AML/CFT Policy

Compliance Policy

AML, CFT, CPF & TFS

Al Jaber Exchange (AJEX) is a leading financial services provider in the UAE, offering remittance services, foreign currency exchange, and wage payments through the Wages Protection System (WPS), operating under a license from the Central Bank of the UAE (CBUAE). AJEX is committed to the highest standards of integrity and compliance, particularly in the areas of Anti-Money Laundering (AML), Counter-Terrorism Financing (CFT), Targeted Financial Sanctions (TFS), and Proliferation Financing. In line with UAE regulations and international standards, AJEX has developed and implemented formal, effective policies and procedures to combat money laundering, terrorism financing, proliferation financing, and financial crimes. The company adheres to the relevant laws, regulations, and guidelines set by the CBUAE and global regulatory bodies such as the Financial Action Task Force (FATF), the Office of Foreign Assets Control (OFAC), the United Nations (UN), and the European Union (EU). AJEX upholds a zero- tolerance policy towards any activities that knowingly or intentionally breach these laws, ensuring transparency and maintaining the trust of its clients and stakeholders. The company’s rigorous internal controls, policies, and procedures are designed to facilitate.

Client Verification:

Verification involves comprehensive checks of information using reliable, independent source documents, data, or information as the second stage of the KYC (Know Your Customer) process and maintaining records of such documents for the periods stipulated by the regulatory authorities.

1. Know Your Customer (KYC)

The Know Your Customer (KYC) principle constitutes the basis of the AML (Anti-Money Laundering) / CFT framework and is the key to effective protection of financial institutions against financial crime. Knowing your customer before executing transactions is the foremost tool of AML/CFT policies and procedures and involves making all reasonable efforts to determine the identity of customers and the beneficial ownership of accounts and ensuring, to the extent possible, that the funds involved in the transactions are originating from legitimate sources and being used for legitimate purposes. Wherein, Customer Due
Diligence (CDD) for standard customers and Enhanced Due Diligence (EDD) for higher-risk customers, tailored to the unique operational environment of Al Jaber Exchange UAE.

2. Customer Due Diligence (CDD)

A process of knowing the customers through the interaction, observance of the behavior, the pattern of transactions, the business, the source of funds as compared to the amount the transaction, etc. which is covered by KYC and Anti-Money Laundering (AML) regulations.

3. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is an advanced risk assessment process designed to scrutinize high-risk such as

i. Politically exposed persons (PEPs) and
ii. Those from high-risk jurisdictions, customers and significant financial transactions. This includes gathering comprehensive background information, verifying the source of funds, and ensuring the purpose of transactions is legitimate, considering the specific risks in the UAE context.

4. Sanctions Screening

Al Jaber Exchange employ automated systems to screen customers and transaction parties against multiple international and UAE-specific sanctions lists. This includes lists from the UAE Central Bank, UN Security Council, OFAC, OFSI, EU, and the UAE Local Terrorist List. Screening is conducted during customer onboarding and on an on-going basis to identify potential risks associated with money laundering and/or terrorist financing activities.

5. Transaction Monitoring

AJEX has implemented an automated monitoring system that is adequate with respect to its size, activities and complexity and the risks present in the exchange house. Our advanced systems are designed to identify patterns or transactions that may indicate money laundering, terrorism financing and proliferation financing.

6. Reporting Suspicious Transactions

In AJEX, whenever we detect transactions or behaviors that appear irregular, full details of all suspicious transactions, whether put through or not, should be reported, and any transaction that seems suspicious may be undertaken only with prior approval of the compliance officer. If the compliance officer is reasonably satisfied that the suspicious transaction has/may have resulted in money laundering, he should immediately make a report to the appropriate authorities through the GO AML Online Portal.

7. Comprehensive Record Keeping & Confidentiality

All records, documents, data, and statistics related to transactions, such as transaction receipts, KYC, CDD, and EDD; ongoing monitoring; business correspondence; and copies of personal identification documents must be retained for a minimum period of five (5) years from the date of completion of the
transaction, termination of the business relationship, or from the closing date of the account with utmost confidentiality.

8. Employee Training and Awareness

As per The Standard, AML training is given to all new employees within 30 days of joining, with annual follow-up training sessions. Training covers AML/CFT/CPF policies, identifying suspicious activities, and understanding legal obligations, tailored to the UAE’s regulatory landscape.

9. Regular Policy Reviews

AJEX periodically review and update our AML/CFT Policy to align with evolving regulations, industry best practices, and changes in our operations. This continuous evaluation helps us remain compliant and adapt to new challenges.

10. Independent Review of Compliance & AML Department

The Compliance function undergoes regular reviews by internal auditors, UAE Central Bank examiners, and external auditors. These reviews assess the program’s effectiveness and ensure compliance with regulatory requirements, focusing on the unique operational risks and regulatory environment in the
UAE.