Siri Global Business Consultants (hereinafter referred to as 'the Company') is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) compliance. This policy sets out the Company's obligations and procedures to prevent the use of its services for money laundering, terrorist financing, and other financial crimes, in accordance with UAE Federal Law No. 20 of 2019 on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT Law) and Cabinet Decision No. 10 of 2019.
As a Corporate Services Provider (CSP) and Designated Non-Financial Business and Profession (DNFBP), the Company is registered with the UAE Financial Intelligence Unit (FIU) goAML portal and complies with all directives issued by the Central Bank of the UAE and relevant supervisory authorities
This policy applies to:
The Company operates in compliance with the following key legislations and guidelines:
| Term | Definition |
|---|---|
| Money Laundering (ML) | The process of making proceeds of crime appear legitimate through placement, layering, and integration |
| Terrorist Financing (TF) | Providing or collecting funds with the intent or knowledge that they will be used to carry out terrorist acts |
| Customer Due Diligence (CDD) | The process of verifying the identity of clients and assessing the risks they present. |
| Beneficial Owner (BO) | Any natural person who ultimately owns or controls a client entity, typically with 25% or more ownership interest. |
| Politically Exposed Person (PEP) | An individual who holds or has held a prominent public function, presenting higher ML/TF risks. |
| Suspicious Transaction Report (STR) | A report filed with the UAE FIU goAML when a transaction is suspected of being related to ML/TF. |
| Designated NonFinancial Business (DNFBP) | A category under FATF that includes corporate service providers, accountants, lawyers, and real estate agents. |
The Company adopts a risk-based approach (RBA) to AML/CFT compliance. Clients and transactions are assessed based on the following risk factors:
The Company shall perform CDD on all clients prior to establishing a business relationship or conducting a transaction. CDD measures include:
EDD is applied to high-risk clients including PEPs, clients from high-risk jurisdictions, and complex structures. EDD includes:
SDD may be applied only where the risk of ML/TF is demonstrably low and where permitted by applicable law. The Company retains the right to apply standard CDD at any time.
The Company shall maintain all records related to client identification, transactions, and CDD for a minimum of five (5) years from the date of:
Records shall be maintained in a manner that allows them to be retrieved promptly upon request by competent authorities. All records shall be stored securely and protected from unauthorized access.
All employees are required to report any suspicion or reasonable grounds for suspicion of money laundering or terrorist financing to the Company's Compliance Officer immediately. The Compliance Officer shall:
Failure to report suspicions is a criminal offence under UAE AML law. The Company maintains a strict non-retaliation policy for good-faith reporters.
The Company conducts sanctions screening against UAE, UN, OFAC, and EU consolidated lists prior to onboarding any client and on an ongoing basis. Clients found to be designated sanctioned individuals or entities shall not be onboarded, and any existing relationship shall be immediately terminated and reported.
The Company is committed to ensuring all relevant employees receive adequate AML/CFT training. Training covers:
Training shall be conducted at onboarding and refreshed at least annually, with records maintained.
The Company has appointed a dedicated Compliance Officer responsible for:
Non-compliance with this policy and UAE AML laws may result in:
This AML Policy shall be reviewed and updated at least annually, or whenever there are significant changes in applicable legislation, business activities, or risk profile. The Board of Directors and senior management are responsible for approving any amendments to this policy.