Financial Crime Risk Polices
1) Anti-Money Laundering and Counter Terrorist Financing (AML/CFT) Policy Statement:
At Federal Exchange, we are pleased to announce our unwavering commitment to the highest standards of integrity, security, and regulatory compliance. Our dedication to safeguarding the financial system and preventing illicit activities such as Money Laundering(ML) and Terrorist Financing (TF) is the cornerstone of our operations. To promote transparency and awareness, we have compiled comprehensive information on our Anti-Money Laundering and Counter Terrorist Financing (AML/CFT) compliance.
Our Commitment
At Federal Exchange, compliance is not just a requirement; it is a cornerstone of our operations. Our AML/CFT practices are aligned with the Central Bank of the UAE (CBUAE) standards, guidelines, UAE National Risk Assessment (NRA), FATF recommendations, and other international best practices. We prioritize the protection of the financial system, diligently adhering to regulatory frameworks to ensure transparency and trust.
Key Pillars of our AML/CFT Compliance
- Appointment of Compliance Officers: Designated Compliance officers oversee compliance activities, ensuring effective implementation.
- Customer Due Diligence (CDD): We meticulously verify and authenticate the identity of our customers, ensuring a thorough understanding of their financial activities.
- Transaction Monitoring: Our advanced systems continuously monitor transactions for any unusual or suspicious activities, allowing us to take prompt action after EDD measures.
- Risk Assessment: We conduct comprehensive risk assessments to identify and mitigate potential risks associated with our business operations.
- Employee Training and Awareness: Our staff undergo regular role based trainings to stay updated on the latest AML/CFT regulations and best practices. We foster a culture of awareness and responsibility.
- Compliance Audits: We regularly undergo internal and external audits to assess and improve our AML/CFT measures. This ensures that our systems and processes are robust and effective.
- System Controls: Our AML/CFT system controls are robust, covering sanctions screening, monitoring, and risk assessment. We are vigilant against Money Laundering (ML), Terrorist Financing (TF), and Proliferation Financing (PF).
- Record Retention: We adhere to record retention policies, preserving crucial information for regulatory scrutiny.
How We Comply
Federal Exchange complies with UAE regulations by:
- Adhering to CBUAE Guidelines: We strictly follow the guidelines provided by the Central Bank of the UAE to ensure our AML/CFT policies are in line with national regulations.
- Regular Updates: Our policies are dynamic and are updated in real-time to accommodate changes in regulations, ensuring continuous compliance.
Visible Assurance
To demonstrate our commitment to AML/CFT compliance, we make the following visible to our stakeholders:
- Documented Policies: Our AML/CFT policies are documented and readily available for scrutiny.
- Transparent Reporting: We are transparent in reporting our AML/CFT efforts, both internally and externally.
- Cooperation with Authorities: We actively collaborate with regulatory authorities to maintain a proactive stance in compliance.
Your Role
As our valued customer or partner, your trust is paramount. By choosing Federal Exchange, you are partnering with an organization that prioritizes your financial security. We invite you to explore our commitment to AML/CFT compliance and to reach out if you have any questions or concerns.
AML/CFT Policy statement
- Compliance Framework:
We pledge unwavering compliance with Federal Law No. (20) of 2018, Cabinet Decision No. (10) of 2019, CBUAE Decision no – 59/4/2019, and relevant guidelines, including Notice no 74/2019, Notice No. 79/2019, and Notice No. 3090/2021. Adherence to CBUAE Standards (Notice No. 35/2018 and updated chapter 16 – Notice No. 5271/2021) is integral to our commitment. - International Standards:
We align with international bodies such as FATF, MENAFATF, Wolfsburg Group, EGMONT group, and similar entities, embracing their recommendations as part of our vigilance. - Sanctions Compliance:
Stringent measures are in place to fully comply with United Nations Security Council Resolutions on sanctions. We diligently implement different sanction regimes guided by UNSC and CBUAE instructions. - Prohibition of Illicit Activities:
Our commitment is resolute—neither the company nor its staff will knowingly facilitate the laundering of proceeds from any act prohibited by the UAE Legal and Regulatory environment, including predicate offenses. - Risk-Based Approach (RBA):
We embrace a Risk-Based Approach in the implementation of procedures and controls governing the diverse range of products and services offered to our valued customers. - Minimizing ML/TF Risk:
FEDERAL Exchange establishes and maintains effective standards, procedures, and systems to minimize Money Laundering (ML) and Terrorist Financing (TF) risks. This is done in alignment with our risk appetite and utilizing an RBA.
