AIFC Regulatory Compliance

AML/CTF Framework Development

All AFSA-licensed firms must have AML/CTF policies and procedures that comply with the AIFC AML, CTF and Sanctions Rules. Bond Stone prepares or reviews AML/CTF policy frameworks, customer due diligence (CDD/EDD) procedures, suspicious activity reporting protocols, and MLRO appointment documentation. These are required for every AFSA licence application and must be kept up to date.

AFSA Supervisory Engagement

Responding to AFSA information requests, preparing responses to AFSA supervisory reviews, representing clients in AFSA meetings, managing annual return filings, and handling AFSA enforcement correspondence. Bond Stone acts as the primary AFSA liaison for several licensed firms — including management of the AFSA check-in protocol and ongoing communication with AFSA case officers.

AFSA Discontinuance Management

Voluntary surrender of an AFSA licence — wind-down plan preparation, client notification obligations, AFSA application submission, regulatory exit documentation, and post-discontinuance confirmation. Bond Stone has managed AFSA discontinuance mandates for international digital asset exchanges.

AFSA Approved Individual Registration

Applications for registration of key personnel as AFSA Approved Individuals — CEO, MLRO, Compliance Officer, Finance Officer. Fit-and-proper assessment documentation, reference checks, and AFSA submission. Under the Fees Rules, USD 500 is payable for each Approved Individual application, and an Ancillary Service Provider pays USD 500 to change its MLRO or Audit Principal.

FinTech Lab Migration to Full Regime

A FinTech Lab Licence has effect for 2 years and may be extended. A participant that wishes to operate on a broader scale migrates to full authorisation and pays migration fees (FEES 8.1.3). Bond Stone advises on timing, the full licence application and engagement with AFSA during the transition.

First supervision fee payable to AFSA, pro-rated by whole months to the year end (FEES 3.1.2, 3.1.4)

Supervision fee to AFSA by 1 January (FEES 3.1.3). AML Return to AFSA within two months after year end (AML 13.7). Audited financial statements to AFSA within four months of year end (GEN 6.3). Annual return or confirmation statement and accounts to the Registrar of Companies. Review of AML/CTF policies.

Notify AFSA of material changes to the business model, key personnel, ownership or activities. Apply for approval of a change of control where required, and for Approved Individual status for replacement key personnel.

An unpaid annual or supplementary fee increases by 1% for each month or part of a month. A notification, report or return to AFSA more than 3 business days late attracts a late fee of USD 500 (USD 300 for FinTech Lab Participants). An annual return, confirmation statement or accounts more than 5 business days late attracts USD 100 payable to the Registrar. A late fee unpaid after 30 calendar days grows by 10% of the late fee for each calendar day (5% for the Registrar) (FEES Schedules 10, 11).