Anti-Money Laundering policy implemented and followed by ABC Auditing

Accepting client.
While accepting a new client the client’s name, shareholders’ name and key stakeholders' name (if required in any
case) must be subject to screening with the AML screening software implemented by the firm (ABC Auditing).

To confirm that our organisation, have complied with all UAE Federal laws or regulations relating to AML/CFT and
is not aware of any violations or possible violations of these laws and regulations which may have any regulatory
implications the following procedures must be performed during the assignment and any suspicious must be reported
to Money Laundering Reporting Officer, MLRO.

Procedures to be performed at different stages of the assignment:

Test Observation
Meeting clients in their principal place of business.
Planning & Risk Assessment Phase

Understanding the nature of client’s business.

For existing clients - reviewing Client Registration

Form (CRF) and matching the details with client data
base. Any changes in the structure, activity or any risk
area to highlighted to the reviewer, MLRO & partner.

Perform screening on:

 Interpol Site – Attach Screenshot Use the sanction screening software

implemented.
 CIA Site – Attach Screenshot

 UN Sanctioned List – Attach Screenshot

 Checking within updates received from MLRO,

reviewer & partner.
 Test Observation
Review the legal documents of the entity in addition to
provided during CRF and look for Ultimate Beneficial
Owner UBO, specially where the shareholders are:
 Corporate/companies
 Offshore formations
 Shareholders do not reside in UAE.
 Politically Exposed Person (PEP)
 Legal persons owned by individuals of the same
origin or with participation of individuals of the same
origin from jurisdictions that are considered as non-
cooperative.
While performing audit check if the entity is involved
in the below mentioned activity / transactions during
the period under audit:

 Non‐Governmental Organizations (NGOs)

 Financial Investment Corporation
 Arms, weapon manufacturers, distributors and
During Field Work

dealers
 Precious metals distributors and dealers
 Antique dealers
 Professionals who act as intermediaries (Lawyers or
accountants that manage their customer’s funds in
their accounts)
 Auction houses
 Real Estate Companies
 Hotels Casinos, Gaming Centers, Racetracks
 Money Remittance Companies
 Cash‐intensive businesses (such as supermarkets,
restaurants/bars, parking garages and some
unorganized sectors)
General Transactions Susceptible To ML/FT:
 Barter Exchange
 Funds From “Tax Havens” Or From Countries That
Are Considered Non-Cooperative By FATF, Or If
They Send Large Amounts Of Money To These
Countries On A Regular Basis.
 When There Seems To Be No Logical Business
Explanation To Conduct Such Transactions.
 Client Located At Such Place Or Who Sends Or
Receives Large Fund Transfers On A Regular Basis
That Cannot Be Clearly Identified As A Legitimate
Transaction, To Or From Countries Where There Is A
Reportedly High Drug‐ Trafficking Activity Or
Known Connections To Terrorist Organizations, Or A
Country That Is Considered As Non-Cooperative To
Combat Money Laundering, Or A Country That Is
Not Compliant With International Standards
 Test Observation
Regarding Client Identification And Know Your
Customer Policies Or Suspected Of Money
Laundering Activities
 Transfers Broken Into Smaller Amounts Of Money
That Are Clearly Trying To Avoid A Huge Sum.
 Transfers Sent Or Received That Do Not Provide
Clear Information About The Sender Or Payee In
Order To Identify Such Transaction. Transfers Of
Large Amounts Of Money To Or From Abroad That
Are To Be Paid In Cash.
 International Transactions To Customers/Accounts
Without Having The Necessary Background On
Those Transactions, Or Where The Stated Business
Activity Of The Customer Does Not Explain Such
Transaction.
 Transfers Received From Abroad That Are Almost
Immediately Used For Buying Financial Instruments
To Conduct Payments To Third Parties.
 Staff At The Firm Who Show A Sudden Change In
Their Lifestyle Or Refuse To Take Time Off.
 Staff At The Firm Who Use Their Personal Address
To Receive Documentation From Customers.
 Special Attention Should Be Paid To Staff At The
Firm Who Show A Sudden And Significant Increase
In Their Operations.
 When Dealing With Peps, Special Attention Should
Be Paid To Their Transaction, Making Sure These
Are Consistent With The Activity Stated And The
Client Profile.
 Client Who Makes Unsound Use Of The Services Of
The Firm.
 Transactions being performed on behalf of 3 rd party/is
or family members (Holding Real Estate etc.)
 Any sign of forgery of documents which may be used
to transfer fund to other countries.
 Funding the nuclear program directly or indirectly.
Check inventory items not of dual nature (may be
used in nuclear weapons) and oil or its derivatives etc.
 Use of exchange houses/ networks to make payment
to terrorists.
 Sale & purchase of items with customer / supplier of
jurisdiction or country that are not compatible with
technical level of the receiving or supplying country.
 Individual or entity online presence or culture
supports violent extremism or radicalization.
 Inaccurate info., Irregularities or inconvenience
during KYC.
 Donation to sanctioned group, derogatory
information, etc.
 Dealings, directly or through a client of your client,
 Test Observation
with sanctioned countries or territories where
sanctioned persons are known to operate.
 Change in activity or developed during the course but
was not intended when the company formed.
(Applicable if license activity not changed).
 Complex legal structure or commercial terms to hide
the beneficial owner.
Suspicious Transaction Reporting (STR):
In case, you find any suspicious transaction or have
doubt about the transaction or any hint that encourage
you to file STR; discuss with MLRO, reviewer and
partner, on timely basis.
(You must not discuss the matter with your client,
otherwise you might be convicted for tipping off)
Note: Refer FATF site for sanction countries list and updates at https://www.fatf-gafi.org/about/

________________________
Prepared By: Click or tap here to enter text.

Acknowledged By:

Staff Name:
Date: December 15, 2023