liquidity, audit, profitability and ownership funding.

04

Institutional KYC dossier

Corporate
Charter, register, license, group chart, UBO and management
Regulatory
License scope, regulator contacts, prudential returns and recent inspection findings
AML
Enterprise-wide risk assessment, policies, CDD/EDD, sanctions, TM and STR process
Audit
Audited financials, internal audit and independent AML testing
Payments
Currencies, corridors, use cases, volumes, customer types, SWIFT BIC and sample messages
Questionnaires
Wolfsberg CBDDQ or bank form - in full and in accordance with evidence

05

AML/CFT/CPF is the central part of the solution

Cross-border correspondent relationships are considered a higher risk and require an EDD. The analysis covers jurisdictions, sanctions, ownership, customer base, products, nested access and respondent control quality.

CDD / EDD
Identification, beneficiaries, purpose, reputation and regulator quality
Sanctions / TFS
Screening clients and payments, ownership/control and escalation
Transaction monitoring
Scenarios for corridors, types of clients, volumes and behavior
Nested access
Identification and control of downstream institutions and their clients
Governance
Senior management approval, risk appetite and documented solution

06

Payment and technical architecture

Legal approval must coincide with real operational readiness: SWIFT connectivity, ISO 20022 data, sanctions screening, cut-off, reconciliation, liquidity and payment investigation.

Messages
Acceptable MT/MX, RMA scope and mandatory data fields
Settlement
Prefunding, intraday liquidity, fees, cut-off and value dates
Operations
Maker-checker, repair, returns, investigations and exception handling
Controls
Real-time screening, post-event monitoring and case management
Resilience
BCP/DR, cybersecurity, incident notification and vendor controls

07

Correspondence project procedure

  1. 01
    Target model

    Currencies, corridors, products, clients, volumes and clearing needs.

  2. 02
    Gap assessment

    License, AML, governance, audit, SWIFT and operations.

  3. 03
    Bank mapping

    Suitable UAE correspondents and their risk appetite.

  4. 04
    Due diligence

    Questionnaire, evidence, interviews, approvals and remediation.

  5. 05
    Implementation

    Agreements, RMA, testing, limits, funding and controlled go-live.

08

Opening is the beginning, not the end of the test

The Correspondent institution updates the risk assessment and respondent profile, monitors transactions and documents actions. Significant changes in ownership, license, clients, corridors or volumes will be communicated in advance.

Periodic review
Risk-based KYC refresh and relationship re-evaluation
Payments
Deviations from the stated profile, new countries and unusual patterns
Requests
Quick response to RFI with primary documents and customer context
Audit
Independent testing of control and remediation findings
Exit
If the risk is uncontrollable, restrictions, suspension or termination are possible

09

Critical red flags

Formal license

There is no physical presence, staff or effective supervision.

Opaque access

Nested institutions, payable-through use or customer segments are not disclosed.

Weak AML

General policies without risk assessment, systems evidence and independent testing.

Payments don't match

Corridors, volumes and purpose differ from the approved profile.

10

Readiness pack before contacting

  1. 01

    The license and legal opinion cover the proposed services.

  2. 02

    Ownership, governance and physical presence are confirmed.

  3. 03

    AML/CFT/CPF framework works and is independently tested.

  4. 04

    Payment corridors, clients, volumes and nested access are transparent.

  5. 05

    SWIFT, ISO 20022, sanctions, liquidity and operations are ready for testing.

Official basis

CBUAE correspondent guidance

The structure of this section follows the current CBUAE guidelines and international risk-based practice.

01

CBUAE — Correspondent Banking Guidance 2025

Current guidance on risk assessment, EDD, governance, monitoring, sanctions, SWIFT/RMA and recordkeeping.

Open official source
02

CBUAE — AML/CFT Guidelines

Mandatory correspondent due diligence and prohibition of relations with shell banks.

Open official source
03

CBUAE — Register

The official register of banks and other licensed financial institutions in the UAE.

Open official source
04

CBUAE — synopsis of correspondent guidance

Summary of requirements for governance, independent audit, training, recordkeeping and risk controls.

Open official source

Correspondent readiness

We will prepare the bank for institutional due diligence

We will conduct a gap assessment, collect an evidence pack and design a payment architecture.

Discuss the correspondence project
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