This Anti-Money Laundering (AML) Policy provides a comprehensive framework for Universal Exchange Center to comply with all applicable AML and Counter-Terrorist Financing (CTF) laws, regulations, and guidelines in the UAE. This includes those issued by the Central Bank of the UAE (CBUAE) and relevant international standards. This policy prevents the use of Universal Exchange Center’s services for money laundering, terrorist financing, and other illicit activities, safeguarding the integrity of the financial system.

Money Laundering: The process of disguising the source of illegally obtained money to make it appear legitimate. Includes placement, layering, and integration stages.
Terrorist Financing: Providing financial support, in any form, to terrorists or terrorist organizations, regardless of the legality of the source.
Suspicious Activity: Transactions, behaviors, or patterns that raise suspicion of money laundering or terrorist financing, including unusual transaction sizes or high-risk jurisdictions.
Customer Due Diligence (CDD): Processes to verify customer identities and assess risk profiles through KYC procedures.
Enhanced Due Diligence (EDD): Additional scrutiny applied to high-risk customers, transactions, or situations.

Universal Exchange Center is committed to preventing money laundering and terrorist financing in accordance with the Central Bank of the United Arab Emirates’ regulations and international best practices in Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF). To this end, we are fully equipped to detect suspicious activities associated with money laundering, fraud, terrorist financing, and the financing of illicit organizations, and report them to the Central Bank of the UAE, as per the regulations. At Universal Exchange Center, we are dedicated to conducting business securely, with integrity, and in compliance with all applicable laws and regulations.

We have implemented robust AML and compliance practices across all our branches, supported by a state-of-the-art information technology infrastructure and advanced AML solutions that enable us to maintain full compliance at all times.

Universal Exchange Center is fully committed to adhering to the laws and regulations which reflect the relevant recommendations issued by the Financial Action Task Force (FATF) and the Basel Statement of Principles on preventing the utilization of the financial system for criminal purposes, issued by the Basel Committee.

Universal Exchange Center is also determined to continuously evaluate and uphold its AML policies, procedures, and controls through a robust internal and external audit program. Universal Exchange Center is firmly committed to complying with all applicable AML/CTF laws, regulations, and best practices. Key elements of our AML/CTF program are:

Customer Due Diligence (CDD): We implement robust CDD measures, including KYC procedures, to verify the identity of all customers, assess their risk profile, and understand the nature of their business. This includes implementing risk-based CDD measures (Simplified, Standard, and Enhanced).
Transaction Monitoring: We implement comprehensive transaction monitoring systems and procedures to detect suspicious activity, using both automated systems and manual reviews. These systems are regularly calibrated to maintain effectiveness.
Suspicious Activity Reporting (SAR): We promptly report any suspicious activity to the UAE Financial Intelligence Unit (FIU) according to regulatory requirements.
Record Keeping: We maintain accurate and complete records of all transactions and customer information for at least five years, or as otherwise required by law.
Training and Awareness: We provide regular and comprehensive AML/CTF training to all employees to ensure they are aware of their responsibilities and can identify and report suspicious activity.
Risk Assessment: We conduct regular AML/CTF risk assessments to identify and mitigate potential risks. This risk assessment considers the nature, scale, and complexity of Universal Exchange Center’s operations.
Independent Audit: We conduct independent audits of our AML/CTF program to ensure its effectiveness and compliance with regulations.

Universal Exchange Center employs rigorous AML procedures to prevent misuse of financial systems. These procedures are aligned with FATF recommendations and Basel principles.

