Anti-MoneyLaundering (AML) Policy

1. PURPOSE & SCOPE

   This policy outlines ProClipse Consulting FZ LLC's commitment and comprehensive approach to preventing money laundering and terrorist financing across all our operations from the UAE to our branches and subsidiaries. It applies to all employees, consultants, trainers, associates, clients, participants, principles and partners.

2. LEGAL FRAMEWORK

   ProClipse Consulting FZ LLC adheres to all relevant AML laws and regulations, ensuring compliance with national and international standards. This includes, but is not limited to, laws set forth by the Financial Action Task Force (FATF) and relevant national regulatory bodies. Specifically, we comply with:

   1. UAE and Middle East:

      • Federal Decree-Law No. (20) of 2018 (as amended by Federal Decree Law No. (26) of 2021)

      • Cabinet Decision No. (10) of 2019 (as amended by Cabinet Resolution No. (24) of 2022)

      • Cabinet Decision No. (58) of 2020 on Beneficial Owner Procedures

      • Cabinet Resolution No. (74) of 2020 on Terrorism Lists and UN Security Council Resolutions

   2. Australia: (In conjunction with the ProClipse AUSTRAC AML/CTF Program)

      • Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act)

      • Financial Transaction Reports Act 1988 (FTR Act)

   3.  All relevant AML laws in jurisdictions where we operate

3. KEY PRINCIPLES & IMPLEMENTATION

   1. Risk Assessment and Management

      • Conduct bi-annual risk assessments using our proprietary risk matrix

      • Implement risk mitigation strategies within 30 days of assessment completion

      • Review high-risk clients quarterly and others annually

      • Align risk assessment procedures with AUSTRAC guidelines for Australian operations

   2. Customer Due Diligence (CDD)

      •  Utilize our digital KYC platform for client onboarding and verification

      • Verify client identity using government-issued ID and biometric checks

      • Screen all clients against international sanctions lists using Thomson Reuters World-Check

      • Conduct enhanced due diligence for transactions above AED 55,000 or equivalent

      • For Australian operations, implement enhanced CDD measures for high-risk customers as per AUSTRAC guidelines (Ref. ProClipse AUSTRAC AML/CTF Program)

   3. Transaction Monitoring

      • Deploy our AI-powered transaction monitoring system to flag suspicious activities

      • Review flagged transactions within 24 hours

      • Maintain a centralized database of all transactions for at least 7 years 

      • Implement effective transaction monitoring programs aligned with AUSTRAC's 2024 regulatory priorities for Australian operations

   4. Reporting

      • Use the goAML portal for reporting suspicious activities to the UAE FIU

      • For Australian operations, report suspicious matters, cash transactions of A$10,000 or more, and international funds transfer instructions to AUSTRAC within mandated timeframes (Ref. ProClipse AUSTRAC AML/CTF Program)

      • Submit reports to relevant authorities in other jurisdictions as required

      • File reports within 48 hours of detecting suspicious activity

   5. Training and Awareness

      • Conduct monthly online AML training sessions for all staff

      • Provide in-person, role-specific training quarterly

      • Assess staff knowledge through bi-annual online tests

      • Share weekly AML updates via our internal newsletter

      • Include jurisdiction-specific training modules for UAE, Australia, and other relevant regions

   6. AML Compliance Team

      • Maintain a dedicated AML compliance team led by our Chief Compliance Officer

      • Conduct weekly team meetings to discuss emerging risks and regulatory changes

      • Provide 24/7 support to staff via our AML hotline

      • Designate compliance officers for each other major jurisdiction we operate in for liaison with Headquarters in the UAE and the Chief Compliance Officer

   7. Internal Controls and Audits

      • Perform monthly internal audits of AML procedures

      • Engage an external auditor for annual comprehensive AML audits

      • Implement audit recommendations within 60 days

      • Ensure audits cover compliance with both international and jurisdiction-specific requirements

   8. Record Keeping

      • Utilize our secure, cloud-based document management system for all AML-related records

      • Maintain records for a minimum of 7 years, with automatic archiving and deletion protocols

      • Ensure record-keeping practices comply with the Privacy Act 1988 for Australian operations (Ref. ProClipse AUSTRAC AML/CTF Program)

   9. Sanctions Compliance

      • Update our sanctions screening database daily

      • Conduct real-time screening of all transactions and new business relationships

      • Block any transactions involving sanctioned entities or individuals

      • Ensure compliance with both international sanctions and jurisdiction-specific lists

