Jordan KYC, KYB & AML compliance checklist
A practical, source-linked checklist for implementing KYC, KYB and AML requirements in Jordan.
- Last reviewed
- Last reviewed:
- Version
- Version 1.0
Portable implementation guide
Get the PDF checklist
11 control areas · 37 implementation checks
Last reviewed: 7 October 2026 · Version 1.0
Download the checklistDirect answer
What does the Jordan compliance checklist cover?
The Jordan checklist translates primary KYC, KYB and AML rules into 11 control areas and 37 implementation checks. It identifies the relevant authorities, customer and beneficial-owner controls, reporting duties, recordkeeping expectations and evidence teams should retain.
Key regulatory facts
- Primary AML law
- Law No. 20 of 2021
- FIU
- Anti-Money Laundering and Counter Terrorist Financing Unit
- SAR timing
- Immediately, including attempted activity, regardless of value
- Records
- At least 5 years from the applicable transaction or relationship trigger
- Beneficial ownership
- Apply ownership and ultimate effective-control tests; registry guidance includes 20% criteria
- Cross-border cash declaration
- More than JOD 10,000 or equivalent
- Privacy law
- Personal Data Protection Law No. 24 of 2023, effective 17 March 2024
- FATF public lists
- Not listed at 19 June 2026
Implementation detail
Jordan compliance requirements and actions
Open each control area to review the requirement, recommended implementation action, evidence to retain and the primary-source citation used by the research team.
01Scope, authorities, and licensingClassify the activity, Jordan nexus and supervisor before launch.3 items+
Determine whether the business is a reporting entity.
- Implementation action
- Map each service to financial institutions, real-estate and precious-metals businesses, specified legal and accounting activities, company-service activities and any category added by Cabinet.
- Evidence to retain
- Perimeter memo, service map and authority confirmation.
- Primary citation
- Law 20/2021 article 14
Obtain each activity-specific licence before operating.
- Implementation action
- Classify banking, exchange, money transfer, electronic payment, finance, securities, insurance and digital products under the current sector regime.
- Evidence to retain
- Licence matrix, approvals and conditions.
- Primary citation
- Banking Law; Money Exchange Business Law; CBJ payment instructions
Use current sector rules and controlling Arabic text.
- Implementation action
- Track CBJ, JSC, AMLU and other supervisory instructions, including amendments and Article 44 continuity.
- Evidence to retain
- Source inventory, translations and change log.
- Primary citation
- Law 20/2021 articles 21 and 44
02Governance and risk assessmentControls must be risk-based, documented and effective.3 items+
Assess and monitor ML/TF risks.
- Implementation action
- Cover customers, countries, products, services, delivery channels, transactions and new technologies in a proportionate assessment.
- Evidence to retain
- Methodology, assessment, approvals and updates.
- Primary citation
- Law 20/2021 article 15(a)-(c)
Maintain approved mitigation controls.
- Implementation action
- Document CDD, monitoring, SAR, records, sanctions, training and escalation procedures based on assessed risk.
- Evidence to retain
- Approved framework, procedures and issue register.
- Primary citation
- Law 20/2021 article 15(b), (f)
Appoint responsible compliance personnel and independent assurance.
- Implementation action
- Apply the exact sector instruction on authority, resources, reporting and testing.
- Evidence to retain
- Appointment, board reports, training, audit and remediation.
- Primary citation
- Law 20/2021; applicable supervisory instructions
03Natural-person identificationIdentify customers, beneficial owners and representatives at every applicable trigger.4 items+
Never use anonymous or fictitious accounts.
- Implementation action
- Identify and verify the customer with reliable, independent evidence before activation.
- Evidence to retain
- Identity attributes, document provenance and fraud checks.
- Primary citation
- Law 20/2021 article 15(d)
Apply risk-based CDD and enhanced measures when required.
- Implementation action
- Understand purpose and intended nature, verify relevant persons and apply EDD for higher risk or suspicion.
- Evidence to retain
- Trigger, profile, verification and approval.
- Primary citation
- Law 20/2021 article 15(d)-(e)
Verify representatives and authority.
- Implementation action
- Identify the representative and authenticate the mandate before accepting instructions.
