Customer Acceptance Policy

Introduction

The Customer Acceptance Policy (CAP) of AAEE is an important document in determining the basis on which AAEE enters into relationships with its customers. An inadequate CAP or the inadequate implementation of the CAP can expose AAEE to serious compliance, legal and reputational risks.

AAEE will accept only those customers whose identity is established by conducting due diligence appropriate to the risk profile of the customer. Collecting sufficient relevant information about the customer before the account relationship is established is the most effective defense against AAEE being used as the medium to launder the proceeds of crime or to finance terrorism.

1 - Objectives and application of the policy

The objectives of this Policy are as follows:

To establish explicit criteria for the acceptance of customers.
To establish procedures to verify the identity of individuals or corporations for opening an account.
To ensure that AAEE is in a proper position (i.e. by having taken measures and collected documentation) to understand the customer and its financial activities, so AAEE can manage its risks carefully; and
To reduce legal, reputational or AML risks faced by AAEE.

This Policy is applicable to all business units and front-office employees of AAEE and is to be read in conjunction with related operational guidelines which are issued from time to time.

Regardless of the limitations given in this Policy, AAEE fully respects and complies with the right of an individual customer to access basic products in line with consumer protection regulation and refuses any kind of discrimination related to this kind of service.

2 - Customers

For purposes of this Policy, a customer is defined as a person or entity who or which maintains an account or has a business relationship with AAEE.

2.1 Accepting new customer – individuals

When accepting new customers (this applies to the establishment of all business relationships AAEE concludes with its customers based on Chapter 16 of the Standards for the Regulations Regarding Licensing and Monitoring of Exchange Business), the responsible employees must act with the highest degree of care and caution in customer identification. This applies also to the process of collecting necessary data, relevant information, and obligatory documents.

AAEE reserves the right to copy the personal documents based on which the customer was identified. The copying and storage process shall be carried out in accordance with the provisions of the Anti-Money Laundering and Terrorist Financing guidance and the Personal Data Protection guidance.

When establishing a new business relationship with individuals, the customer needs to provide to AAEE following information:

Full legal name;
Residential status (whether UAE Resident or UAE Non-Resident);
Address in the UAE (for UAE Residents);
Temporary address in the UAE and the permanent address in the home country (for UAE Nonresidents);
Mobile number;
Email, if available;
Date of Birth;
Nationality;
Country of Birth;
ID type (whether Emirates ID or Passport or GCC national ID);
ID number;
ID place of issue;
ID issue date;
ID expiry date;
Profession; and
Expected annual activity (i.e. expected annual value and number of transactions for future transaction monitoring).

Customer identification is carried out at the time of its physical presence and by consulting

the official identity document. As an official document when establishing a business

relationship, AAEE considers:

a) Emirates ID; or
b) Passport with valid visa; or
c) GCC National ID for GCC nationals.

AAEE will copy the ID document, based on which it will carry out the identification. The copy will be archived in accordance with the legal requirements.

2.2 Accepting a new customer – Legal persons

AAEE requires the following documentation to open an account for a legal person:

(All the original documents shall be required for verification and shall be furnished to Al Amal Express Exchange for verification)

Customers are requested to fill up the KYC Questionnaire & Corporate Booklet.
Ownership structure of the legal person or legal arrangement and purpose and nature of the intended business relationship.
The legal person or legal arrangement’s legal form(Trade License) and collect a copy of the legal person or legal arrangement’s proof of existence (Ejari/Utility bill)
Copies of the powers that regulate and bind the legal person or legal arrangement (MOA/AOA/POA/Board Resolution)
Names of relevant persons holding senior management positions in the legal person.
Copies of valid permissions/licenses of the legal person or legal arrangement(Industrial License etc.)
Original IDs of Bos. Where the BO resides outside the UAE, original copies of IDs must be appropriately notarized or attested by relevant authorities in the respective foreign country and in the UAE;
The list of authorized signatories and their original IDs.
Authorization letter for representatives, original IDs of representatives and the relationship

In general, AAEE does not open accounts for legal persons not incorporated in UAE (including freezones) or which are not physically present or keep an operating business in UAE. There are no exceptions to this rule.

3 - Politically exposed persons

A politically exposed person is any natural person who is active, or has been active in the last year, in a prominent public position in UAE or another country, including his immediate family members and close associates.
Natural persons considered to be politically exposed are:

heads of State, heads of Government, ministers and their deputies or assistants, and state secretaries;
elected representatives of legislative bodies.
members of the governing bodies of political parties (president of political party,
irrespective of whether the political party is active on a national or local level, and
members of executive body of political party active on a national level);
judges of the supreme and constitutional courts and other high-level judicial bodies
against whose decisions, except in exceptional cases, regular or extraordinary legal
remedies cannot be brought;
the governor and vice governor of the central bank governing board,
ambassadors and heads of consulates (including honorary consular officer), head of
a diplomatic representation of an international organization in the UAE, as defined by the List of diplomatic representations, consulates, international organizations, and representations of international organizations in the UAE (diplomat list), high-ranking officer in the armed forces serving as Chief of the General Staff , deputy Chief of the General Staff of the Armed Forces, Force Commander of the Armed Forces
members of the management or supervisory bodies of companies in majority ownership of the state (over 50% indirect or direct holding by the state);
heads of bodies of international organizations headquartered in the UAE, heads of institutions, international organizations, and representations of international organizations in the UAE (diplomat list), and their deputies.

