QUESTIONNAIRES

POOJA GOLD Annual AML/CFT Risk Assessment (2021) info_outline Instructions

TRADING LLC Reporting period from 1 Jan
to 31 Dec 2020

Inherent Risk
Structure
Q.1 Please select your establishment's legal form:
Please select
Public Joint Stock Company, Private Joint
Stock Company, Limited Liability Company,
Sole Establishment, Sole Establishment LLC,
Free Zone Establishment FZE, or Free Zone
Company FZC.
Q.2 Please select the licensing authority.
Please select

Q.3 Does your establishment have owners / Yes No

shareholders with 25% or more ownership or
control?
Control: for example - voting rights

Q.5 Does your establishment have beneficial Yes No

owners with 25% or more ownership or
control?
Control: for example - voting rights
Q.7 Is the establishment a branch or subsidiary of Yes No
another entity located outside of the UAE?
Q.9 Indicate the total number of employees in
your organization.

Customers
Q.10 What was your establishment's turnover for
Please select
the reporting period?
a)<25,000,000
b)25,000,000-50,000,000
c)50,000,000-75,000,000
d)75,000,000-100,000,000
e)>100,000,000
Q.11 How many total customers / clients did your
establishment have during the reporting
period?
The reporting period is defined as 1 Jan to 31 Dec of 2020
Q.12 Does your establishment have customers / Yes No
clients that are Individuals?
(natural persons)

Q.18 Does your establishment have customers / Yes No

clients that are legal persons?

Products, Services, & Transactions

Q.20 What is the total value of funds transferred,
Please select
buying and selling, of products and services
for precious metals and stones for the
reporting period?
a)<25,000,000
b)25,000,000-50,000,000
c)50,000,000-75,000,000
d)75,000,000-100,000,000
e)>100,000,000
Q.21 Does your establishment sell jewelry? Yes No

Q.22 Does your establishment sell bullion? Yes No

Q.23 Does your establishment engage in refining Yes No

or work with others who conduct refining
activities of precious metals and stones?
Q.24 What is the primary business activity of your
Please select
establishment, by revenue?

Q.25 Does your establishment make domestic Yes No

transactions?
Q.27 Does your establishment make international Yes No
transactions?
Q.29 Does your establishment accept or make Yes No
payments using cash equal to or above AED
55,000?
Q.30 Are there any cases in which your Yes No
establishment received cash amounts
exceeding AED 55,000 for jewellry, bullion, or
precious metals and stones?
Q.31 Please identify, in list form, what additional products and services related to precious metals and
stones that your establishment provides.
If none, state 'none'.

4000/4000

Q.32 Did your establishment accept any virtual Yes No

currency payments in the reporting period?
Q.33 Does your establishment make or receive Yes No
single payments over AED 500,000?

Distribution
Q.34 Does your establishment offer products and Yes No
services in a Commercial Free Zone?
Q.35 Does your establishment operate a store for Yes No
face-to-face customers / clients?
Q.37 Does your establishment operate a website Yes No
for online customers / clients?
Q.38 Does your establishment use a non-staff Yes No
Third Party (Agent, Representative,
Introducer, other) to deal with clients or to
provide or receive products or services?
Q.40 Does your establishment export or arrange to Yes No
export products out of country?
Controls and Quality of Risk Mitigation
Compliance / Regulatory History
Q.41 Has your establishment had any violations in Yes No
the past under Cabinet Decision No. (10) of
2019 concerning implementing regulation of
Federal Decree Law No. (20) of 2018 on Anti
Money Laundering and Combating the
Financing of Terrorism and Illegal
Organizations?
Cabinet Decision No. (16) of 2021

General Policies and Procedures

Q.44 Did your establishment prepare a Yes No
documented set of AML/CFT Policies and
Procedures?

AML/CFT Risk Assessment

Q.46 Did your establishment carry out and Yes No
document an internal risk assessment to
understand its money laundering and
terrorist financing risks?

Governance
Q.52 Do the board and senior management receive Yes No
regular AML/CFT reports?
Q.53 Do the board and senior management ensure Yes No
that shortcomings are rectified?
Q.54 Does the senior management review high risk Yes No
customers / clients?

Compliance Officer
Q.55 Has the establishment appointed a Yes No
compliance officer?

Customer Due Diligence

Q.60 Does the establishment undertake CDD which Yes No
is risk based?

Suspicious Transaction Reporting

Q.65 Did your establishment sign up to the goAML Yes No
system of the FIU?
Q.66 Does your establishment have in place a Yes No
process for monitoring transactions for
potential suspicion and reporting suspicious
transactions?

Record Keeping
Q.69 Does the establishment keep transaction Yes No
records for at least 5 years?
Q.70 Is all CDD and business correspondence kept Yes No
for at least 5 years after the end of a
customer / client relationship?

Training
Q.71 Does your establishment conduct regular Yes No
ongoing AML/CFT training for staff?
Q.72 Does your establishment conduct AML/CFT
Please select
training immediately or shortly after
recruitment?

Targeted Financial Sanctions

Q.73 Does your establishment have procedures in Yes No
place to check if its customers / clients and
any other parties (such as beneficial owners)
are subjects of targeted financial sanctions
by the United Nations Security Council, the
UAE, or any other relevant body?
Q.74 Has your establishment ever identified Yes No
exposure to TFS designated persons?
Q.75 Does the board and senior management Yes No
engagement cover TFS?
Signatories
Attestation of authority
Q.76 Questionnaire prepared by
Please write out your legal name

4000/4000

Q.77 Questionnaire reviewed and approved by

Approval to be completed by the Compliance Officer or Manager (as per the establishment's trade license). Please write out
your legal name.

4000/4000

Ministry of Economy
Version 1.1.1 © FINANCIAL TRANSPARENCY SOLUTIONS Disclaimer