Anti-Money Laundering Policy

1. Policy Statement 

At AHOY, we are committed to preventing money laundering, terrorist financing, and related financial crimes. We uphold the highest standards of integrity, compliance, and transparency in all our business operations. This Anti-Money Laundering (AML) Policy reflects our dedication to compliance with applicable laws and regulations in the United Arab Emirates (UAE), including Federal Law No. 20 of 2018 Concerning Anti-Money Laundering and Combating the Financing of Terrorism, and associated regulations. 

2. Purpose and Objectives 

  • To establish a robust framework for detecting, preventing, and reporting potential money laundering and terrorist financing activities. 

  • To ensure compliance with UAE AML regulations and international best practices. 

  • To educate and empower employees to identify and mitigate AML risks. 

  • To safeguard AHOY’s reputation and integrity by fostering a culture of compliance and transparency. 

3. Scope and Applicability 

This policy applies to all employees, officers, directors, contractors, agents, consultants, and any third parties acting on behalf of AHOY across all geographic jurisdictions, particularly within the UAE. It covers all aspects of AHOY’s operations, including but not limited to financial transactions, client onboarding, and third-party engagements. 

4. Definitions 

  • Money Laundering: The process of concealing the origins of illegally obtained money, typically by complex transactions, to make it appear as legitimate funds. 

  • Terrorist Financing: Providing financial support for terrorist activities, regardless of the source. 

  • Suspicious Activity: Any transaction or activity that raises concerns about potential money laundering or terrorist financing. 

  • Customer Due Diligence (CDD): Procedures to verify the identity of clients and assess AML risks before establishing a business relationship. 

  • Enhanced Due Diligence (EDD): Additional verification measures for higher-risk clients or transactions. 

5. Legal and Regulatory Framework 

AHOY commits to full compliance with applicable AML laws, including: 

  • UAE Federal Law No. 20 of 2018 on AML and Terrorism Financing. 

  • UAE Executive Regulations and related guidelines issued by the UAE Central Bank and the Financial Intelligence Unit (FIU). 

  • International AML standards from FATF (Financial Action Task Force) and other relevant bodies. 

6. Customer Due Diligence (CDD) and KYC Procedures 

  • All clients and third parties must undergo appropriate CDD and KYC checks prior to establishing or continuing business relationships. 

  • Customer identification must include verification of identity documents, source of funds, and assessment of AML risks. 

  • High-risk clients and transactions will undergo EDD with stricter scrutiny and ongoing monitoring. 

  • Ongoing monitoring of all transactions is required to identify suspicious activity. 

7. Detection and Reporting of Suspicious Activities

  • Employees are trained to recognize red flags such as inconsistent transaction patterns, unusual client behavior, or suspicious documentation. 

  • Any staff suspecting money laundering or terrorist financing must report promptly to the designated AML compliance officer or department. 

  • All reports will be handled with confidentiality and in accordance with UAE legal obligations. 

  • Suspicious activity reports (SARs) must be submitted to the UAE FIU without delay, following established reporting procedures. 

8. Record Keeping 

  • Maintain detailed records of all AML-related activities, including customer information, transaction records, risk assessments, and SARs. 

  • Records must be retained for a minimum of five years from the end of the business relationship or transaction, in accordance with UAE law. 

  • Recordkeeping must ensure data confidentiality and security. 

9. Training and Awareness 

  • All relevant personnel will receive ongoing AML training to stay informed of legal requirements, red flags, and reporting obligations. 

  • Training will be conducted periodically and tailored to employees' roles and exposure to AML risks. 

10. Internal Controls and Compliance 

  • Establish and maintain effective internal controls, policies, and procedures to prevent AML violations. 

  • Designate an AML Compliance Officer responsible for oversight, monitoring, and enforcement of this policy. 

  • Conduct periodic AML risk assessments and audits to identify vulnerabilities and improvement areas. 

  • Implement independent reviews and audits on AML compliance. 

11. Due Diligence in Third-Party Relationships 

  • Conduct thorough AML risk assessments for third-party relationships, including due diligence on clients, vendors, partners, and agents. 

  • Incorporate contractual provisions requiring compliance with AML laws and this policy. 

12. Policy Review and Continuous Improvement 

  • This AML Policy will be reviewed annually or upon regulatory updates to remain current and effective. 

  • Updates and improvements will be incorporated based on new risks, regulatory changes, or audit findings. 

13. Disciplinary Actions 

  • Non-compliance with this AML policy may result in disciplinary action, up to and including termination of employment or engagement, and legal prosecution under UAE law. 

  • Employees are encouraged to report any concerns