Navigating ADGM's LPA Risk Report: AML/CFT Compliance for UAE Businesses

Introduction

The global fight against Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) is a dynamic and relentless endeavor, demanding continuous vigilance from jurisdictions and businesses worldwide. The United Arab Emirates (UAE) stands at the forefront of this commitment, consistently enhancing its regulatory framework to safeguard its financial ecosystem. Within this robust environment, the Abu Dhabi Global Market (ADGM), as a leading international financial free zone, plays a pivotal role in maintaining financial integrity and transparency. ADGM's proactive approach to identifying and mitigating financial crime risks is exemplified by its publication of the Legal Professional Activities (LPA) Risk Report.

This comprehensive report offers critical insights into the specific money laundering and terrorist financing vulnerabilities inherent in legal professional activities conducted within ADGM. For every UAE business, whether established within the free zone or engaging with ADGM-based legal service providers, understanding the nuances of this report is not merely a matter of compliance. It profoundly impacts operational risks, shapes due diligence obligations, and underpins the long-term viability and security of investments and partnerships across the Emirates. This article dissects the ADGM LPA Risk Report, outlines its implications for UAE businesses, and provides a strategic roadmap for bolstering compliance defenses against financial crime.

The Evolving AML/CFT Landscape in the UAE

The UAE has significantly strengthened its AML/CFT framework in recent years, aligning with international standards set by the Financial Action Task Force (FATF). This commitment is reflected in a series of legislative and regulatory enhancements, including Federal Decree Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, and its Executive Regulations. These measures aim to foster a secure and transparent financial environment, preventing the misuse of the UAE's financial system for illicit purposes.

Various regulatory bodies across the UAE contribute to this national strategy. The Central Bank of the UAE (CBUAE) oversees financial institutions, the Ministry of Economy (MoEc) regulates Designated Non-Financial Businesses and Professions (DNFBPs), and financial free zones such as ADGM and the Dubai International Financial Centre (DIFC) implement their own robust regulatory regimes. These free zones, with their distinct legal and regulatory frameworks, are crucial in identifying sector-specific risks and issuing targeted guidance, ensuring a comprehensive approach to combating financial crime.

Deep Dive into the ADGM LPA Risk Report

ADGM's LPA Risk Report represents a critical component of its strategy to uphold a secure and transparent financial market. The report's primary purpose is to assess and articulate the specific money laundering and terrorist financing risks associated with legal professional activities conducted within the free zone. By doing so, ADGM aims to enhance awareness, guide risk mitigation efforts for legal professionals, and inform clients about their due diligence responsibilities when engaging legal services.

Purpose and Scope of the Report

The report is an outcome of ADGM's commitment to implementing a risk-based approach to AML/CFT supervision. It provides a detailed analysis of the inherent vulnerabilities within the legal sector, identifies common threats, and highlights potential financial crime typologies. This proactive publication serves multiple strategic objectives:

Enhancing Sectoral Awareness: Educating legal professionals and their clients about the specific AML/CFT risks pertinent to their activities.
Guiding Risk Mitigation: Providing a framework for legal firms to develop and implement robust internal controls and compliance measures.
Informing Regulatory Supervision: Directing ADGM's supervisory activities towards areas of higher risk within the legal sector.
Promoting Transparency: Fostering a culture of compliance and accountability across the ADGM ecosystem.

The report typically draws on national risk assessments, international best practices, and ADGM's own supervisory experiences to provide a tailored evaluation of risk factors.

Defining Legal Professional Activities (LPAs) and Their Inherent Risks

The ADGM LPA Risk Report identifies specific categories of legal professional activities that are particularly susceptible to exploitation for money laundering and terrorist financing. These activities, by their very nature, can provide avenues for illicit funds to enter the legitimate financial system, obscure beneficial ownership, or facilitate the movement of illicit assets.

1. Conveyancing and Real Estate Transactions

Real estate transactions often involve substantial sums, making them attractive for money laundering. Legal professionals involved in conveyancing, property transfers, and escrow services can unwittingly become facilitators. The risks include:

Over/under-valuation: Manipulating property prices to move illicit funds.
Complex ownership structures: Using shell companies or trusts to obscure the true owner of the property.
Third-party payments: Funds flowing from unrelated or high-risk sources.
Rapid turnover of property: Buying and selling properties quickly without clear commercial justification.

