1. Commitment to Compliance
1.1 ACCLRT is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in the conduct of its business activities.
1.2 The firm has implemented internal policies, procedures, and controls designed to prevent the misuse of its services for money laundering, terrorist financing, proliferation financing, or other financial crimes.
1.3 ACCLRT operates in accordance with applicable Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) laws and regulations of the United Arab Emirates.
2. Regulatory Framework
2.1 ACCLRT adheres to the UAE’s risk-based AML/CFT regulatory framework, including the requirements set out under Federal Decree Law No. (10) of 2025 and related regulatory guidance applicable to financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs).
2.2 ACCLRT continuously monitors regulatory developments to ensure that its compliance framework remains aligned with applicable laws, regulatory requirements, and industry best practices.
3. Customer Due Diligence (CDD)
3.1 Prior to establishing a business relationship, ACCLRT conducts appropriate Customer Due Diligence (CDD) procedures.
3.2 Such procedures may include, but are not limited to:
a. Verification of the client’s identity.
b. Identification and verification of Ultimate Beneficial Owners (UBOs).
c. Understanding the nature and purpose of the business relationship.
d. Assessment of the client’s risk profile.
3.3 Where higher risks are identified, Enhanced Due Diligence (EDD) measures may be applied in accordance with regulatory requirements.
4. Risk-Based Approach
4.1 ACCLRT adopts a risk-based approach to identifying, assessing, and managing potential AML/CFT risks associated with its services and client relationships.
4.2 This approach includes evaluating risks related to:
a. Client profiles and ownership structures.
b. Jurisdictions involved in the business relationship.
c. Nature of the services provided.
d. Transaction patterns and activities.
4.3 Where elevated risks are identified, ACCLRT may implement additional monitoring, due diligence procedures, or risk mitigation controls.
5. Sanctions and Compliance Screening
5.1 ACCLRT may conduct sanctions and compliance screening of clients, beneficial owners, and related parties.
5.2 Screening may be performed against applicable international sanctions lists, regulatory watchlists, and UAE regulatory databases.
5.3 ACCLRT reserves the right to decline, suspend, or terminate engagements where sanctions or compliance concerns arise.
6. Reporting Obligations
6.1 Where suspicious activity is identified, ACCLRT complies with applicable regulatory obligations relating to the reporting of such activities to the relevant competent authorities in the United Arab Emirates.
6.2 ACCLRT maintains internal procedures designed to support the timely identification, assessment, and escalation of potential financial crime risks.
7. Cooperation with Authorities
7.1 ACCLRT cooperates with relevant regulatory and law enforcement authorities in the United Arab Emirates in matters relating to financial crime prevention, regulatory compliance, and enforcement activities.
8. Policy Updates
8.1 ACCLRT reserves the right to update or modify the Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy at any time to reflect regulatory changes, legal requirements, or internal compliance updates.
8.2 Updated versions of this policy will be published on the Website and will become effective immediately upon posting.
9. Policy Updates
9.1 If you have any questions regarding the AML & Compliance Policy, you may contact ACCLRT at [email protected]