AML Policy

1. Introduction

Money laundering poses a significant threat to the stability and integrity of the global financial system, undermining trust and facilitating illicit activities such as terrorism, drug trafficking, and organised crime. As such, CORELEDGER - F.Z.E recognises the importance of taking proactive measures to combat money laundering and safeguard the integrity of our operations. This Anti-Money Laundering Policy serves as a cornerstone of our commitment to maintaining transparency, accountability, and ethical business practices.

2. Purpose

This policy establishes guidelines and procedures to identify and assess money laundering risks in our operations, implement controls that prevent and detect such activities, ensure compliance with applicable AML laws and regulations, and provide employees with the training required to recognise and report suspicious behaviour.

3. Legal and Regulatory Framework

CORELEDGER - F.Z.E is committed to complying with all applicable laws and regulations related to anti-money laundering.

4. Risk Assessment

CORELEDGER - F.Z.E conducts regular risk assessments to identify and evaluate the potential risks of money laundering associated with our business activities. This assessment takes into account factors such as:

• The nature of our products and services;
• Geographic locations of operations;
• Customer demographics;
• Delivery channels and transaction volumes.

Based on the risk assessment, appropriate controls and measures are implemented to mitigate identified risks effectively. By identifying and prioritizing areas of heightened risk, we are better equipped to allocate resources strategically, implement targeted controls, and tailor our compliance efforts to mitigate the specific threats posed by money laundering activities.

5. Customer Due Diligence (CDD)

CORELEDGER - F.Z.E implements robust customer due diligence procedures to verify the identity of our customers and assess the risk of potential money laundering activities. This includes:

• Obtaining identification documents from customers;
• Conducting enhanced due diligence for high-risk customers, such as politically exposed persons (PEPs) and high net worth individuals;
• Monitoring customer transactions for unusual or suspicious activities.

By conducting thorough CDD, we not only comply with regulatory requirements but also enhance our ability to detect and deter illicit financial activities, thereby safeguarding the integrity of our business operations and the broader financial system.

6. Transaction Monitoring

Transaction monitoring is a critical component of CORELEDGER - F.Z.E's anti-money laundering program, enabling us to detect and investigate suspicious activities in real-time. Our transaction monitoring systems utilise advanced analytics and algorithms to identify unusual patterns, trends, and anomalies indicative of potential money laundering or terrorist financing activities.

The following table outlines the parameters used in our transaction monitoring process:

Parameter	Description
Transaction Amount	Monitoring transactions above a certain threshold for further investigation.
Frequency of Transactions	Identifying unusually frequent transactions by the same customer.
Transaction Patterns	Analysing transaction patterns such as round-figure amounts or repetitive behaviour.

Transaction monitoring thresholds:

Transaction Type	Threshold Amount	Frequency Threshold
Cash Deposits	AED 100,000	1 deposit / day
Wire Transfers	AED 100,000	2 transfers / day
High-Risk Countries	Varies based on risk assessment	—
Structured Transactions	AED 100,000	2 transactions / week

By continuously monitoring customer transactions and account activities against these parameters and thresholds, we can promptly identify and escalate suspicious behaviour for further investigation and reporting. Additionally, our transaction monitoring efforts are complemented by ongoing risk assessments and periodic reviews to ensure the effectiveness and efficiency of our monitoring processes in mitigating the evolving threats posed by financial crime.

7. Reporting and Recordkeeping

CORELEDGER - F.Z.E is committed to fulfilling its obligation to report suspicious activities to the relevant authorities promptly. Employees are required to report any suspicious transactions or activities to the designated compliance officer, who will then assess the situation and determine whether further action, such as filing a suspicious activity report (SAR), is necessary.

In addition to fulfilling regulatory requirements, maintaining comprehensive records of customer transactions and due diligence documentation enables CORELEDGER - F.Z.E to demonstrate our commitment to transparency and accountability. These records serve as a valuable resource in internal audits, regulatory examinations, and investigations, facilitating the identification of trends and patterns indicative of potential money laundering activities. By diligently documenting and reporting suspicious transactions, we contribute to the collective effort to disrupt illicit financial flows and protect the integrity of the global financial system.

8. Training and Awareness

CORELEDGER – F.Z.E provides regular training and awareness programs to ensure employees understand their responsibilities in preventing and detecting money laundering. Training covers relevant laws, regulations and company policies, recognition of red flags that may indicate suspicious activity, and the correct procedures for reporting such activity internally.

9. Compliance Monitoring and Review

CORELEDGER – F.Z.E conducts periodic reviews and audits of its AML policies and procedures to ensure they remain effective and current. Reviews assess the adequacy of existing controls, identify areas for improvement, and result in corrective actions where necessary.

10. Conclusion

CORELEDGER - F.Z.E recognizes that combating money laundering is a collective responsibility that requires ongoing vigilance, collaboration, and adaptation to evolving threats. By adhering to the principles outlined in this Anti-Money Laundering Policy and embracing a culture of compliance throughout our organisation, we reaffirm our commitment to upholding the highest standards of integrity, ethics, and regulatory compliance. Together, we play a crucial role in safeguarding the integrity of the financial system and protecting society from the harms associated with illicit financial activities.

11. Contact Information

For questions or concerns regarding this Anti-Money Laundering Policy, please contact: