AML Policy

The Lari Exchange Management always gives high importance to AML /CFT and Regulatory Compliance from the inception of the business.

The Lari Exchange’s AML-CFT Compliance Program is designed to fulfill the requirements stipulated by the Central Bank of the UAE, applicable international laws and standards.  These laws / standards include but not limited to Federal Decree Law No. (20) of 2018, Cabinet Decision No (10) of 2019, Cabinet Resolution No. 74 of 2020 and FATF recommendations on Anti Money Laundering & combating terrorist financing etc.

 

Lari Exchange has designed and implemented an effective as well as comprehensive compliance policy and procedures based on CBUAE and international standards. The policy covers all product and services of our exchange, and it is approved by the partners/owners of the company.

The Policy and procedures being reviewed and updated annually at minimum or there are any changes in local and international laws or standards.

A designated Compliance Officer has been appointed by Lari Exchange who has been given the specific responsibility of managing its AML/CFT compliance program.

In accordance with the international and regulatory standards for financial institutions, we are committed to design an effective RBA policy to identify, assess and mitigate the AML/CFT Risk involved for the operations of our exchange company.

We have designed a robust risk assessment methods and process to identify the Risk involved with the business relationship.  Based on the various risk factors involved, we classify our customers under different category such as High Risk, Medium Risk and Low Risk.

Lari Exchange has identified and assessed the money laundering and financing of terrorism (ML/FT) risks associated with its business on a regular basis using following perimeters:

a.      Customer Risk

b.      Counterparty Risk.

c.      Product Risk.

d.      Jurisdictional / Country Risk

e.      Delivery Channel Risk.

The Know Your Customer (KYC) principle in line with Central Bank of the UAE and international standards constitutes the basis of the AML/CFT framework and is the key to effective protection of financial institutions against financial crime. Lari Exchange ensured that the funds involved in their transactions are originating from legitimate sources and used for legitimate purposes using carrying out effective KYC process.

These processes are followed:

a.      Customer Identification (CID) Process;

b.      Customer Due Diligence (CDD) Process; and

c.      Enhanced Due Diligence (EDD) Process.

Lari exchange is very keen to conduct sanctions & PEP screening process and escalation procedures as required by regulators, correspondent banks and international organizations. We have designed robust system for the screening of customers and Transactions against Local & International Sanctions and Politically exposed Person (PEP).

Sanction & PEP screening is conducting real-time with the use of an exclusive Screening system where the Refinitiv’s World-Check database has been incorporated that contains all mandatory list including CBUAE, OFAC, UNSC, EU, HM Treasury, List of PEPs etc., and other required lists.

 

We have implemented effective transaction monitoring system to identify the unusual transactions through our exchange house. We have implemented an independent system to monitor all transactions through our exchange and   incorporated various monitoring rules with the system which covers different parameters and typologies of transactions.

Lari Exchange has designed systematic procedures for its employees to report internally suspicious cases of money laundering or terrorist financing directly to the Compliance Officer who then thoroughly investigate them. If there are reasonable grounds for suspicion the Compliance Officer reports such cases to the FIU through Online Portal (GoAML) provided by the CBUAE.

We have established comprehensive AML/CFT compliance training for all employees including Partner & Senior Management. The AML/CFT compliance training are provided to all new joiners within thirty 30 days from the date of joining. Refresher training is provided to all employees annually.

The purpose of an Independent Review is to monitor the adequacy of the Lari Exchange AML-CFT Compliance Program. The review determines whether the business is operating in compliance with the requirements of the Central Bank of the UAE as well as the International Standards.

Independent external auditors evaluate the effectiveness of our AML-CFT Compliance Program annually in addition to the periodical internal audit.