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AML/CFT Policy

AML/CFT/CPF Compliance Policy at Al Dhahery Money Exchange

Our Commitment to Integrity, Transparency & Financial Crime Prevention

Al Dhahery Money Exchange is committed to maintaining the highest standards of integrity, transparency, governance, and regulatory compliance across all areas of our operations. As an exchange house licensed and regulated by the Central Bank of the United Arab Emirates (CBUAE), we maintain a stringent compliance framework designed to prevent money laundering, terrorist financing, proliferation financing, fraud, sanctions breaches and all other forms of financial crime.

Our Compliance and AML/CFT/CPF Framework Strictly Adheres To

Al Dhahery Money Exchange is fully committed to complying with all local and international AML/CFT/CPF laws, regulations, and guidelines. Our operations strictly align with the following mandates and global best practices, including but not limited to:

  • Federal Decree Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations and its amendment Decree Federal Law No. (26) of 2021.
  • Cabinet Decision No. (10) of 2019 concerning the Implementing Regulation of Federal Decree Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations.
  • Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing and Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025.
  • The Standards for Exchange Houses issued by the Central Bank of the UAE, with specific adherence to Chapter 16 regarding AML/CFT compliance.
  • Official directives, typologies and guidelines issued by the UAE Financial Intelligence Unit (FIU).
  • Recommendations issued by the Financial Action Task Force (FATF).
  • All other applicable international sanctions obligations, regulatory mandates, applicable laws, regulations and international best practices.

Zero-Tolerance Policy

At Al Dhahery Money Exchange, compliance is far more than a regulatory obligation. It is a core business principle deeply embedded within our governance structure, operational framework and corporate culture. We adopt a proactive, risk-based and technology-driven approach to financial crime prevention to safeguard the integrity of the financial system and protect our stakeholders.

Accordingly, we maintain a strict, zero-tolerance policy against:

  • Money Laundering, Terrorist Financing and Proliferation Financing.
  • Sanctions violations and evasion.
  • Fraud, corruption, bribery and corporate malpractice.
  • Unethical or illegal conduct.
  • All other forms of financial crime or operational misconduct.
  • Any activity that compromises the integrity of our internal policies and procedures.

Governance & Tone from the Top

Our Owner, Compliance Committee and Senior Management actively promote a rigorous culture of compliance, ethical conduct, accountability, and absolute regulatory adherence across all of our operations.

The Compliance Function operates as an independent body, empowered with adequate authority, resources and oversight to ensure the flawless implementation of AML/CFT/CPF controls and regulatory obligations.

Our dedicated compliance professionals are specifically responsible for:

  • Direct oversight of the AML/CFT/CPF compliance framework.
  • Fulfilling all regulatory and statutory reporting obligations.
  • Investigating unusual transactional patterns and filing Suspicious Activity/Transaction Reports (STRs/SARs) to the UAE FIU.
  • Managing financial crime risks and evaluating risk parameters across all products, services and delivery channels.
  • Maintaining proactive regulatory liaison with the Central Bank of the UAE and other competent authorities.
  • Driving continuous improvement and ongoing enhancements of our compliance framework and controls.

Risk-Based Approach (RBA)

Al Dhahery Money Exchange applies a comprehensive Risk-Based Approach (RBA) in accordance with CBUAE requirements, FATF Recommendations, and international best practices. Our framework is designed to identify, assess, monitor, and mitigate financial crime risks in a manner proportionate to the nature, size, and complexity of our business operations. Enhanced monitoring and controls are applied to higher-risk customers, transactions and business relationships to ensure effective risk mitigation.

Know Your Customer (KYC)

Al Dhahery Money Exchange implements stringent Know Your Customer (KYC) and Customer Due Diligence (CDD) measures across the entire customer lifecycle, in strict alignment with CBUAE guidelines and international best practices. Customer identities are authenticated using valid, government-issued documents, with Ultimate Beneficial Owners (UBOs) rigorously identified and verified where applicable. By establishing clear customer risk profiles, we continuously monitor transaction activity to proactively identify unusual anomalies or suspicious behavior. In cases of elevated risk, Enhanced Due Diligence (EDD) and advanced monitoring protocols are systematically enforced. We reserve the right to decline or terminate transactions immediately should a client fail to provide the required information or documentation.