2. Managing Client Accounts and Trust Funds

The management of client accounts and trust funds places legal professionals in a position of direct control over financial assets. This proximity to funds presents significant layering opportunities for criminals. Risks include:

Commingling of funds: Mixing legitimate client funds with illicit money.
Rapid movement of funds: Frequent transfers to various accounts without clear purpose.
Use of nominees: Operating accounts on behalf of undisclosed beneficial owners.
Disguising source of funds: Using the trust or client account to make funds appear legitimate.

3. Forming and Managing Legal Persons and Arrangements

Legal professionals frequently assist clients in establishing and managing various legal entities such as companies, trusts, foundations, and partnerships. These structures, while legitimate, can be misused to create complex and opaque ownership layers, hindering law enforcement efforts to identify ultimate beneficial owners (UBOs). Risks involve:

Creation of shell companies: Entities with no apparent business activity, primarily used for financial transactions.
Nominee directors/shareholders: Using individuals to mask the true controllers of an entity.
Complex, multi-jurisdictional structures: Intricate arrangements designed to deliberately obscure ownership and control.
Lack of transparency in UBO information: Inadequate collection or verification of UBO details.

4. Creating and Managing Bank Accounts and Investment Portfolios

When legal professionals directly create or manage bank accounts and investment portfolios on behalf of clients, they are handling financial assets that can be directly implicated in money laundering schemes. This includes managing portfolios, facilitating investment in various assets, and executing financial transactions. The key risks are:

Investment in illicit assets: Using laundered funds to acquire legitimate investments.
Rapid asset conversion: Converting assets quickly to obscure their origin.
Facilitating illicit transfers: Directing funds to high-risk individuals or entities.
Lack of scrutiny on incoming funds: Insufficient due diligence on the source of funds flowing into managed accounts.

5. Other Relevant LPAs

While the core activities listed above are primary concerns, other LPAs can also present risks. These might include:

Litigation funding: Opaque funding sources for legal disputes.
Debt recovery: Facilitating the collection of illicit debts.
Immigration by Investment schemes: Where legal professionals assist in programs that grant residency or citizenship in exchange for investment, which can be vulnerable to illicit fund flows if due diligence is lax.

Regulatory Expectation

ADGM mandates that legal professionals and their clients maintain a keen awareness of these inherent risks. Compliance is not merely about ticking boxes, but about genuinely understanding the vulnerabilities and implementing proportionate mitigation strategies to prevent the financial system from being exploited.

Key Vulnerabilities Identified by ADGM

Beyond specific activities, the ADGM LPA Risk Report often highlights broader vulnerabilities within the legal sector that can be exploited by criminals. These include:

Client confidentiality privilege: While essential, it can sometimes be misused as a shield to obstruct legitimate inquiries into suspicious activities, necessitating clear guidelines on when this privilege must yield to AML/CFT obligations.
Complexity of legal structures: The legitimate complexity of legal arrangements (trusts, foundations, multi-jurisdictional companies) can be intentionally leveraged by criminals to create layers of obfuscation, making it challenging to trace beneficial ownership and the origin of funds.
Lack of specialized AML/CFT expertise: Legal professionals, especially those in smaller practices or niche areas, might lack sufficient training or resources to identify sophisticated financial crime typologies.
Reliance on client declarations: Over-reliance on client-provided information without independent verification can leave firms exposed to false or misleading data.
Pressure from clients: Legal professionals may face pressure from clients to expedite transactions or bypass rigorous due diligence, particularly in high-value or time-sensitive matters.

Emerging Threats and Typologies

The financial crime landscape is constantly evolving, with criminals adapting their methods to exploit new technologies and regulatory gaps. The ADGM LPA Risk Report typically considers:

Use of Virtual Assets (VAs): The increasing use of cryptocurrencies and other virtual assets can introduce new challenges for tracing funds, especially when converted to fiat currency through legal channels.
Trade-Based Money Laundering (TBML): The manipulation of trade transactions through over- or under-invoicing, phantom shipments, or multiple invoicing can involve legal facilitation in contract drafting or dispute resolution.
Sanctions Evasion: Legal professionals might be unwittingly or knowingly involved in creating structures that allow sanctioned entities or individuals to bypass restrictions, a high-risk area for financial centers.
Financing of Proliferation: While less common, the legal sector can be exploited to fund activities related to weapons of mass destruction, often through complex financial arrangements and shell companies.

Strategic Implications for UAE Businesses

The ADGM LPA Risk Report extends its relevance far beyond the legal sector itself. Any UAE business that operates within ADGM, engages ADGM-based legal service providers, or indeed any legal professional, must critically assess the implications of this report for their own operations and compliance frameworks.

Strengthening Your Due Diligence Framework

The report underscores the necessity for UAE businesses to implement robust and ongoing due diligence processes when engaging legal service providers. This means moving beyond basic checks to a more comprehensive and risk-based approach.

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

When selecting legal counsel, businesses should apply CDD principles to the legal firm itself and, where applicable, understand the firm's CDD procedures for their ultimate clients. For engagements involving higher risks—such as complex M&A, international property transactions, or wealth management structures—Enhanced Due Diligence (EDD) is imperative. This includes:

Assessing the legal firm's AML/CFT framework: Inquiring about their internal policies, training programs, and their approach to risk assessment.
Verifying regulatory standing: Confirming the firm's licensing and good standing with ADGM or other relevant authorities.
Understanding beneficial ownership of the legal firm: Identifying the ultimate owners and controllers of the legal practice, particularly if it's a new or unknown entity.

Source of Funds/Wealth Verification

Businesses must be diligent in understanding the source of funds or wealth involved in transactions facilitated by legal professionals, especially if these funds are being routed through client accounts. This requires a clear understanding of the original source of the assets, not just the last intermediary.

Ultimate Beneficial Ownership (UBO) Transparency

The report reinforces the national push for UBO transparency. Businesses must ensure that legal professionals they engage are equally committed to identifying and verifying the UBO of any entities or arrangements they are forming or managing. This is critical for mitigating the risk of shell companies or opaque structures being used for illicit purposes.

Mitigating Reputational, Legal, and Financial Risks

Association with a legal professional or firm that is unknowingly or knowingly complicit in money laundering or terrorist financing activities can trigger a cascade of severe consequences for any UAE business.

Legal Penalties and Regulatory Fines

Non-compliance with AML/CFT regulations can result in substantial financial penalties for businesses and individuals, ranging into millions of Dirhams. Beyond fines, regulatory bodies can impose sanctions, restrict operations, or even revoke licenses. Individuals involved may face imprisonment. The UAE's commitment to combating financial crime means that enforcement is rigorous and penalties are significant.

Damage to Corporate Image and Investor Confidence

Reputational damage is often the most enduring consequence. Being linked to financial crime, even indirectly, can erode public trust, harm brand value, and deter investors. In a competitive global market, a strong reputation for integrity is a vital asset, and its loss can be catastrophic.

Operational Disruptions and De-risking

Investigations into AML/CFT breaches can lead to significant operational disruptions, diverting resources, halting transactions, and freezing assets. Furthermore, financial institutions often engage in "de-risking" strategies, terminating relationships with clients perceived to carry higher AML/CFT risks, which can severely impact a business's ability to operate.

Broader Business Relationships

Partners, suppliers, and international counterparts will scrutinize a business's AML/CFT compliance. A poor record or perceived laxity can lead to the termination of crucial business relationships, hindering growth and market access.

Chain of Liability

Businesses must recognize that liability for financial crime can extend beyond direct involvement. Failing to conduct adequate due diligence on third-party legal providers can expose a business to accusations of complicity or negligence, triggering legal and reputational repercussions.

Aligning Internal AML/CFT Policies with Regulatory Expectations

The ADGM LPA Risk Report provides valuable intelligence that businesses should integrate into their internal AML/CFT policies and procedures. This ensures a comprehensive, consistent, and effective compliance strategy that aligns with a key UAE financial regulator's specific concerns.

Risk-Based Approach

Businesses should update their internal risk assessments to specifically account for the vulnerabilities and threats identified in the LPA Risk Report, particularly when engaging legal service providers. This allows for a proportionate application of controls, focusing resources on areas of highest risk.

Internal Controls and Record-Keeping

Review and enhance internal controls related to third-party engagements, particularly for legal services. This includes clear policies for vendor selection, contract management, and ongoing monitoring. Meticulous record-keeping of all due diligence performed, communications, and transaction details is essential for demonstrating compliance during audits or investigations.