The AML/CFT policy and procedures will be reviewed and updated, Bi-annually at a minimum, to make it consistent with all applicable Laws, Regulations, Notices, the Standards and other international best practices and to make it effective in mitigating the existing as well as emerging ML/FT risks; or changes in any one or a combination (but not limited to).
This AML/CFT Policy is not just a document it’s our commitment to a secure financial landscape, fostering trust and compliance at every level of our operations. Every member of the FEDERAL Exchange family plays a crucial role in upholding these principles.
2) Sanctions Policy Statement:
Policy Statement:
Federal Exchange is committed to strict compliance with all sanctions, both primary and secondary, imposed by the United Nations Security Council (UNSC), local terrorist lists of the UAE and other secondary lists such as Office of Foreign Assets Control (OFAC), European Union (EU), the United Kingdom (HMT) and other international lists. Our commitment extends to adhering to international sanctions laws and regulations, reflecting our active presence in international trade and financial transactions.
We operate under a zero-tolerance policy towards any activity, transaction, or business relationship with sanctioned individuals, entities and countries.
Sanctions Screening Systems:
Our AML/CFT systems are equipped with automatic updates for sanctions filtering, ensuring they stay current with the latest versions of lists published by sanction regimes. Additionally, we employ sanctions screening capabilities within our Point of Sale (POS) System, leveraging the Dow Jones database.
Key Practices:
Screening Customers and Transactions: We conduct rigorous screening of customers and transactions against sanctions lists issued by UNSC, local terrorists list by the UAE, EU, HMT, and OFAC, as well as relevant local and international lists.
Prohibition of Business Activity: Federal Exchange strictly prohibits on-boarding or continuing customer relationships, providing products or services, or facilitating transactions that may violate applicable sanctions or our Sanctions Policy. This includes refraining from engaging in any business activity with individuals or entities named in a sanctions list or activities involving countries or territories subject to comprehensive sanctions.
- Customer Screening: All customers and connected parties undergo screening for sanctioned targets, aligning with applicable sanctions regimes.
- Transaction Screening: Real-time transaction screening is conducted on all transactions concerning designated persons, groups, and entities subject to financial sanctions.
Our commitment to compliance is reflected in our continuous evaluation of the requirements of sanction regimes. The sanctions policy is updated promptly with any changes and, at a minimum, on an annual basis.
By implementing robust measures and staying proactive, Federal Exchange ensures a secure financial landscape, upholding global standards in the face of evolving sanctions laws and regulations.
3) Counter Proliferation Financing (PF) and Dual Usage Policy Statement:
Federal Exchange, in alignment with the UAE’s commitment to countering proliferation financing and dual-use goods, asserts its dedication to preventing the misuse of financial systems for activities related to the proliferation of weapons of mass destruction.
Key Principles:
- Risk Mitigation: We employ a risk-based approach to identify, assess, and mitigate the risks associated with proliferation financing and dual-use goods.
- Compliance with EOCN: Federal Exchange adheres to the guidelines and regulations provided by the UAE’s Executive Office for Control and Non-Proliferation (EOCN) and other government agencies to ensure robust counter-proliferation measures.
- Integration with Sanctions Policy: Our efforts in counter proliferation financing seamlessly integrate with our Sanctions Policy, reinforcing a comprehensive approach to preventing illicit financial activities.
- Continuous Monitoring: We continuously monitor transactions and customer activities to detect and prevent any potential involvement in proliferation financing or the trade of dual-use goods.
By incorporating stringent measures and collaborating with relevant authorities, Federal Exchange remains steadfast in its commitment to preventing the proliferation of weapons of mass destruction and ensuring the integrity of the global financial system.
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