Our AML Framework

In line with the commitment outlined by our Board of Directors, we developed an AML Program that is centered on the premises of “Know Your Customer” (KYC). Our Compliance Officer(Executive Director – Risk & Compliance), with an independent reporting line to Board Level Compliance Committee, has the overall responsibility to ensure compliance with requirements of UAE Central Bank in relation to AML.

Considering our unique business model, our comprehensive AML Program places special emphasis on the activities performed by our Partners by incorporating the requirements of FATF Recommendation No. 17.

Our AML Policy is built on the following principles:

  • Prior to initiating relationship with new customers, we shall ascertain the identity of Individuals through "Know Your Customer" identification verification procedures;
  • In case of Juridical persons, we shall establish and verify the identity of the ultimate natural person (s) who owns the entity, controls the entity and its assets or on whose behalf the relationship is being established;
  • We shall set up a comprehensive risk assessment system to ascertain the level of risk exposure considering product, payment method and customer;
  • Customer accounts shall be continuously monitored to detect unusual/suspicious activity. We shall utilize adequate processes and systems in this regard. Once suspicious activity is identified, we shall report such customer details to UAE Central Bank in accordance with the regulatory requirements;
  • We shall not entertain any transactions with shell banks;
  • We shall adhere to all applicable sanction restrictions as determined by UAE Central Bank and United Nations. We shall monitor customer accounts against applicable sanction restrictions;
  • Designated Compliance Officer shall incorporate and monitor necessary controls to ensure adherence with all applicable AML requirements;
  • All employees (including trainees and temporary personnel) responsible for carrying out transactions and/or for initiating and/or establishing customer relationships must undergo Anti-Money Laundering training;
  • We shall maintain all customer identity related documentation in accordance with requirements of UAE Central Bank; and
  • We shall extend complete cooperation to UAE Law Enforcement and Regulatory authorities on matters relating to Anti-Money Laundering and combating financing of terrorism.

All the requirements of our AML Program are well documented through a comprehensive set of Policies and Procedures which are updated at periodic intervals. Our custom-built AML System facilitates in risk rating our customers and monitoring their behaviors.

AML_Checklist

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Our Commitment towards Anti-Money Laundering

We are committed to the highest standards of Anti-Money Laundering (AML) Compliance with not just the letter, but also the spirit of the law. Our Policy is designed to ensure compliance with the requirements and obligations set out by UAE Federal Government, Central Bank and other international standards such as Financial Action Task Force (FATF) and Wolfsburg Group Principles. 

Our AML Policy lays down the following guiding principles:
  • Mandatory identification and verification of all customers, including beneficial ownership;
  • Risk-intelligent approach for Customer Due Diligence;
  • Timely identification, assessment and reporting of suspicious transactions;
  • Compliance with Sanction requirements prescribed by UAE Central Bank and United Nations;
  • Periodic training for all employees with emphasis on incorporating a "regulatory compliance culture"

Adherence to our AML Program is the responsibility of every employee and our commitment towards Anti-Money Laundering efforts is supported and led by Board of Directors and Management. We believe that no customer relationship is worth compromising our commitment to combating money laundering. 

A Board Level Compliance Committee ("Committee") has been tasked by our Board of Directors to oversee implementation of NBC's AML Policy. In accordance with the requirements of UAE Central Bank, the Committee has designated our Executive Director - Risk & Compliance as the "Compliance Officer". The Compliance Officer, independently reports to the Committee and has the overall responsibility of maintaining AML Policies, Procedures and Systems effectively and thereby ensuring achievement of NBC's Compliance Obligations. 

We implemented a state-of-the-art automated system to assist in its efforts to combat money laundering and terrorist financing attempts. The automated system facilitates NBC in risk rating customers, watch-list filtering, configure transaction monitoring rules and facilitate resolution of alerts. 

We incorporated a comprehensive AML Training Program, whereby all employees joining the Organization undergo a mandatory AML training followed by periodic trainings at regular intervals. 

NBC management, employees and partners shall strictly adhere to the requirements of the approved Anti-Money Laundering and combating the financing of terrorism policy statement to prevent misuse of NBC's products and services for money laundering purposes.

FATCA & CRS

FATCA - Foreign Account Tax Compliance Act

FATCA was enacted in 2010 by US Government to target non-compliance by US Taxpayers using foreign financial institutions. Government of the UAE has indicated its support for the underlying policy goal and effective July 01, 2014, implemented the requirements of FATCA in the UAE.

As a regulated Financial Institution, we are fully committed to comply with the requirements of FATCA. National Bond Corporation Sole Proprietorship P.S.C. is registered with IRS for FATCA Compliance and carries a Global Intermediary Identification Number (GIIN): 0L7U0L.99999.SL.784.

All banks and financial institutions in the UAE are impacted by FATCA, however, their approach may differ to that adopted by NBC. We may be contacting you to request additional information or documentation to verify your reportable status under FATCA. It is essential that you respond to all requests for information or documentation, even if you believe you already provided such information or if you are certain about your status under FATCA.

If you have any enquiries regarding your tax position or implications of FATCA on your reportable income, please contact your tax advisor, as we are unable to provide you with tax advice.

CRS - Common Reporting Standard

The CRS was developed in response to the G20 request and approved by the OECD “The Organization of Economic Co-operation & Development” Council on 15 July 2014. Under the CRS requirements, UAE Government has outlined its commitment to exchange information from 2018. Accordingly, CRS requirements are implemented effective January 1, 2017.

As a regulated Financial Institution, we are fully committed to comply with the requirements of CRS. As per the requirements, we will obtain information about your tax residency status through self-certification and additional information, wherever required.

If you are tax resident outside UAE, we will provide your information, including details relating to your accounts to UAE Government through our regulator. UAE shall exchange the information relating to your accounts to the tax authorities in the countries where you are considered as resident for taxation purposes. It is essential that you respond to all requests for information or documentation, even if you believe you already provided such information or if you are certain about your tax residency status.

If you have any enquiries regarding your tax residency status, please visit OECD Automatic Exchange of Information Portal, read through our FAQs. In case of specific enquiries, please contact your tax advisor, as we are unable to provide you with tax advice.

Learn more about CRS