AML Policy

1. Introduction

Joyalukkas Exchange is committed to the highest standards of Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Countering Proliferation Financing (CPF). Our policy reflects our dedication to adhering to the Central Bank of the UAE’s regulations and international best practices, including those set by the Financial Action Task Force (FATF). We aim to protect our services from being misused for financial crimes by implementing robust detection, deterrence, and reporting mechanisms.

2. AML Compliance Policy Declarations

Joyalukkas Exchange pledges full compliance with the UAE’s AML/CFT/CPF laws and regulations, aligning with the FATF recommendations and the Basel Committee principles. Our AML policies and procedures are designed to mitigate risks and are subject to continuous improvement through regular internal and external reviews.

3. AML Program Pillars

  • Development of Internal Policies and Controls: Creating and maintaining detailed AML/CFT/CPF policies specific to our operations and the unique risks we face in the UAE.
  • Designation of Compliance Officer: Appointing a senior compliance officer with in-depth knowledge of UAE regulations and approval from the Central Bank of the UAE, responsible for overseeing AML/CFT/CPF activities.
  • Training Programs: Offering comprehensive and ongoing training tailored to our employees’ roles, ensuring they understand their responsibilities and the specific risks associated with our business.
  • Independent Review: Engaging in regular independent reviews of our AML program to ensure its effectiveness and adherence to UAE laws and international standards.

4. Know Your Customer (KYC)

We implement rigorous KYC procedures to verify the identity of all customers, ensuring compliance with local and international regulations. This includes Customer Due Diligence (CDD) for standard customers and Enhanced Due Diligence (EDD) for higher-risk customers, tailored to the unique operational environment of Joyalukkas Exchange UAE.

5. Customer Due Diligence (CDD)

We collect sufficient information to understand each customer's identity, financial activities, and transaction purposes. This involves verifying identities using reliable, independent source documents, data, or information relevant to the UAE market.

6. Enhanced Due Diligence (EDD)

For high-risk customers, such as politically exposed persons (PEPs) and those from high-risk jurisdictions, we apply additional scrutiny. This includes gathering comprehensive background information, verifying the source of funds, and ensuring the purpose of transactions is legitimate, considering the specific risks in the UAE context.

7. Sanctions Screening

We employ automated systems to screen customers and transaction parties against multiple international and UAE-specific sanctions lists. This includes lists from the UAE Central Bank, UN Security Council, OFAC, OFSI, EU, and the UAE Local Terrorist List. Screening is conducted during customer onboarding and on an ongoing basis to detect any sanctioned entities or individuals.

8. Transaction Monitoring

Our transaction monitoring systems are designed to detect unusual or suspicious activities specific to the nature of transactions we handle in the UAE. This involves real-time and retrospective analysis to identify patterns or behaviors indicative of money laundering, terrorist financing, or proliferation financing.

9. Reporting of Suspicious Transactions

All staff are trained to recognize and report suspicious transactions through established internal channels. The compliance officer investigates these reports and, when necessary, files Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit UAEFIU.

10. Staff Training

We provide extensive AML training to all new employees within 30 days of joining, with annual follow-up training sessions. Training covers AML/CFT/CPF policies, identifying suspicious activities, and understanding legal obligations, tailored to the UAE's regulatory landscape.

11. Record Keeping & Confidentiality

We maintain comprehensive records of customer identification documents, transaction data, and AML-related activities for a minimum of five years from the date of last transaction, ensuring they are securely stored and treated with the highest level of confidentiality in compliance with UAE regulations.

12. Independent Review of Compliance & AML Department

The Compliance function undergoes regular reviews by internal auditors, UAE Central Bank examiners, and external auditors. These reviews assess the program's effectiveness and ensure compliance with regulatory requirements, focusing on the unique operational risks and regulatory environment in the UAE.