AML Policy

AML Policy

Yase Exchange joins hands with Central Bank of the UAE, the Organization of American States and other major international organizations to fight money laundering and terrorist funding activities. Keeping this mind, we have implemented the best AML practices in all our branches. Our state-of-the-art infrastructure and AML-compliant software further complements the requirements of KYC principles.

Anti-Money Laundering Compliance Policy Declarations

Yase Exchange is fully committed to adhering to the local Laws and Regulations which reflect the relevant recommendations issued by Financial Action Task Force (FATF) and the Basel Statement of Principles on preventing the utilization of the banking system for criminal purposes, issued by the Basel Committee.

Accordingly, we have taken the necessary procedural and control measures to provide our support in the fight against money laundering and the financing of terrorism.

Yase Exchange is also committed to continually fulfill its Anti-Money Laundering obligations to its foreign correspondent banks who may from time to time require due diligence information on transactions covered under the guidelines and recommendations of the FATF.

Yase Exchange is also committed to examining and maintaining its Anti-Money Laundering procedures and controlon an on-going basis.

To ensure continuity of high standards of Anti-Money Laundering Compliance, our Internal Audit Group will monitor and test the Compliance Program through random examination of the relevant processes and controls on a monthly, quarterly and six monthly basis, and report its findings directly to the Managing Director.

Ascertainment of customer identity

Customer identity is being verified before accepting a customer's transaction for AED 2000 and above or equivalent in foreign currency. Customer identity is also being verified for unusual/suspicious transactions regardless of the amount. 'Know Your Customer / Customer Due Diligence procedures and guidelines' are scrupulously adhered to.

Establishment of ultimate beneficial owner of funds

True and ultimate ownership of remittance money is being established before accepting a customer's request in cases where a customer acts on behalf of another person or entity. In such a case, the employee handling the transaction obtains identification details from the customer at our counters. In case of doubt that a transaction might be meant for terrorism or terrorist organizations or for terrorist purposes, Yase Exchange will freeze the transaction and inform the financial intelligence unit at the Central Bank in writing immediately.

Enhanced know your customer/due diligence

Enhanced due diligence is conducted when transactions appear to be potentially suspicious on the basis of suspicious transaction indicators. Customer service staff ensures to ask for additional identification documents or documentary proof of source of fund as they deem appropriate. Compliance Regime conducts in-depth due diligence when an unusual/ potentially suspicious transaction report #UPS 1 is received from branches or operations, and also when the regular surveillance of remittances reveals potentially suspicious activities.

Internal Reporting of Unusual /potentially suspicious transaction

All staff handling remittances are required to report any potentially suspicious or unusual transactions, to Compliance Officer, using our internal reporting system.

Reporting of unusual / suspicious transactions

All Staff are required to detect and report unusual/ potentially suspicious transactions to Compliance Officer who will in turn, conduct in-depth investigation, and take an appropriate action before reporting such transactions to Anti-Money Laundering Suspicious Case Unit (AMLSCU) at the UAE Central Bank.

Staff Training

Training on Anti-Money Laundering is being provided within a maximum of two months after the employee has joined Yase Exchange, with follow up training for every employee every two years. This training covers employees with customer contact or those authorized to handle and complete cash and non-cash transactions.

The training is also provided to those who are:

• Currently not engaged in customer service but do provide relief duties in branches during the vacation period of customer service staff.
• Members of compliance regime i.e. Area Compliance officers, and Branch Compliance Officers in line with their Anti-Money Laundering responsibilities.

Internal security measures - Know your staff

The HR Dept. confirms and documents the reliability of employees first, when a person is employed and again within a period of twenty four (24) months thereafter. The latter documentation consists of an attestation by an appropriate supervisor stating that there is no reason to believe the person is not reliable in terms of the UAE Anti-Money Laundering Law and Regulations.

Record keeping

All records including, customer's identification documents and related data, transaction data, and any other related documents are maintained and retained for a minimum of five years.

Confidentiality of records and suspicious transactions

All customer and transactional information is kept confidential at all times, and in addition, customer are not advised that their transactions are considered suspicious and being reported to Compliance Officer internally, or to the UAE Central Bank. Non-Compliance invites criminal charges against Yase Exchange, its Chairman, Director, Management, and its employees at fault.

Internal Audit's Role

Internal Audit tests the activities of the Compliance Regime, and performs random checks on key responsibilities. All findings and observation are being discussed with Manager Compliance, and reported to the Managing Director. Money Laundering & terrorist funding is a global challenge and a declared criminal activity in most countries.

The U.A.E government also has promulgated Federal Law No.4 criminalizing money laundering activities.

Under the aforesaid Federal Law, the U.A.E. Central Bank has issued Anti-Money Laundering Regulations which encompass the Forty Recommendations on combating Money Laundering and the Eight Special Recommendations on combating Terrorist Financing, issued by Financial Action Task Force (FATF) established by G7 countries.

Financial Institutions including Money Services providers licensed to operate in the U.A.E. are legally liable to comply with these regulations requiring but not limited to; due diligence checks, monitoring of financial transactions to detect and report possible money laundering transactions.

Definition of money laundering

Money laundering refers to any transaction aimed at concealing and/or changing the identity of illegally obtained money, so that it appears to have originated from legitimate sources, where in fact it has not. This includes monies that are destined to finance terrorism or criminal acts. Examples are money derived from illegal activities such as;

• Narcotics and psychotropic substances.
• Kidnapping, piracy and terrorism.
• Offences committed violation of the environmental laws.
• Illicit dealing in fire-arms and ammunition.
• Bribery, embezzlement, and damage to public property.
• Fraud, breach of trust and related offences.
• Any other related offences referred to in International Conventions to which the U.A.E. is party.