Immediate family members for the purpose of determining political exposure are spouse or partner, parents and children and their spouses or unmarried partners.

The person’s close associates for determining political exposures are all natural persons known to be joint beneficial owners or having any other close business relationship with a politically exposed person. A close associate is also a natural person who is the only beneficial owner of a business entity or similar legal entity under foreign law known to have been established for the benefit of politically exposed persons.

The opening of all accounts to Politically Exposed Persons requires the approval of the AML Officer and manger. In addition, an approval of the board will be required if a legal entity is owned by PEP. Such an account will be classified as High Risk in accordance with the Risk Assessment Analysis and Methodology of AAEE, for Anti-Money Laundering and Counter-Terrorist Financing and requires regular client activity monitoring.

4 - Due diligence procedures

AAEE shall not open an account or process a transaction until the valid personal or commercial identity of the individual or legal entity has been established and verified.

The responsible employee must apply relevant due diligence procedures for customers in the following cases:

Opening an account and/or establishing a business relationship with a new customer;
In cases where AAEE has suspicion in respect of accuracy or adequacy of the information obtained in relation to the customer’s identity or ultimate beneficial owner’s data,
when updating customer information.

AAEE shall not enter a business relationship or execute any transactions before applying due diligence procedures stipulated in this policy and AML policy.

AAEE shall only open an account once all the documents required to be submitted per the relevant category of customer has been duly submitted.

4.1 – Disclosure of ultimate beneficial owner

AAEE must investigate the ownership structure in such a way as to know who the ultimate owner of the legal entity is, up to the natural person, or who are those natural persons who may influence the operations of this legal entity, in accordance with the AML policy and internal procedures.

AAEE should obtain documents from independent and objective sources from which the ultimate beneficial ownership structure of the customer can be inferred. The documents shall be provided by the customer and shall not be older than 3 months at the beginning of the onboarding process.

5 - Updating customer information

AAEE should update the customer’s identification information periodically in line with the customer’s AML risk category. Customer due diligence is mandatory if more than a year has passed since the last review of the customer’s business activity and supporting documents (ultimate beneficial ownership structure and other).

All the requirements in chapter 16(of the Standards for the Regulations Regarding Licensing and Monitoring of Exchange Business) concerning updating the customers profile must be followed as mentioned in the AML policy.

6 - Termination of business relationship

AAEE will terminate an established business relationship with the customer if there is a risk of money laundering and terrorist financing or a risk of any other regulatory sanction in relation to the relationship.

AAEE will terminate an established business relationship with the customer if customer engages in any activity mentioned in section 7 of this policy and any activity that exceeds our risk apatite.

AAEEwill close the existing account or terminate any activity if the customer does not provide all the necessary data for AML/CFT.

AAEE may terminate an existing account with immediate effect in cases of breach of contract, breach of other general terms and conditions, as well as for reasons indicating that account activity does not comply with the intent and purpose the customer gave when entering the business relationship, or for reasons of non-compliance with Exchange House rules and regulations.

7 - Restricted activities

AAEE does not provide account opening, payment services or any other products to the following the customer groups:

7.1 Prohibition of business based on geographical criterion

AAEE does not establish business relationships or effect transactions with or for legal persons that are directly or indirectly associated with the countries of Yemen, North Korea, Cuba, Iran and the Crimea region.

Also, AAEE will not enter relationships with:

Customers resident in any country against which the UAE has issued prohibition notices.
Customers or counterparties who are resident in a non-cooperative country or territory.

7.2 Prohibition of business based on business activities of the customer

AAEE does not establish business relationships with entities which have registered as

one of the activities:

Unlicensed Money services businesses/Hawaladars (e.g. remittance dealers, money transfer agents),
virtual (crypto) currency platforms and individuals or companies offering the sale, purchase and distribution of virtual currencies,
Companies who issue bearer shares.
Any non-face to face customer.
A company that is not registered in the U.A.E. (NO customer Registration is allowed for Corporate that have been registered outside the UAE.)
Individuals or companies acting as payment aggregators, and
Shell/virtual banks or similar financial institutions.
Any other activity that exceeds our risk Apatite

7.3 Prohibition of business based on other indicators

AAEE does not enter business relationships with entities or individuals of unknown identity or using fictitious or unreal names, or if there is reasonable doubt that the identification documents are falsified.

AAEE will not establish a business relationship with an Exchange House or similar financial institution that:

offers anonymous products to its customers;
is a virtual/shell bank itself;
operates with virtual/shell banks;
does not carry out controls in terms of restrictive measures; and
does not implement AML/CFT and sanctions measures.
Any individual or entity whose name appears on a sanctions list or whose shareholders, beneficial owners, directors, or principal controllers appear on such lists.

AAEE will not open an account if the customer’s past activities had a negative financial or reputational impact on AAEE.