AML Policy

ANTI-MONEY LAUNDERING (AML) POLICY



Money laundering is defined as the process intended to mask benefits derived from serious criminal offenses or criminal conduct, as described under Federal Decree No. (20) of 2018 on anti-money laundering and countering the financing of terrorism, to make it appear that such benefits originated from a legitimate source.



1.1 THE THREE STAGES OF MONEY LAUNDERING



Generally, money laundering is composed of three (3) stages involving several transactions which could alert an intermediary such as the Company to the money laundering activity:



Placement – the physical act of disposing of the cash proceeds drawn from illegal activities

Layering – the act of separating illicit proceeds from their source by creating complex tiers of financial transactions in order to disguise the audit trail and to provide anonymity

Integration – the act of providing an appearance of legitimacy to criminally- derived wealth. If the layering process is successful, the integration step places the laundered proceeds back into the economy in a manner that their re-entry into the financial system has the appearance of being normal business funds



1.2 BASIC PRINCIPLES TO COMBAT MONEY LAUNDERING



Denarii Cash endeavors to apply the following principles in order to detect, prevent and oppose the use of the Company’s services for money laundering and terrorist financing:



Established and duly appointed Compliance Office

Know-Your-Customer (CDD and EDD)

Reporting to AMLC

Ongoing Employee Training

Ongoing monitoring and Compliance Testing

Record Keeping and Data retention in accordance with AML laws and regulations

Internal Audit Function



1.2.2 COMPLIANCE WITH LAWS



Denarii Cash ensures that its business is conducted in conformity with the height of ethical standards, that laws and regulations are respected and complied with whenever possible, and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities.



1.2.3 COOPERATION WITH LAW ENFORCEMENT AGENCIES



Within the legal constraints relative to client confidentiality, Denarii Cash cooperates with law enforcement agencies. This includes taking appropriate measures within the law if there are reasonable grounds for suspecting money laundering. Any disclosure made in conjunction with the Act shall be made to the Executive Director of the Anti-Money Laundering Council of the Central Bank of the UAE.

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