CBUAE guidance on AI and ML and AI use cases

Keeping customer due diligence files current is not listed in Annex III, so a back office system that assembles reviews for an analyst to decide is usually minimal risk. The design decides the rest: a conversational agent that asks customers for missing information must tell them they are interacting with an AI system (Article 50(1)); biometric verification that only confirms a person is who they claim to be is excluded from Annex III point 1(a), while remote biometric identification is high risk; and Article 5(1)(d) prohibits assessing the risk that a person will commit a criminal offence based solely on profiling, so behavioural triggers should open a review for a human rather than score the customer. GDPR applies to the collection and retention of KYC data, including Article 22 if an automated refresh leads to a decision with legal or similarly significant effect, such as closing an account.

An AML customer risk rating is not listed in Annex III. Article 5(1)(d) prohibits AI risk assessments that predict whether a natural person will commit or will likely commit a criminal offence based solely on profiling of that person or on assessing their personality traits and characteristics; it exempts only AI that supports the human assessment of a person's involvement in a criminal activity, which is already based on objective and verifiable facts directly linked to a criminal activity. An AML customer risk rating built from due diligence attributes, transaction behaviour and screening results is itself an automated evaluation of a person's situation and behaviour, which is profiling under GDPR Article 4(4), and due diligence facts such as occupation, geography and products are not facts directly linked to a criminal activity, so the rating does not sit squarely inside the exemption. What keeps it a defensible AML due diligence tool rather than an offence prediction is that it does not itself accuse a person of an offence: it sets a level of scrutiny, a human analyst reviews material moves, and regulatory minimum rules sit above the model as hard constraints. A rating driven mainly by nationality or other personal attributes weakens that position further, which is why the proxy discrimination guardrail matters. If the same score is used to evaluate the creditworthiness of natural persons or to establish their credit score, that use falls under Annex III point 5(b) and is high risk, so keep the AML rating and credit decisions separate.

An internal assistant that screens contracts for compliance with Shariah standards is not listed in Annex III: it assesses contracts, structures and securities, not the creditworthiness of natural persons (Annex III point 5(b)). If a customer facing version answers product questions, it must disclose that people are interacting with an AI system under Article 50(1). National Islamic finance regulators set their own Shariah governance expectations.

Adverse media and PEP screening for due diligence is not listed in Annex III. It processes personal data, including data about alleged offences, so GDPR Article 10 and national AML law govern what may be collected and how long it is kept.

Sanctions screening by banks and payment firms is not listed in Annex III: point 5 covers credit scoring and life and health insurance pricing, and point 6 covers AI used by or on behalf of law enforcement authorities. It is not a prohibited practice under Article 5, and as an internal tool it carries no Article 50 transparency duty. It still processes personal data at scale, so GDPR applies, and decisions that block a payment or freeze assets remain human decisions.