Reporting Suspicious Transactions (STRs/SARs)

Even if a business is not a DNFBP or financial institution, it has a moral and often legal obligation to report suspicious activities. Awareness of the red flags outlined in the LPA Risk Report can help staff identify potentially illicit transactions facilitated by legal services, enabling timely reporting to the UAE's Financial Intelligence Unit (FIU) through the goAML system.

Governance and Oversight Responsibilities

Senior management and boards must ensure that adequate resources are allocated to AML/CFT compliance. This includes establishing clear lines of responsibility, fostering a culture of compliance, and regularly reviewing the effectiveness of the AML/CFT framework in light of evolving regulatory guidance and risk assessments.

Critical Risk Indicators for Legal Engagements

While the ADGM LPA Risk Report provides specific insights, certain overarching risk indicators are universally applicable and should trigger enhanced scrutiny when engaging legal professionals. UAE businesses must integrate these into their risk assessment frameworks.

Geographical Risk

Transactions or client relationships involving individuals or entities from jurisdictions identified as high-risk by international bodies like FATF, or those subject to sanctions, warrant immediate and heightened scrutiny.

FATF Grey/Black Lists: Engagements linked to countries on the FATF's high-risk or monitored lists should be treated with extreme caution.
Sanctioned Jurisdictions: Any nexus to countries or entities under international sanctions (e.g., UN, OFAC) is a major red flag, potentially leading to severe penalties.
Jurisdictions with lax AML/CFT regimes: Transactions involving jurisdictions known for weak regulatory oversight can be used to obscure illicit funds.

Client Risk

Understanding the client is paramount. Complexity, opacity, or unusual profiles should raise flags.

Complex Ownership Structures: Clients with multi-layered, opaque corporate structures, especially those spanning several jurisdictions, might be designed to conceal UBO.
Politically Exposed Persons (PEPs): Engaging clients who are PEPs, their family members, or close associates, requires EDD due to the inherent risk of corruption or illicit enrichment.
Unexplained Wealth or Source of Funds: When the volume or nature of a client's funds or wealth appears inconsistent with their declared business activities or background.
Reluctance to Provide Information: Any resistance to providing standard due diligence documentation, UBO information, or explanations for transactions.

Service Risk

Certain legal services inherently carry higher AML/CFT risks due to their nature.

High-Value Transactions: Engaging legal professionals for significant financial transactions without clear commercial rationale.
Opaque Legal Structures: Requesting the formation of trusts, foundations, or companies with complex nominee arrangements that appear to serve no legitimate purpose beyond secrecy.
Unusual Payment Methods: Insisting on cash payments for large sums, payments from third parties, or use of virtual assets without proper justification and verification.
Rapid Transactions: Transactions that are rushed through without sufficient time for proper due diligence or appear to accelerate without a clear business need.

Technology and Innovation Risk

The rapid advancement of technology, while offering efficiency, also introduces new vulnerabilities.

Digital Identity Verification: Reliance on digital identity solutions without robust verification processes can be exploited.
Virtual Assets: The use of virtual assets in transactions can present challenges for tracing and transparency if not managed with specialist expertise.
FinTech Platforms: Engagement with innovative financial technology platforms that may lack established AML/CFT controls.

Behavioral Red Flags

Subtle behavioral cues from clients or intermediaries can often indicate underlying risks.

Unusual Urgency: Clients pushing for transactions to be completed with extreme urgency, bypassing standard procedures.
Secretive Behavior: Unwillingness to disclose the true nature of a transaction or the identity of parties involved.
Circuitous Instructions: Receiving instructions from multiple, unrelated third parties or through unusual channels.
Inconsistent Information: Discrepancies between information provided and publicly available data or other sources.

Actionable Roadmap for Enhanced Compliance

To proactively address the insights provided by ADGM's LPA Risk Report and fortify their AML/CFT defenses, UAE businesses should implement a structured and comprehensive action plan.

1. Conduct a Comprehensive Risk Assessment

Regularly review and update your internal AML/CFT risk assessment. Specifically, evaluate your exposure to the risks identified in the ADGM LPA Risk Report, considering your business's activities, geographical footprint, client base, and interactions with legal professionals. This assessment should be dynamic, reflecting changes in your business model, regulatory landscape, and global financial crime typologies.

