The Customer Acceptance Policy (CAP) of AAEE is an important document in determining the basis on which AAEE enters into relationships with its customers. An inadequate CAP or the inadequate implementation of the CAP can expose AAEE to serious compliance, legal and reputational risks.
AAEE will accept only those customers whose identity is established by conducting due diligence appropriate to the risk profile of the customer. Collecting sufficient relevant information about the customer before the account relationship is established is the most effective defense against AAEE being used as the medium to launder the proceeds of crime or to finance terrorism.
The objectives of this Policy are as follows:
This Policy is applicable to all business units and front-office employees of AAEE and is to be read in conjunction with related operational guidelines which are issued from time to time.
Regardless of the limitations given in this Policy, AAEE fully respects and complies with the right of an individual customer to access basic products in line with consumer protection regulation and refuses any kind of discrimination related to this kind of service.
For purposes of this Policy, a customer is defined as a person or entity who or which maintains an account or has a business relationship with AAEE.
2.1 Accepting new customer – individuals
When accepting new customers (this applies to the establishment of all business relationships AAEE concludes with its customers based on Chapter 16 of the Standards for the Regulations Regarding Licensing and Monitoring of Exchange Business), the responsible employees must act with the highest degree of care and caution in customer identification. This applies also to the process of collecting necessary data, relevant information, and obligatory documents.
AAEE reserves the right to copy the personal documents based on which the customer was identified. The copying and storage process shall be carried out in accordance with the provisions of the Anti-Money Laundering and Terrorist Financing guidance and the Personal Data Protection guidance.
When establishing a new business relationship with individuals, the customer needs to provide to AAEE following information:
Customer identification is carried out at the time of its physical presence and by consulting
the official identity document. As an official document when establishing a business
relationship, AAEE considers:
AAEE will copy the ID document, based on which it will carry out the identification. The copy will be archived in accordance with the legal requirements.
2.2 Accepting a new customer – Legal persons
AAEE requires the following documentation to open an account for a legal person:
(All the original documents shall be required for verification and shall be furnished to Al Amal Express Exchange for verification)
In general, AAEE does not open accounts for legal persons not incorporated in UAE (including freezones) or which are not physically present or keep an operating business in UAE. There are no exceptions to this rule.
A politically exposed person is any natural person who is active, or has been active in the last year, in a prominent public position in UAE or another country, including his immediate family members and close associates.
Natural persons considered to be politically exposed are:
Immediate family members for the purpose of determining political exposure are spouse or partner, parents and children and their spouses or unmarried partners.
The person’s close associates for determining political exposures are all natural persons known to be joint beneficial owners or having any other close business relationship with a politically exposed person. A close associate is also a natural person who is the only beneficial owner of a business entity or similar legal entity under foreign law known to have been established for the benefit of politically exposed persons.
The opening of all accounts to Politically Exposed Persons requires the approval of the AML Officer and manger. In addition, an approval of the board will be required if a legal entity is owned by PEP. Such an account will be classified as High Risk in accordance with the Risk Assessment Analysis and Methodology of AAEE, for Anti-Money Laundering and Counter-Terrorist Financing and requires regular client activity monitoring.
AAEE shall not open an account or process a transaction until the valid personal or commercial identity of the individual or legal entity has been established and verified.
The responsible employee must apply relevant due diligence procedures for customers in the following cases:
AAEE shall not enter a business relationship or execute any transactions before applying due diligence procedures stipulated in this policy and AML policy.
AAEE shall only open an account once all the documents required to be submitted per the relevant category of customer has been duly submitted.
4.1 – Disclosure of ultimate beneficial owner
AAEE must investigate the ownership structure in such a way as to know who the ultimate owner of the legal entity is, up to the natural person, or who are those natural persons who may influence the operations of this legal entity, in accordance with the AML policy and internal procedures.
AAEE should obtain documents from independent and objective sources from which the ultimate beneficial ownership structure of the customer can be inferred. The documents shall be provided by the customer and shall not be older than 3 months at the beginning of the onboarding process.
AAEE should update the customer’s identification information periodically in line with the customer’s AML risk category. Customer due diligence is mandatory if more than a year has passed since the last review of the customer’s business activity and supporting documents (ultimate beneficial ownership structure and other).
All the requirements in chapter 16(of the Standards for the Regulations Regarding Licensing and Monitoring of Exchange Business) concerning updating the customers profile must be followed as mentioned in the AML policy.
AAEE will terminate an established business relationship with the customer if there is a risk of money laundering and terrorist financing or a risk of any other regulatory sanction in relation to the relationship.
AAEE will terminate an established business relationship with the customer if customer engages in any activity mentioned in section 7 of this policy and any activity that exceeds our risk apatite.
AAEEwill close the existing account or terminate any activity if the customer does not provide all the necessary data for AML/CFT.
AAEE may terminate an existing account with immediate effect in cases of breach of contract, breach of other general terms and conditions, as well as for reasons indicating that account activity does not comply with the intent and purpose the customer gave when entering the business relationship, or for reasons of non-compliance with Exchange House rules and regulations.
AAEE does not provide account opening, payment services or any other products to the following the customer groups:
7.1 Prohibition of business based on geographical criterion
AAEE does not establish business relationships or effect transactions with or for legal persons that are directly or indirectly associated with the countries of Yemen, North Korea, Cuba, Iran and the Crimea region.
Also, AAEE will not enter relationships with:
7.2 Prohibition of business based on business activities of the customer
AAEE does not establish business relationships with entities which have registered as
one of the activities:
7.3 Prohibition of business based on other indicators
AAEE does not enter business relationships with entities or individuals of unknown identity or using fictitious or unreal names, or if there is reasonable doubt that the identification documents are falsified.
AAEE will not establish a business relationship with an Exchange House or similar financial institution that:
AAEE will not open an account if the customer’s past activities had a negative financial or reputational impact on AAEE.
Copyright © 2022 Al Amal Express Exchange – All rights Reserved
WhatsApp us