AML Policy

Home | AML Policy

Al Ahalia Money Exchange Bureau is committed to maintaining a regime in accordance with the Central Bank’s regulations and the best international practices in AML-CTF that acts as a significant deterrent to any criminal elements, including money launderers and persons wishing to assist, in any way, acts of terrorism.
In view of the foregoing, we have implemented robust AML & compliance practices in all our branches. Our state-of-the-art infrastructure and AML software further enable us to be fully compliant at all times.

Our Goal

Al Ahalia Money Exchange Bureau strives its best efforts in designing and implementing the internal policies and continuous staff training so that the movement of funds through this organization does not culminate in financing the harmful activities which impose severe threats to humanity as a whole.
We are committed to the following AML/CFT local laws and regulations as well as international laws and standards including:

  • The Standards for the Regulations Regarding Licensing and Monitoring of Exchange Business (“the Standards”)
  •  Decree Federal Law No. (20) of 2018 On Anti- Money Laundering and Combating the Financing of Terrorism and Illegal Organizations (“AML-CFT Law”).
  • Cabinet Decision No. (10) of 2019 concerning the Implementing Regulation of Decree Federal Law No. (20) of 2018 On Anti- Money Laundering and Combating the Financing of Terrorism and Illegal Organizations (“AML-CFT Decision”)
  • Cabinet Decision No (74) of 2020 regarding Terrorism Lists Regulation and Implementation of United Nation Security Council Resolutions on the Suppression and Combating of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its Financing and Relevant Resolutions.

International laws, Best practices and industry standards, including:

  • Financial Action Task Force (FATF) Recommendations
  • Middle East & North Africa Financial Action Task Force (MENAFATF)
  • Bank Secrecy Act
  • USA Patriot Act
  • Office of Foreign Assets Control (OFAC) of the US Department of the Treasury
  • United Nations Security Council (UNSC)
  • HM Treasury – United Kingdom

“Anti-Money Laundering & Combating Terrorism Financing Compliance Declaration Policy”

We, Al Ahalia Money Exchange Bureau, are committed to operate the business with integrity, within the scope of law and with security. Al Ahalia Money Exchange Bureau has implemented the comprehensive AML & CTF policies and procedure, robust Sanction screening and AML Monitoring system to detect, prevent and report any Money Laundering and Terrorist Financing associated risks.

The company has implemented Risk Management Solutions, like “World-Check”, the most comprehensive Sanctions and Politically Exposed Persons (PEP) database for sanctions and PEP screening. We use the most latest and advanced Transaction Monitoring System for end-end AML Monitoring and real-time sanctions screening.

Al Ahalia Money Exchange Bureau’s policies against Money Laundering and Terrorism Financing ensures highest standards of due diligence in relation to “Know Your Customer (KYC) principles”. We consistently update our policies and systems to comply with the regulatory framework and appropriate guidelines issued by the regulator from time to time.

Al Ahalia Money Exchange Bureau adheres to the Three Line of Defense:

  • Operational Management
  • Risk Management and Compliance Functions
  • Internal Audit

Know Your Customer – KYC

Al Ahalia Money Exchange Bureau’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 conducts 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.
Enhance 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 Al Ahalia Money Exchange Bureau.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.

Al Ahalia Money Exchange Bureau 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.

Staff Training

Al Ahalia Money Exchange Bureau has implemented the comprehensive AML & CFT training program to all employees including to the Senior Management and Board of Directors. The top management of the company strongly believes that effective AML Training will help the company to develop a good corporate governance within the Organization.

Al Ahalia Money Exchange Bureau’s AML/CFT training materials includes:
a) Money laundering and terrorist financing, definitions, typologies as well as recent trends;
b) ML/FT risks associated with the products and services offered by the Licensed Person;
c) AML/CFT policies and procedures including the highlights on recent changes;
d) The regulatory responsibilities and obligations of employees under AML/CFT Laws, Regulations, Notices and the Standards;
e) Description of Know Your Customer process and its importance;
f) Due Diligence measures and procedures for monitoring transactions;
g) Sanction screening and DPEP/FPEP screening procedures;
h) Red flags to identify unusual transactions or transaction patterns or customer behaviours;
i) Processes and procedures of making internal disclosures of unusual transactions;
j) Roles of the Compliance Officer and Alternate Compliance Officer including their full contact details;
k) Tipping off;
l) Record retention policy;
m) Reference to industry guidance and other sources of information;
n) Emerging ML/FT risks and measures to mitigate such risks;
o) Penalties for non-compliance with the AML/CFT Laws, Regulations, Notices and the Standards; and
p) Disciplinary procedures to be applied on employees for not adhering to the AML Policy and Procedures.
Anti-Money Laundering and Combating Financing of Terrorism training is part of the compliance program and training is provided to all new staff and existing staff regarding updates in AML/CFT policies & procedures.

Suspicious Transactions Reporting

Al Ahalia Money Exchange Bureau 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.

Record-Keeping

Al Ahalia Money Exchange Bureau ensures that, a proper file keeping system is in place, all databases and documents are available at all times. Reconstruct the transactions undertaken, at the request of the relevant authorities. Provide copies of these transactions to the concerned authorities at their request.
All the records / documents of transfers are kept for a minimum period of 5 years from the date of transaction.
Al Ahalia Money Exchange Bureau shall at all times 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 defense 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.

Al Ahalia Money Exchange Bureau

Licensed by the Central Bank of the UAE