2. Implement Enhanced Vetting of Legal Professionals

Develop a rigorous process for selecting and monitoring legal service providers, particularly those operating within ADGM.

Pre-engagement Due Diligence: Before retaining a legal firm, conduct thorough background checks. Request details of their AML/CFT policies, internal controls, and their approach to client risk assessment and UBO identification. Verify their regulatory licenses and professional standing.
Contractual Obligations: Incorporate specific clauses in engagement letters and contracts requiring legal service providers to adhere to stringent AML/CFT standards and provide transparency on transactions and beneficial ownership where relevant.
Ongoing Monitoring: Periodically review the performance and compliance posture of your legal partners. Stay informed about any regulatory actions or adverse media against them.

Document Everything

Maintain meticulous records of all due diligence conducted on legal service providers, including questionnaires, responses, and internal assessment notes. This documentation is crucial for demonstrating compliance to regulators and auditors.

3. Establish Robust Internal Controls and Policies

Update your internal AML/CFT policies and procedures to specifically address the risks associated with engaging legal services.

Clear Guidelines: Develop clear internal guidelines for all departments (procurement, legal, finance, executive management) on how to engage, vet, and monitor legal professionals.
Transaction Monitoring: Implement systems to monitor transactions involving legal service providers for unusual patterns, large sums, or payments to/from high-risk jurisdictions.
Escalation Procedures: Establish clear escalation procedures for reporting any red flags or suspicious activities identified during engagements with legal professionals.

4. Provide Continuous Training and Awareness

Educate your employees, especially those in legal, finance, compliance, and procurement departments, on the findings of the ADGM LPA Risk Report and the broader AML/CFT risks within the legal sector.

Targeted Training: Conduct regular training sessions focused on recognizing specific red flags and typologies related to legal professional activities, UBO identification, and source of funds verification.
Awareness Campaigns: Promote a culture of vigilance across the organization, emphasizing the importance of AML/CFT compliance and the collective responsibility to prevent financial crime.

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5. Leverage Technology for Compliance (RegTech)

Consider adopting RegTech solutions to enhance the efficiency and effectiveness of your AML/CFT compliance efforts, particularly for due diligence and ongoing monitoring.

Automated Sanctions Screening: Implement tools for real-time screening of legal professionals and associated parties against global sanctions lists.
UBO Verification Software: Utilize specialized software to map complex ownership structures and verify ultimate beneficial owners.
Transaction Monitoring Systems: Employ advanced analytics to detect anomalous transaction patterns that might indicate illicit activity.

6. Engage Proactively with Compliance Expertise

For businesses operating in complex sectors, engaging with external compliance specialists can provide invaluable support.

Expert Interpretation: Specialists can help interpret regulatory reports like the ADGM LPA Risk Report, providing practical guidance tailored to your specific business context.
Framework Development: Assist in developing or refining your AML/CFT policies, procedures, and internal controls to meet evolving regulatory expectations.
Independent Reviews: Conduct independent audits or reviews of your compliance framework to identify gaps and recommend improvements.
Strategic Advisory: Offer strategic advice on managing high-risk engagements and navigating complex cross-border transactions involving legal services.

Future Outlook and Sustaining Compliance

The publication of reports like the ADGM LPA Risk Report signals a clear and unwavering commitment from UAE authorities to foster a transparent and secure financial environment. The regulatory landscape for AML/CFT is not static; it is in a state of continuous evolution, driven by global standards, emerging threats, and technological advancements. For UAE businesses, this means that compliance is an ongoing journey, not a one-time endeavor.

Sustaining compliance requires more than just meeting current regulations; it demands foresight, adaptability, and a proactive engagement with the evolving risk environment. This includes continuously monitoring updates from ADGM, the CBUAE, MoEc, and international bodies like the FATF. The emphasis will increasingly be on the effectiveness of implemented controls, rather than mere procedural adherence.

The role of collaboration also cannot be overstated. Public-private partnerships, intelligence sharing, and open communication between regulators, businesses, and legal professionals are critical components of a resilient AML/CFT ecosystem. By collectively understanding and addressing the vulnerabilities highlighted in reports such as the ADGM LPA Risk Report, the UAE can further solidify its position as a leading global financial hub that prioritizes integrity and security.

Timeline for Compliance Review

Maintaining an effective AML/CFT framework requires regular review and adaptation.

Annual Comprehensive Review: Conduct a full review of your AML/CFT policies, risk assessments, and internal controls annually, or whenever there are significant changes to your business model or regulatory environment.
Upon New Engagement with LPAs: Perform a thorough risk assessment and enhanced due diligence on any new legal service provider before initiating an engagement.
Following Regulatory Updates: Immediately review and adjust your internal frameworks in response to new ADGM circulars, national AML/CFT legislation, or international FATF guidance.
Post-Incident Analysis: After any identified compliance gap or suspicious activity, conduct a root cause analysis and implement corrective measures.

Compliance Checklist for Engaging LPAs

Before engaging any legal professional, ensure you have addressed the following:

Regulatory Verification: Confirm the legal firm's license and good standing with ADGM or relevant authorities.
AML/CFT Policy Inquiry: Obtain and review the firm's AML/CFT policy and internal control framework.
Risk Assessment Integration: Have you incorporated the LPA Risk Report's insights into your own risk assessment for this engagement?
UBO Clarity: Is the Ultimate Beneficial Ownership of any involved entities fully understood and verified?
Source of Funds/Wealth: Is the source of funds and wealth for the transaction clearly established and legitimate?
Contractual Safeguards: Are AML/CFT compliance clauses included in the engagement agreement?
Red Flag Awareness: Are your internal teams aware of specific red flags related to the proposed legal activities?
Documentation: Have all due diligence steps and communications been meticulously documented?

Common Pitfalls to Avoid

Businesses often encounter specific challenges that can undermine their AML/CFT compliance efforts related to legal engagements.

Over-reliance on Legal Privilege: Misinterpreting legal professional privilege as a blanket exemption from AML/CFT reporting obligations can lead to severe breaches. Privilege does not cover facilitating criminal activity.
Generic Due Diligence: Applying a one-size-fits-all due diligence approach instead of a risk-based methodology, failing to escalate scrutiny for high-risk engagements.
Inadequate Training: Assuming staff automatically understand AML/CFT risks without specific, recurrent training on evolving typologies and regulatory expectations.
Lack of Proactive Review: Waiting for a regulatory inspection or an incident to review and update AML/CFT policies, rather than continuously adapting to the dynamic risk landscape.
Ignoring Behavioral Red Flags: Overlooking subtle cues or unusual client requests that, when combined, point to potential illicit activity.
Insufficient Documentation: Failing to maintain comprehensive records of all due diligence efforts, risk assessments, and decision-making processes, which is critical for demonstrating compliance.

Key Takeaway

The ADGM LPA Risk Report is a critical compass for UAE businesses, guiding them to proactively embed robust AML/CFT measures into their operations, particularly when engaging legal professionals, to protect against financial crime and uphold corporate integrity.

Conclusion

The Abu Dhabi Global Market's LPA Risk Report serves as a timely and essential guide for all businesses operating in the UAE's sophisticated financial landscape. It underscores the critical importance of understanding and actively mitigating the money laundering and terrorist financing risks associated with legal professional activities. By shedding light on specific vulnerabilities and threats, ADGM reinforces the collective responsibility to maintain the highest standards of financial integrity.

For UAE businesses, this report is a clarion call to enhance due diligence practices, fortify internal compliance frameworks, and foster a culture of unwavering vigilance. Proactive engagement with its insights allows companies to not only meet regulatory expectations but also to strategically safeguard their reputation, operational stability, and long-term viability in a global economy increasingly focused on transparency and accountability. The continuous evolution of financial crime necessitates a commitment to perpetual learning and adaptation.

In an environment where regulatory scrutiny is intensifying and the consequences of non-compliance are severe, businesses that proactively integrate these insights will distinguish themselves as responsible and secure entities. While the path to robust AML/CFT compliance may seem complex, expert guidance from advisory firms like AURNE can provide clarity, practical strategies, and the specialized knowledge required to navigate these intricate regulations, ensuring your business remains resilient and compliant.

Source & References

This article is for general information only and does not constitute professional, legal, tax, or financial advice. Speak to AURNE for guidance specific to your situation.

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