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 Officerwith an independent reporting line to Board Level Compliance Committee, has the overall responsibility to ensure Compliance with requirements of Securities & Commodities Authority (SCA), UAEin 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 SCA, UAE 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 SCA, UAE 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 SCA, UAE; 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.