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AML POLICY &
PROCEDURE
Cardio
AML POLICY &
PROCEDURE
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AML  POLICY & PROCEDURE

Mesrkanloo International Exchange (MIE) is committed to prevent money laundering and terrorist financing in accordance with the Central Bank of the United Arab Emirate’s regulations and international best practices in Anti-Money Laundering (AML) & Counter Terrorist Financing (CTF). To this effect, we are fully geared to detect suspicious activities associated with money laundering, fraud, terrorist financing & financing of illicit organizations, and report them to the Central Bank of the UAE, as per the regulations. We at MIE are dedicated to conduct business securely with integrity and in compliance with all applicable laws and regulations. We have therefore implemented robust AML and compliance practices in our branch. Our state-of-the-art information technology infrastructure and AML solutions enable us to be always fully compliant.

MIE is fully committed to adhering to the laws and regulations which reflect the relevant recommendations issued by the Financial Action Task Force (FATF) and the Basel Statement of Principles on preventing the utilization of the banking system for criminal purposes, issued by the Basel Committee. MIE is also determined to constantly evaluate and uphold its AML policy, procedures, and controls on an on-going basis by ensuring befitting internal and external audit program.

MIE adheres to the four pillars of an effective AML program:

  1. Development of internal policies, procedures, and related controls
  2. Designation of a compliance officer
  3. A thorough and ongoing training program
  4. Independent review for compliance.

Know Your Customer - KYC

MIE’s policy of Know Your Customer is related to keeping a well-documented, up-to-date file with all relevant information about the customer and their business activities in order to confirm the customer is genuine and the funds involved in their transactions are originating from legitimate sources and used for legitimate purpose. We are required to identify the Beneficial Owners of companies and businesses who remit money or conduct any transaction and should obtain satisfactory evidence of their identities. “All identity documents required will be physically checked and copies of the same will be retained whenever required. Validity of the documents will be checked before acceptance.

Customer Due Diligence - CDD

Customer Due Diligence (CDD) is a process of obtaining relevant details of the customer to ensure that they conduct the transactions in line with their personal profile / business activities; thus, ensuring source of fund and purpose are legitimate as well as to ensure that the transaction is in any way not related to Money Laundering and Terrorist Financing.

Enhanced Due Diligence - EDD

Enhanced Due Diligence is to take additional measures, besides usual Customer Due Diligence, to know more about a customer and to confirm that his/her transactions and funds are legitimate and free from any criminal link by obtaining relevant supporting documents.

Risk Based Approach

Risk Based Approach (RBA) is one of the FATF initiatives and is followed in MIE. RBA assists the financial institutions to make the best use of their limited resources to focus on matters where the money laundering risks are on the higher side. MIE has designed a robust risk assessment method and process for different types of customers and partners who are dealing with us to find out the Risk involved with the business relationship. An Enterprise-Wide Risk Assessment is also carried out for better evaluation and mitigation of risk.

Suspicious Transaction Reporting

MIE is obliged, personally to report, when there are reasonable grounds to suspect that the funds are proceeds of a criminal activity or to be used for terrorism or terrorist act or Terrorist Financing or Money Laundering. All suspicious transactions and activities are reported to the FIU.

Record-Keeping

MIE ensures that, a proper file keeping system is in place, all databases and documents are always available. They help in reconstructing the transactions undertaken, at the request of the relevant authorities. All documents are kept in both soft and hard copy formats. All the records / documents of transactions are kept for a minimum period of 5 years from the date of transaction or date of exiting the relation with the customer. MIE shall always maintain the confidentiality of information indicated in the transaction records.

Independent Review

The AML department is subject to independent reviews by the internal audit team from the 3rd line of defence perspective, by the Central Bank of the UAE examiners, as well as independent external auditors. This ensures the compliance program is always up-to-date and fit for the management of regulatory risk.