AML Policy
Reems Exchange is committed to prevent money laundering and terrorist
financing in accordance with the Central Bank of the United Arab Emirate’s
regulations and international best practices in Anti-Money Laundering (AML)
& Counter Terrorist Financing (CTF). To this effect, we are fully geared
to detect suspicious activities associated with money laundering, fraud,
terrorist financing & financing of illicit organizations, and report
them to the Central Bank of the UAE, as per the regulations. We at Reems
Exchange are dedicated to conduct business securely with integrity and in
compliance with all applicable laws and regulations.
We have therefore implemented robust AML and compliance practices in all our
branches. Our state-of-the-art information technology infrastructure and AML
solutions enable us to be fully compliant at all times.
Anti-Money Laundering Compliance Policy Declarations
Reems Exchange is fully committed to adhering to the laws and regulations
which reflect the relevant recommendations issued by the Financial Action
Task Force (FATF) and in line with Central Bank of UAE’s revised “Standards”
(The Standards for the Regulations Regarding Licensing and Monitoring of
Exchange Business, issued in February 2018 and its amended version 1.20
chapter 16 of November 2021 & Federal Decree Law No. (20) of 2018 on
Anti-Money Laundering and Combating the Financing of Terrorism and Financing
of Illegal Organizations as amended by Federal Decree No. 26 of 2021), we
have revamped our policy and process for doing money remittance business so
as to comply with the standards. Reems Exchange is also determined to
constantly evaluate and uphold its AML policies, procedures and controls on
an on-going basis by ensuring befitting internal and external audit program.
Reems Exchange adheres to the four pillars of an effective AML program:
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• Development of internal policies, procedures and related controls
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• Designation of a compliance officer
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• A thorough and ongoing training program
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• Independent review for compliance.
Know Your Customer (KYC)
We follow a strong identity verification process for all our customers as
per local and international AML/CTF regulations irrespective of the amount
of the transaction.
Robust KYC (Know Your Customer) and KYCC (Know your Customer’s Customer)
policies are adhered to at all levels of the organization. Identifying and
conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)
wherever required is a normal process at Reems Exchange for identifying any
sign of money laundering.
Customer Due Diligence (CDD)
In our CDD process, we obtain relevant details of every customer to ensure
that the transactions they perform are in line with their profile or
business activities. Our focus has always been to ensure the legitimacy of
the source of funds and purpose of transaction.
Enhance Due Diligence (EDD)
EDD is to perform additional measures, besides the usual CDD, to know more
about the customer, his source of funds and to confirm that the transactions
are within its means. To verify that funds are legitimate and not related to
any criminal proceeds by obtaining authentic and genuine documents which
must support both the underlying and stated purpose. Reems Exchange adopts a
risk-based approach to identify and eliminate potential risks. Hence EDD is
compulsorily performed on all high-risk accounts.
Sanctions Screening
To ensure compliance with the applicable sanctions against persons and
entities, Reems Exchange has an automated system to screen the names of the
customers against the sanctions lists issued by the Central Bank of the UAE,
the UN Security Council (UNSC), The Office of Foreign Assets Control
(OFAC),the list issued by European Union (EU), and the local terrorist list
issued by the UAE Supreme Council for National Security. Along with the
customers’ names, all the parties associated with the transactions are also
filtered through the screening system in order to ensure compliance with
Sanctions Obligations.
Transaction Monitoring
Reems Exchange ensures that an ongoing ‘Transaction Monitoring’ is conducted
to detect transactions which are unusual or potentially suspicious based on
the customer profile/ behavior. The front-line agents acts as a first line
of defense and are empowered to escalate any unusual behavior/ transactions
through internal channels. This process is supplemented by an extensive
review of the transactions at the second line of defense including increased
monitoring of the customer’s transactions and behavior.
Reporting of Unusual or Suspicious Transactions
All our staff are trained and equipped to report unusual or potentially
suspicious transactions through our internal channels to the compliance
officer. The compliance officer, conducts an in-depth investigation and
takes appropriate action before reporting such transactions to the Financial
Intelligence Unit (FIU), at the Central Bank of the UAE.
Staff Training
We at Reems Exchange strongly believe in empowering our employees at every
level. Effective AML trainings help the company develop a good AML/CTF
governance at different levels within the organization.
New employees are trained on AML policy & procedures within 30 days of
joining Reems Exchange, with follow-up trainings conducted annually.
Record Keeping & Confidentiality
All records including the customer’s identification documents, related data,
transaction data and any other relevant document are maintained and retained
for a minimum of five years. This is in line with the regulations of the
Central Bank of the UAE. Reems Exchange shall always maintain the
confidentiality of information provided by its customers and their
transaction records.
Independent Review of the Compliance & AML Department
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.