- Evidence to retain
- Representative KYC, authority document and validation.
- Primary citation
- Law 20/2021 article 15; sector CDD instructions
Do not proceed when CDD cannot be completed.
- Implementation action
- Do not open, execute, begin or continue the relevant relationship or transaction; assess an AMLU report without tipping off.
- Evidence to retain
- Failure reason, restriction and SAR assessment.
- Primary citation
- Law 20/2021 article 16
04KYB and beneficial ownershipVerify legal existence, ownership and ultimate effective control.4 items+
Verify the legal person and its authority structure.
- Implementation action
- Obtain current registry, constitutional, director, signatory and business-purpose evidence.
- Evidence to retain
- Certified extract, documents and discrepancy record.
- Primary citation
- Law 20/2021 article 15; sector CDD instructions
Identify natural persons who ultimately own or control.
- Implementation action
- Trace direct, indirect, layered, nominee and other control arrangements; do not stop at a legal-person shareholder.
- Evidence to retain
- Ownership chart, calculations and verified identities.
- Primary citation
- Law 20/2021 article 2; BO Regulation 62/2022
Apply registry criteria without treating a percentage as a safe harbour.
- Implementation action
- Use the current Regulation 62/2022 and CCD guidance, including relevant 20% ownership, voting, profit, appointment or liquidation criteria, while assessing ultimate effective control and fallback persons.
- Evidence to retain
- Criterion-by-criterion analysis and rationale.
- Primary citation
- BO Regulation 62/2022 article 9; CCD BO guidance
Maintain the company BO register and required filings.
- Implementation action
- Record prescribed particulars, reconcile changes and submit declarations through the live CCD procedure within the applicable deadline.
- Evidence to retain
- BO register, forms, receipts and change log.
- Primary citation
- Companies Law; BO Regulation 62/2022
05PEPs, EDD, and remote onboardingApply enhanced measures to PEPs and higher-risk relationships.3 items+
Determine whether the customer or beneficial owner is a PEP.
- Implementation action
- Use risk-management procedures and apply the approval, wealth, funds and monitoring measures required by the applicable sector rule.
- Evidence to retain
- Screening, classification, approval and corroboration.
- Primary citation
- Law 20/2021 article 15(e)
Apply EDD proportionate to higher risk.
- Implementation action
- Obtain additional customer, purpose, ownership, source-of-wealth and source-of-funds information and intensify monitoring.
- Evidence to retain
- Risk trigger, additional CDD and approval.
- Primary citation
- Law 20/2021 article 15(d)
Control non-face-to-face onboarding.
- Implementation action
- For eligible CBJ-regulated services, apply Instructions 7/2021 and any product-specific identity, authentication, fraud and exception controls.
- Evidence to retain
- Method assessment, authentication result and exceptions.
- Primary citation
- CBJ electronic KYC Instructions 7/2021
06Monitoring and suspicious reportingOngoing scrutiny supports immediate reporting to AMLU.4 items+
Monitor and refresh on a risk basis.
- Implementation action
- Compare activity with purpose, expected behaviour, risk and source of funds; update CDD when events or doubts arise.
- Evidence to retain
- Scenarios, alerts, reviews and refresh records.
- Primary citation
- Law 20/2021 articles 15 and 17(b)
Escalate suspicion without waiting for proof.
- Implementation action
- Assess transactions, activities and attempts promptly and document reasonable grounds and formation time.
- Evidence to retain
- Chronology, information and decision.
- Primary citation
- Law 20/2021 article 18
Notify AMLU immediately regardless of value.
- Implementation action
- Submit the prescribed SAR through the current goAML route and retain the acknowledgement.
- Evidence to retain
- Suspicion timestamp, submission and receipt.
- Primary citation
- Law 20/2021 article 18; AMLU FAQ
Prevent tipping off and protect SAR information.
- Implementation action
- Restrict access and customer communications and follow lawful information-sharing rules.
- Evidence to retain
- Access logs, scripts, training and incidents.
- Primary citation
- Law 20/2021 articles 19 and 20
07Payments, wires, thresholds, and digital assetsSeparate CDD triggers, declarations and activity-specific licensing.4 items+
Carry required originator and beneficiary information.