Sanctions Screening & Targeted Financial Sanctions (TFS)

Al Dhahery Money Exchange maintains an advanced sanctions compliance framework to ensure absolute adherence to local and international statutory mandates. All customers, beneficiaries, counterparties, and transactions undergo rigorous, real-time automated screening against comprehensive global watchlists and adverse media. Our screening scope covers national and international registries, including the United Nations Security Council (UNSC) Consolidated List, the UAE Local Terrorist List, directives from local regulatory authorities and the UAE FIU, internal high-risk databases, US OFAC, the European Union, and HM Treasury (OFSI). In strict compliance with the mandates of the Central Bank of the UAE, we implement Targeted Financial Sanctions (TFS) obligations, reporting to the respective authorities, asset freezing, and transaction blocks immediately and without delay where applicable.

Transaction Monitoring & Financial Crime Detection

Al Dhahery Money Exchange utilizes an advanced transaction monitoring system, advanced data analytics and rigorous internal controls to detect, investigate and escalate suspicious or unusual activity. Our transaction monitoring framework and rules include but are not limited to behavioral analysis, threshold and velocity monitoring, pattern recognition, anomaly detection, and geographic risk assessment. Backed by a structured escalation and investigation process, this framework ensures the timely identification and reporting of potential financial crime risks. Our systems and controls are continuously enhanced to align with regulatory expectations, emerging typologies and industry best practices.

Suspicious Transaction Reporting (STR/SAR)

All employees are required to immediately escalate unusual or suspicious activities through internal reporting channels.

Where appropriate, suspicious transactions or activities are investigated and reported to the UAE Financial Intelligence Unit (FIU) through the GoAML platform in accordance with applicable laws and regulations. We remain fully committed to timely and effective reporting in support of national and international efforts to combat financial crime.

Staff Training & Compliance Awareness

Al Dhahery Money Exchange is dedicated to maintaining a resilient culture of compliance through continuous staff awareness and professional development. We deliver comprehensive, periodic AML/CFT/CPF training programs to personnel at all organizational levels including frontline staff, senior management, the compliance team, and the Owner. The curriculum encompasses critical regulatory obligations, KYC/CDD/EDD frameworks, sanctions compliance, and internal reporting workflows. Furthermore, our training emphasizes the proactive detection of suspicious activities and evolving financial crime typologies, ensuring our entire workforce remains fully equipped to adapt to emerging risks, regulatory updates, and global industry best practices.

Record Keeping & Confidentiality

In compliance with UAE regulatory requirements, all customer records, transaction data, and supporting documentation are securely maintained for the minimum statutory retention period. We apply strict confidentiality and data protection standards to ensure that customer information is safeguarded against unauthorized access, disclosure, misuse, alteration or loss.

Independent Review & Continuous Improvement

Our Compliance and AML/CFT/CPF framework is subject to ongoing independent review and enhancement to ensure continued effectiveness, adequacy, and alignment with regulatory requirements and international best practices. The framework is periodically evaluated by:

  • Internal auditors.
  • Independent external auditors.
  • Regulatory examiners and supervisory authorities.

We continuously invest in our governance, controls, technology, training, transaction monitoring systems and sanctions screening capabilities to enhance our overall operational infrastructure and strengthen financial crime prevention controls.

Regulatory Cooperation

Al Dhahery Money Exchange fully cooperates with the Central Bank of the UAE, the UAE Financial Intelligence Unit (FIU), law enforcement agencies and all other competent regulatory authorities. We actively support national and international initiatives to combat money laundering, terrorist financing, proliferation financing, sanctions violations and other financial crimes.

We are dedicated to supporting the UAE's ongoing mission to strengthen its AML/CFT/CPF framework through enhanced supervision, enforcement, international cooperation, and strict alignment with FATF standards and international best practices.

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