   10. Beneficial Ownership Verification

       • Use our proprietary beneficial ownership tracking tool to map complex ownership structures

       • Verify beneficial ownership information annually or upon any change in ownership

       • Refuse business with entities unable to provide clear beneficial ownership information

       • Align verification processes with AUSTRAC requirements for Australian operations

   11. Ongoing Monitoring

       • Conduct continuous monitoring of business relationships using our automated monitoring system

       • Review and update client risk profiles quarterly

       • Terminate relationships with clients who fail to provide updated due diligence information within 30 days of request

       • Implement additional monitoring measures for high-risk clients in line with AUSTRAC guidance

   12. Policy Review and Update

       • Review this policy quarterly in light of regulatory changes and emerging risks

       • Communicate policy updates to all stakeholders within 7 days of any changes

       • Conduct an annual comprehensive policy review with input from all department heads

       • Stay informed about potential regulatory changes, such as the expansion of AML/CTF obligations to "Tranche-2" entities in Australia.

   13. Australia-Specific AML/CTF Program ((Ref.ProClipse AUSTRAC AML/CTF Program)

       • Consult the implemented comprehensive AML/CTF program aligning with AUSTRAC's requirements for our Australian operations.

       • This program includes, but is not limited to, risk assessment, employee training, customer due diligence, transaction monitoring, and reporting procedures specific to Australian regulations

       • Maintain a separate, detailed document outlining the key components of our AUSTRAC-compliant AML/CTF program 

       • Review and update this program annually or as required by changes in AUSTRAC guidelines or our risk profile

       • Ensure all staff involved in Australian operations are trained on and adhere to this specific program

4. INTERNATIONAL BEST PRACTICES AND CROSS-JURISDICTIONAL COMPLIANCE

   ProClipse Consulting FZ LLC is committed to adhering to international best practices in AML/CFT compliance across all our global operations. This includes and not limited to:

   1. Alignment with FATF Recommendations: We strive to align our practices with the latest Financial Action Task Force (FATF) recommendations and guidance.

   2. Cross-Jurisdictional Compliance: We implement additional measures as required by local regulations in each jurisdiction where we operate, as outlined in our Legal Framework section.

   3. Enhanced Due Diligence: We apply enhanced due diligence measures for high-risk customers, transactions, or jurisdictions, including those identified by FATF or local regulatory bodies.

   4. Comprehensive Risk Assessment: Our risk assessment framework considers both local and global risk factors, ensuring a holistic approach to AML/CFT risk management.

5. TECHNOLOGY AND SYSTEMS

   ProClipse Consulting FZ LLC leverages advanced technology solutions that are adaptable to multi-jurisdictional requirements, ensuring consistent application of AML/CFT measures across our global operations. These include:

   • AI-powered transaction monitoring systems

   • Advanced KYC and customer due diligence platforms

   • Sophisticated sanctions screening tools

   • Secure, cloud-based document management systems for record keeping

6. COMMITMENT TO EXCELLENCE

   ProClipse Consulting FZ LLC is dedicated to going beyond minimum legal requirements in AML/CFT compliance where appropriate. This may include:

   • Implementing stricter thresholds for reporting and enhanced due diligence

   • Conducting more frequent reviews than mandated by local laws

   • Deploying more sophisticated monitoring and screening tools, especially in high-risk jurisdictions or for high-risk products/services

7. REGULATORY COMPLIANCE

   ProClipse Consulting FZ LLC acknowledges the authority of:

   • The Central Bank of UAE (CBUAE)

   • The Anti-Money Laundering and Combating the Financing of Terrorism Supervision Department (AMLD)

   • Other relevant UAE regulatory bodies

   • The Australian Transaction Reports and Analysis Centre (AUSTRAC) as the relevant regulatory body.

    

   ProClipse Consulting FZ LLC is committed to maintaining robust AML practices as part of the highest standards of AML compliance. All stakeholders are expected to adhere to this policy and contribute to its effective implementation. Any violations or concerns should be immediately reported to the AML & Compliance Team.

    

   If you have any queries about our AML or other Compliance matters, please contact us:

ProClipse Consulting FZ LLC

PO Box 413724, Dubai, United Arab Emirates

[email protected]

Tel: +971 56 6673300

“ProClipse: Change Is Good” is the exclusively dedicated Change Management brand owned and operated by ProClipse Consulting FZ LLC.