- Implementation action
- Apply the current sector wire-transfer fields, screening and missing-data procedures.
- Evidence to retain
- Field matrix, payment samples and repair queue.
- Primary citation
- Applicable CBJ AML/CFT and payment instructions
Do not misstate the JOD 10,000 border declaration as a customer threshold.
- Implementation action
- For physical cross-border cash or bearer negotiable instruments over JOD 10,000 or equivalent, support the Customs declaration obligation; keep product CDD thresholds separate.
- Evidence to retain
- Travel/courier controls, declaration and escalation.
- Primary citation
- Law 20/2021 article 23; Jordan Customs guidance
Obtain payment, transfer or exchange approval.
- Implementation action
- Map wallets, acquiring, remittance, exchange and ancillary features to live CBJ licensing and safeguarding requirements.
- Evidence to retain
- Product memo, licence and compliance tests.
- Primary citation
- Banking Law; Money Exchange Business Law; CBJ instructions
Treat virtual-asset activity as a launch-date perimeter issue.
- Implementation action
- Do not rely on the September 2026 draft amendment; obtain written confirmation of the operative licensing and AML treatment before offering a service.
- Evidence to retain
- Current-law memo, authority confirmation and approval.
- Primary citation
- Law 20/2021; draft 2026 amendment (non-operative)
08Targeted financial sanctionsUse current UN and Jordan designation procedures.3 items+
Screen designations and ownership or control.
- Implementation action
- Screen relevant parties at onboarding, transactions and list updates, using current UN and Jordan lists.
- Evidence to retain
- List versions, tests and decisions.
- Primary citation
- Law 20/2021 article 40; Instructions 1/2021
Freeze without delay and notify through the live route.
- Implementation action
- Prevent dealing or asset availability on a confirmed match and make required notifications without prior notice.
- Evidence to retain
- Match analysis, restriction time and notification.
- Primary citation
- Law 20/2021 article 40; Instructions 1/2021
Use exemptions, delisting or release only under written authority.
- Implementation action
- Apply the designation-specific procedure and preserve all conditions and approvals.
- Evidence to retain
- Legal analysis, permission and release record.
- Primary citation
- Law 20/2021 article 40(f); Instructions 1/2021
09Records and regulator accessRetention triggers differ for transactions and relationships.3 items+
Retain transaction records for at least five years.
- Implementation action
- Run the period from completion and preserve enough data to reconstruct individual transactions.
- Evidence to retain
- Schedule, trigger, samples and retrieval test.
- Primary citation
- Law 20/2021 article 17(a)
Retain CDD, account, correspondence and analysis records for at least five years.
- Implementation action
- Run the period from relationship termination or transaction date, whichever is longer, subject to lawful holds.
- Evidence to retain
- Schedule, trigger and deletion approval.
- Primary citation
- Law 20/2021 article 17(a)
Keep records current and available to competent authorities.
- Implementation action
- Maintain controlled access, legal holds and a complete production audit trail.
- Evidence to retain
- Update history, access matrix and production log.
- Primary citation
- Law 20/2021 article 17(b)
10Privacy, biometrics, breaches, and transfersApply Law 24/2023 and current implementing instruments.3 items+
Map processing conditions, notices and rights.
- Implementation action
- Inventory personal and sensitive data, establish a lawful basis or valid consent, provide required information and support data-subject rights.
- Evidence to retain
- Data map, notices, consent and rights log.
- Primary citation
- Personal Data Protection Law 24/2023 articles 4-7
Apply enhanced governance to sensitive and high-risk processing.
- Implementation action
- Assess biometric and financial-data processing, conduct a DPIA where required and appoint an accredited DPO when statutory criteria apply.
- Evidence to retain
- Classification, DPIA, DPO analysis and appointment.
- Primary citation
- Law 24/2023; PDPD DPIA and DPO guidance
Control processors, security incidents and transfers.
- Implementation action
- Contract processors, implement safeguards, assess transfer conditions and make notifications through the current statutory route.
- Evidence to retain
- Contracts, security controls, transfer assessment and incident record.
- Primary citation
- Law 24/2023 articles 20-23; current regulations
11Practical evidence packsEvidence must reconstruct decisions end to end.3 items+
Maintain an onboarding pack.
