Anti-Money Laundering Policy

1. Policy Statement

Abu El Hag Gold Trading Company is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy establishes our framework for preventing, detecting, and reporting money laundering and terrorist financing activities in accordance with:

• UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism
• UAE Cabinet Resolution No. 10 of 2019 Concerning the Implementing Regulation
• Ajman Free Zone Authority regulations
• Financial Action Task Force (FATF) recommendations

2. Scope and Application

This AML Policy applies to:

• All employees, officers, and directors of Abu El Hag Gold Trading Company
• All business relationships and transactions
• All clients, whether individuals or corporate entities
• Third-party service providers and business partners

3. Risk-Based Approach

We employ a risk-based approach to AML/CTF compliance, which includes:

3.1 Risk Assessment

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

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

3.2 Risk Mitigation

Based on our risk assessment, we implement appropriate controls and enhanced due diligence for higher-risk situations.

4. Customer Due Diligence (CDD)

4.1 Know Your Customer (KYC)

Before establishing a business relationship, we conduct comprehensive KYC procedures to verify:

• Customer identity using reliable, independent source documents
• Beneficial ownership for corporate clients
• Source of funds and wealth
• Nature and purpose of the business relationship

4.2 Individual Customers

For individual customers, we require:

• Valid government-issued photo identification (passport, Emirates ID, national ID)
• Proof of address (utility bill, bank statement not older than 3 months)
• Contact information (phone number, email address)
• Source of funds declaration

4.3 Corporate Customers

For corporate customers, we require:

• Certificate of incorporation or registration
• Memorandum and Articles of Association
• Register of directors and shareholders
• Beneficial ownership information (Ultimate Beneficial Owners holding 25% or more)
• Proof of business address
• Authorization for representatives conducting transactions
• Identification documents for authorized signatories

5. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence for higher-risk customers and situations, including:

• Politically Exposed Persons (PEPs) and their family members or close associates
• Customers from high-risk or non-cooperative jurisdictions
• Complex corporate structures or ownership arrangements
• Large or unusual transactions
• Non-face-to-face customer relationships
• Correspondent banking relationships

EDD measures include senior management approval, additional documentation, increased monitoring, and periodic reviews.

6. Ongoing Monitoring

We conduct ongoing monitoring of all customer relationships and transactions to:

• Ensure transactions are consistent with our knowledge of the customer
• Identify unusual or suspicious patterns of activity
• Keep customer information and documentation up to date
• Conduct periodic reviews based on customer risk level

High-risk customers are subject to more frequent reviews (at least annually), while standard-risk customers are reviewed every 3 years.

7. Transaction Monitoring

We monitor all transactions for suspicious activity, including:

• Transactions inconsistent with customer profile or business activity
• Unusual transaction patterns or volumes
• Structured transactions to avoid reporting thresholds
• Transactions with no apparent economic or lawful purpose
• Transactions involving high-risk jurisdictions

We maintain transaction thresholds and reporting requirements in accordance with UAE regulations.

8. Suspicious Activity Reporting

8.1 Reporting Obligations

We are required to report suspicious transactions or activities to the UAE Financial Intelligence Unit (FIU) through the goAML platform, regardless of the transaction amount.

8.2 What is Suspicious?

Suspicious activity may include:

• Customer reluctance to provide information or documentation
• Provision of false or misleading information
• Transactions with no clear business purpose
• Sudden changes in transaction patterns
• Customer involvement with known criminal activity
• Transactions involving jurisdictions of concern

8.3 Tipping Off Prohibition

UAE law prohibits "tipping off" – we must not disclose to the customer or any third party that a suspicious activity report has been filed or that an investigation is underway.

9. Sanctions Screening

We screen all customers and transactions against:

• UAE Local Terrorist List
• UN Security Council Sanctions Lists
• OFAC (Office of Foreign Assets Control) sanctions lists
• EU sanctions lists
• Other relevant international sanctions programs

We do not conduct business with individuals or entities on sanctions lists and immediately freeze assets and report to authorities if a match is identified.

10. Record Keeping

We maintain comprehensive records for a minimum of 5 years from the end of the business relationship or completion of the transaction, including:

• Customer identification and due diligence documentation
• Transaction records and supporting documentation
• Internal and external correspondence
• Risk assessment documentation
• Suspicious activity reports and analysis

Records are stored securely and made available to competent authorities upon request.

11. Training and Awareness

All employees receive:

• AML/CTF training upon joining the company
• Annual refresher training on AML/CTF obligations
• Updates on new regulations and emerging risks
• Specific training relevant to their roles and responsibilities

Training records are maintained to demonstrate compliance.

12. Compliance Officer

We have appointed a Money Laundering Reporting Officer (MLRO) who is responsible for:

• Overseeing AML/CTF compliance program
• Receiving and evaluating internal suspicious activity reports
• Filing suspicious activity reports with the FIU
• Liaising with regulatory authorities and law enforcement
• Conducting internal audits and reviews
• Keeping management informed of AML/CTF matters

13. Independent Audit

Our AML/CTF program is subject to independent audit to assess its effectiveness and identify areas for improvement. Audit findings and recommendations are reported to senior management and the board.

14. Policy Review and Updates

This AML Policy is reviewed annually and updated as necessary to reflect changes in:

• UAE laws and regulations
• International standards and best practices
• Our business operations and risk profile
• Emerging money laundering and terrorist financing threats

15. Consequences of Non-Compliance

Failure to comply with this AML Policy may result in:

• Disciplinary action, including termination of employment
• Criminal prosecution under UAE law
• Significant fines and penalties
• Reputational damage
• Loss of business license

16. Contact Information

For questions about our AML Policy or to report suspicious activity, contact our Money Laundering Reporting Officer: