EIIE complies with the Central Bank of the UAE AML laws and regulations. Whenever the governing local laws, regulations and the requirements of the relevant UAE regulations set additional requirements, EIIE will comply with those as well.
EIIE takes its responsibility to comply with AML laws and regulations very seriously. In this regard, EIIE has implemented this AML Program to reasonably mitigate money laundering and Terrorist Financing & financing of Illegal Organization risks and ensure compliance with respect to the scope of its current activities. Compliance with the EIIE’s AML Program as well as the implementing regulations in all the jurisdictions in which EIIE operates is a condition of employment for all EIIE directors, officers and employees. Furthermore, all EIIE employees are required to play an active role to assist EIIE in preventing the use of EIIE’s services for illicit activity.
- EIIE will always abide by the rules issued from time to time by Central bank of UAE and regulatory authorities and to assist the regulatory authority in combating Money laundering and Terrorist financing.
- EIIE’s products and services are not used to launder the proceeds of crime or to assist in Terrorist Financing & financing of Illegal Organization.
- EIIE staffs are aware of their obligations and the need for vigilance in the fight against money laundering and Terrorist Financing & financing of Illegal Organization.
- EIIE will arrange for ongoing training to employees with regards to AML/ CFT policy and procedures and latest Regulations issued by Central bank of UAE from time to time
Know Your Customer (KYC)
EIIE KYC policies and procedures are used to determine the true identity of a customer and the type of activity that is “normal and expected,” and to detect activity that is “unusual” for a particular customer.
Customer Due Diligence (CDD)
EIIE conducts CDD on policies, practices and procedures that enable a financial institution to predict with relative certainty the types of transactions in which the customer is likely to engage. CDD includes not only establishing the identity of customers, but also establishing a baseline of account activity to identify those transactions that do not conform to normal or expected transactions.
Enhance Due Diligence (EDD)
EIIE conducts EDD In conjunction with Customer Due Diligence, it calls for additional measures aimed at identifying and mitigating the risk posed by higher risk customers. It requires developing a more thorough knowledge of the nature of the customer, the customer’s business and understanding of the transactions in the account than a standard or lower risk customer.
EIIE requires all the retail and legal entity customers need to obtain the pre -approval from the compliance department at the time of onboarding and executing the corporate transaction. Proper due diligence measure is implemented to obtain and record the information of the customer in our core application at the time of onboarding which will be subject to screening – Dow jones data base and internal watch list. Unless there is no hit identified we will onboard the customer (retail/corporate) to execute the transaction. If a positive match is identified, we will refrain the customer (legal entity/ Individual) from transaction /onboarding and would report to the regulators by filing the STR. We have also subscribed with World check as an additional screening tool to verify parties as part of EDD. All the supporting documents will be collected and verified prior to the approval of transaction and to identify whether purpose of transaction is in line with their activity.
EIIE regularly monitors transactions to proactively identify potentially suspicious activity based on risk sensitivity. Common approaches to transaction monitoring include the customizable transaction monitoring rules or engaging a third-party vendor to assist with the development and implementation of automated rules.
Reporting of Unusual or Suspicious Transactions
EIIE shall file SAR/STR upon having reasonable grounds to SUSPECT a transaction or funds representing all or some proceeds. STR filing is not simply a legal obligation; it is a critical element of the UAE’s effort to combat financial crime and protect the integrity of its financial system. By filing STRs with the UAE FIU, EIIE alert law enforcement about suspicious behavior and allow investigators to piece together transactions occurring across multiple LFIs.
EIIE ensures that the employees have a clear understanding of the ML/FT risks that it is exposed to and can exercise sound judgment, both when adhering to the FI’s AML/CFT risk mitigation measures and when identifying suspicious transactions. Furthermore, due to the ever-evolving nature of ML/FT risks, EIIE shall ensure that the employees are kept up to date on an ongoing basis in relation to emerging ML/FT typologies and new internal and external risks.
Record Keeping & Confidentiality
EIIE as per Article 24 of the AML-CFT Decision, we shall retain all records and documents pertaining to STRs and the results of all analysis or investigations performed for at least five (5) years from the date of completion of the transaction or termination of the business relationship.
Independent Review of the Compliance & AML Department
EIIE Compliance & AML function is subject to reviews by Internal Audit, the Central Bank of the UAE examiners as well as independent external auditors. This ensures that the compliance program is always up-to-date and is meeting all the regulatory requirements.