Anti-Money Laundering (AML) Policy

1. Scope

This AML policy applies to all company operations, including:

• Real estate investment and advisory
• Property sales and rentals
• Financial transactions conducted on behalf of clients

2. Compliance Officer

Our designated AML Compliance Officer is responsible for:

• Monitoring all transactions
• Reporting suspicious activity to UAE authorities via goAML
• Ensuring all staff follow AML/KYC procedures

3. Customer Due Diligence (CDD)

We implement comprehensive customer due diligence procedures:

• We verify client identities and beneficial ownership
• Enhanced due diligence is applied for high-risk clients or transactions
• Transactions above regulatory thresholds are closely monitored

4. Reporting Suspicious Activity

Employees report suspicious activity internally. Our AML Officer submits Suspicious Transaction Reports (STRs) to the UAE Financial Intelligence Unit (FIU) through the goAML system.

We maintain strict confidentiality regarding all suspicious activity reports and comply with all reporting timelines mandated by UAE regulations.

5. Record Keeping

We maintain all transaction and client records in compliance with UAE regulations and retain them for at least 5 years.

Records include:

• Client identification documents
• Transaction records and supporting documentation
• Due diligence findings and risk assessments
• Internal and external correspondence related to compliance

6. Staff Training

All relevant staff receive AML training upon hiring and regularly thereafter. Training covers:

• Recognition of suspicious activities and red flags
• Internal reporting procedures
• UAE AML laws and regulations
• Customer due diligence requirements
• Record-keeping obligations

7. Review of Policy

This policy is reviewed at least annually or as required by regulatory changes. We continuously monitor developments in UAE AML legislation and update our procedures accordingly.

8. Risk Assessment

We conduct regular risk assessments to identify and mitigate money laundering and terrorist financing risks associated with:

• Client types and profiles
• Geographic locations
• Products and services offered
• Delivery channels and transaction methods

9. Sanctions Screening

We screen all clients and transactions against relevant sanctions lists, including:

• UAE Local Terrorist List
• UN Security Council Consolidated List
• Other international sanctions lists as applicable

Contact Information