Customer Due Diligence (CDD): Our CDD procedures include collecting and verifying customer information such as name, address, date of birth, and identification documents. We also screen customers against sanctions lists and Politically Exposed Persons (PEPs) lists. Enhanced Due Diligence (EDD) procedures are implemented for high-risk customers.
Transaction Monitoring: Our transaction monitoring systems use various methods to identify suspicious activity, including rule-based scenarios, statistical analysis, and anomaly detection. Staff also conducts manual reviews of flagged transactions.
Suspicious Activity Reporting (SAR): Any employee who identifies suspicious activity must immediately report it to the Compliance Officer. The Compliance Officer conducts an investigation and files a SAR with the FIU if appropriate.
Record Keeping: Records are stored securely and confidentially, both electronically and physically, according to regulatory requirements.
Training: Training is provided regularly and covers topics such as legal and regulatory requirements, money laundering and terrorist financing typologies, internal policies and procedures, and case studies. Universal Exchange Centers AML-CFT Training materials include:
Overview of Money Laundering and Combating Financing of Terrorism: This section provides a foundational understanding of money laundering and terrorist financing.
Overview of Money Laundering and Combating Financing of Terrorism: This section provides a foundational understanding of money laundering and terrorist financing.
Definition of Money Laundering, Terrorism Financing, and typologies as well as recent trends: This covers clear definitions of these illegal activities, explains common methods (typologies), and addresses emerging trends in financial crime.
AML / CFT Requirements of The Central Bank of UAE: This section specifically focuses on the legal and regulatory framework set forth by the Central Bank of the UAE.
Risk associated with the products and services offered by Universal Exchange Center: This training identifies specific risks related to Universal Exchange Center's particular services and products, enabling staff to better mitigate those risks.
KYC / KYCC policies, EDD and RBA:This covers Know Your Customer (KYC), Know Your Customers Customer (KYCC) policies, Enhanced Due Diligence (EDD) procedures, and Risk-Based Approach (RBA) methodologies.
How to identify suspicious activities and transactions: This provides practical guidance on recognizing red flags and indicators of potential money laundering or terrorist financing.
Record-keeping and reporting requirements: This section details the proper procedures for maintaining records and reporting suspicious activities to the appropriate authorities.
Familiarity with Anti-Money Laundering forms: This ensures staff are familiar with and can correctly complete all necessary AML-related forms.
Employees legal obligations and responsibilities: This clearly outlines the legal duties and responsibilities of each employee in relation to AML-CFT compliance.
Anti-Money Laundering and Combating Financing of Terrorism training is an integral part of Universal Exchange Center's compliance program. This mandatory training is provided to all new hires and updated regularly for existing staff to reflect changes in AML/CFT Policies & Procedures.

Universal Exchange Center has a dedicated Compliance Officer who is responsible for:

Overseeing the implementation and effectiveness of the AML/CTF program.
Developing and updating AML/CTF policies and procedures.
Providing AML/CTF training to employees.
Liaising with the CBUAE and the FIU.
Conducting internal audits and investigations.

Universal Exchange Center is dedicated to upholding the highest standards of AML/CTF compliance. We believe this comprehensive policy is crucial in preventing our services from being used for illicit purposes and contributing to a safer and more secure financial environment.

Money laundering and terrorist financing pose significant threats to society and the stability of the international financial system. Combating these threats demands a coordinated and cooperative global effort. Vigilance and collaboration are essential to effectively address these challenges.

Financial institutions worldwide increasingly recognize the critical importance of implementing and maintaining robust controls and procedures to ensure they know their customers on a reasonable and practical basis. The consequences of insufficient vigilance in this area can be severe. Facilitating a financial transaction while willfully or recklessly disregarding the source of a customer’s funds or the nature of their transaction can result in criminal and/or civil liability for both the employee and Universal Exchange Center.

Money laundering and terrorist financing pose a substantial risk to the global economy, leading to a rapidly increasing demand for regulatory compliance. Managing reputational and legal risks is a top priority within the financial industry. Money laundering not only harms the public but also damages the reputation of the financial services sector. It is therefore in the best interest of the financial industry to take all possible steps to prevent money laundering. Consequently, Universal Exchange Center recognizes the need for collaboration and cooperation in combating the challenges posed by this social evil.