For years, most financial institutions focused their compliance energy on screening clients against watchlists and monitoring transactions. But regulators are now shining a brighter light on Designated Non-Financial Businesses and Professions (DNFBPs)—and if your institution works with them, your compliance responsibilities just got heavier.
DNFBPs—such as casinos, real estate developers and brokers, lawyers, and accountants—are considered high-risk sectors when it comes to money laundering and terrorist financing.
Criminal networks often exploit these industries to funnel illicit funds, disguise ownership, or launder proceeds of crime. Because DNFBPs operate outside traditional banking, they can be perceived as “weak links” in the compliance chain—unless regulators keep a close watch.
That’s why the AMLC and BSP require covered persons to verify that DNFBPs are properly registered with the AMLC before doing business with them. A valid Certificate of Registration (COR or PCOR) is non-negotiable.
If your institution deals with DNFBPs, the burden of compliance is on you. Here’s what’s at stake:
Enhanced Due Diligence (EDD): If a DNFBP can’t provide a valid COR/PCOR, you’re obligated to apply EDD—or risk non-compliance yourself.
Sanctions & Penalties: Failing to check DNFBP registration exposes you to administrative sanctions under AMLC’s Rules of Procedure in Administrative Cases (RPAC).
Business Risk: Continuing relationships with unregistered DNFBPs could lead to audit flags, reputational damage, or worse—license suspension.
The AMLC has already issued multiple advisories reminding covered persons to deal only with DNFBPs that are duly registered. This isn’t a new directive—but enforcement is tightening. The regulator has also begun publishing updated lists of registered DNFBPs, making it easier for auditors to catch lapses in your processes.
Talk to our compliance specialist today to walk through how your institution can stay prepared.
The safest move is to integrate DNFBP registration verification into your regular customer due diligence (CDD) process. Instead of treating it as an afterthought, build it into your client onboarding and ongoing monitoring.
Covered institutions that succeed in compliance aren’t the ones reacting to the latest circular—they’re the ones anticipating the next audit question.
DNFBPs matter because regulators see them as vulnerable gateways for illicit activity. If your institution works with them, the responsibility is clear: verify, document, and be audit-ready.
Failing to do so doesn’t just put the DNFBP at risk—it puts you in the crosshairs of AMLC oversight.