A2B GOLD DMCC KYC & AML Policy

1. Introduction
A2B GOLD DMCC is committed to complying with all applicable Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) regulations, including the UAE Federal Decree-Law No. 20 of 2018 on AML and Combatting the Financing of Terrorism, and the Executive Regulation issued under Cabinet Decision No. (10) of 2019. This policy outlines the procedures and measures we implement to prevent financial crimes such as money laundering, terrorist financing, and other illicit activities.
A2B GOLD DMCC is also registered with the goAML system, developed by the United Nations Office on Drugs and Crime (UNODC), and works in collaboration with the UAE Financial Intelligence Unit (FIU) to report and combat suspicious transactions.

2. Scope
This policy applies to all customers, vendors, suppliers, partners, and counterparties of A2B GOLD DMCC. It is designed to ensure that we conduct business with reputable individuals and entities, in line with applicable laws, while maintaining the highest standards of transparency, integrity, and due diligence.

3. Customer Due Diligence (CDD)
3.1 Customer Identification
We undertake thorough due diligence to identify and verify all customers before engaging in business relationships. The following documentation is required:

  • For Individuals:
  • Copy of a valid passport, national ID card, or driver’s license.
  • Proof of residential address (e.g., utility bill or bank statement).
  • Politically Exposed Person (PEP) status check.

  • For Corporate Entities:
  • Certificate of incorporation and business registration documents.
  • Memorandum and Articles of Association.
  • List of directors and senior management.
  • Verification of the identity of beneficial owners holding 25% or more ownership (including their national ID/passport and proof of address).
  • Proof of company address.

3.2 Enhanced Due Diligence (EDD) for High-Risk Customers
For customers identified as high-risk (e.g., those from Conflict-Affected and High-Risk Areas (CAHRAs) or involving complex ownership structures):

  • Additional documentation or information, including site visits or third-party verification.
  • Continuous monitoring and re-assessment of business relationships.
  • Clear justification for maintaining the relationship, subject to board approval.

3.3 Verification
  • Customers are screened against global sanctions lists, PEP lists, adverse media, and the UAE FIU blacklist using NameScan.io and other reliable screening tools.
  • Local verification is conducted through the UAE International Export Control (IEC) platform (uaeiec.gov.ae) and any other applicable UAE regulatory platforms.

4. Vendor, Supplier, and Partner Due Diligence
The same level of scrutiny applied to customers is also extended to vendors, suppliers, and partners:

  • Identification and Verification:
  • Business registration documents, beneficial ownership structure, and proof of address.
  • Screening against local and global sanctions lists, PEP lists, and adverse media.

  • Compliance with UAE Regulations:
  • Verification through the UAE IEC platform to ensure adherence to all local export and import control regulations.

5. Ongoing Monitoring
  • Transaction Monitoring: Continuous monitoring of all financial transactions to detect suspicious or unusual patterns, particularly those involving high-risk jurisdictions or high-value transactions.
  • Use automated systems to flag suspicious transactions for further review.

  • Periodic Review: Customer, vendor, and partner information is reviewed periodically (at least annually) to ensure accuracy and compliance.

  • High-risk entities must undergo more frequent reviews, particularly if new risks are identified.

6. Record Keeping
  • Retention Period: All customer, vendor, and partner identification documents, due diligence records, and transaction records are securely maintained for a minimum of five years from the date of the last transaction or business relationship termination.

  • Security: All records are stored electronically in a secure database, protected from unauthorized access, ensuring confidentiality and integrity.

7. Suspicious Activity Reporting (SAR) and goAML
A2B GOLD DMCC is registered with the goAML system, which is used by the UAE Financial Intelligence Unit (FIU) to receive, analyze, and distribute suspicious transaction reports (STRs). Our reporting process includes:

  • Internal Reporting: Employees must report any suspicious activities immediately to the Compliance Officer using the internal reporting mechanism.

  • Suspicious Transaction Report (STR):
  • The Compliance Officer will investigate the suspicious activity and, if deemed necessary, file a Suspicious Transaction Report (STR) via the goAML platform with the UAE Financial Intelligence Unit (FIU).

  • STRs are filed in compliance with UAE regulations using the goAML system to ensure quick, efficient, and secure reporting of suspicious activities.

  • Collaboration with FIU: We maintain a close working relationship with the FIU to ensure proper handling of suspicious activity reports and to collaborate on investigations if necessary. Our Compliance Officer will monitor the reported activity and maintain communication with the FIU as required.

  • Follow-Up: The Compliance Officer will continue to monitor reported activities and maintain communication with the relevant authorities as required, ensuring that all regulatory obligations are met.

8. Grievance Mechanism
  • A2B GOLD DMCC has established a confidential grievance mechanism that allows employees, customers, and external stakeholders to report concerns related to the sourcing or trading of gold, including concerns about involvement in Conflict-Affected and High-Risk Areas (CAHRAs). All reports are treated confidentially and impartially.

9. Training and Awareness
  • Mandatory Training: All employees involved in customer interactions, transaction processing, and compliance-related functions receive mandatory training on AML, KYC, and CFT regulations annually.

  • Specialized Training: Employees working with high-risk customers or transactions undergo enhanced, role-specific training, including how to identify red flags and report suspicious activities.

  • goAML Training: Employees involved in suspicious transaction reporting are trained on how to use the goAML system to ensure reports are filed accurately and in a timely manner.

10. Policy Review
  • Annual Review: This policy is reviewed annually to ensure it remains up-to-date with regulatory changes and best practices.

  • Immediate Updates: Any regulatory changes impacting AML/KYC procedures will trigger an immediate review and update of the policy, with all stakeholders being informed promptly.

11. Contact Information
For any questions or concerns regarding this policy or to report suspicious activities, please contact our Compliance Officer at compliance (at) a2bgold.com.