- Implementation action
- Bundle identity, authority, KYB, BO, PEP, sanctions, purpose, risk, privacy and approvals.
- Evidence to retain
- Complete sample and retrieval result.
- Primary citation
- Operational control supporting Law 20/2021
Maintain SAR and sanctions case packs.
- Implementation action
- Link activity, suspicion time, report, receipt, confidentiality, restrictions and communications.
- Evidence to retain
- Case pack, timeline and access record.
- Primary citation
- Law 20/2021 articles 18-20 and 40
Maintain a launch and legal-change pack.
- Implementation action
- Record perimeter, licences, reporting, sanctions, privacy, vendors, tests and the status of the 2026 draft AML amendment.
- Evidence to retain
- Signed pack, source register and approvals.
- Primary citation
- Official sources listed below
Primary-source register
17 sources used for this checklist
Use these links to verify the underlying legislation, regulator guidance, reporting procedures and international status statements.
- Anti Money Laundering and Counter Terrorist Financing Law No. 20 of 2021AMLU · Primary legislation - official English translation
- Official Gazette issue 5743Prime Ministry of Jordan · Official gazette
- Reporting-entity obligationsAMLU · Official guidance
- AMLU instructions registerAMLU · Official instructions register
- Suspicious activity reporting FAQ and goAML routeAMLU · Official filing guidance
- High-risk countries and National Committee Decision 2/2026AMLU · Official current guidance
- CBJ AML/CFT instructions registerCentral Bank of Jordan · Official supervisory register
- Electronic KYC Instructions No. 7/2021Central Bank of Jordan · Official supervisory instructions
- Beneficial ownership register guidanceCompanies Control Department · Official registry guidance
- Beneficial ownership official register pageCompanies Control Department · Official registry portal
- Cross-border cash declaration under Law 20/2021Jordan Customs · Official guidance
- Personal Data Protection Law No. 24 of 2023Ministry of Digital Economy and Entrepreneurship · Primary legislation - official translation
- Personal Data Protection Directorate and implementation guidanceMinistry of Digital Economy and Entrepreneurship · Official regulator guidance
- Jordan Follow-Up Report 2025FATF / MENAFATF · Authoritative assessment
- FATF increased monitoring - 19 June 2026FATF · Authoritative current status
- FATF call for action - 19 June 2026FATF · Authoritative current status
- September 2026 draft AML amendment statusJordan News Agency (Petra) · Official news - draft only
Direct answers
Jordan KYC, KYB and AML questions
Who receives suspicious activity reports?+
The Anti-Money Laundering and Counter Terrorist Financing Unit receives reports through the prescribed goAML route.
When must a SAR be filed?+
Immediately when suspicion or reasonable grounds arise, including attempted activity and regardless of value.
How long are AML records retained?+
At least five years, with the trigger depending on transaction completion or relationship termination; apply the longer relevant period.
What is Jordan's beneficial-owner threshold?+
Apply Regulation 62/2022 and current CCD guidance, including relevant 20% criteria, but also identify ultimate effective control; a percentage is not a safe harbour.
What is the JOD 10,000 rule?+
It is a declaration rule for physical cross-border cash or bearer negotiable instruments above JOD 10,000 or equivalent, not a universal customer-reporting threshold.
Can onboarding be electronic?+
Yes where the regulated activity and product meet CBJ Instructions 7/2021 and all applicable identity, authentication and risk controls.
Are biometrics sensitive data?+
Yes. Apply Law 24/2023, current implementing instruments, DPIA guidance and any DPO requirements.
Is the September 2026 AML amendment operative?+
No evidence of enactment was found as at 7 October 2026; treat it as a draft and monitor the Official Gazette.
Is Jordan on a FATF public list?+
No at 19 June 2026, but absence is not a low-risk conclusion.
Research and review method
VOVE ID Compliance Research maps the regulatory perimeter, translates obligations into operational controls, links each material claim to a source and records the date and version of every review.
General information, not legal advice. Reviewed 7 October 2026. Confirm controlling Arabic text, later Gazette enactments, current sector instructions, AMLU filing specifications, beneficial-owner procedures, sanctions directions, privacy regulations and licensing with the competent authority and qualified Jordan counsel.