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SEND EXCHANGE EST.
Profile for SEND Exchange Est.
SEND EXCHANGE EST.
Head Office
Address: Liwa Street, Hamdan Centre
Near Al Ahlia Hospital, Abu Dhabi, UAE
Tel: 02-6277272
Email: [email protected]
Web: www.ersalexchange.com
ANTI-MONEY LAUNDERING (AML)
POLICY & PROCEDURES
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Table of Contents
SECTION A- POLICY STATEMENT ....................................................................................... 3
SECTION B- PROCEDURES .................................................................................................... 3
1. Know Your Customer ........................................................................................................... 3 2. Registration ........................................................................................................................... 4 3. Identification of the Customer ............................................................................................. 4 4. Bank Account ........................................................................................................................ 6 5. Large Value Transactions .................................................................................................... 6 6. Watch List .............................................................................................................................. 7 7. Reporting of Suspicious Transactions ................................................................................. 8 8. Monitoring and Control ....................................................................................................... 8 9. Record Keeping ................................................................................................................... 10 10. New Staff Recruiting Procedures ...................................................................................... 10 11. Training & Record .............................................................................................................. 10 12. Correspondent Relationship .............................................................................................. 11 13. Agency Relationship ........................................................................................................... 11 14. Privacy Policy ...................................................................................................................... 11
SECTION C- GUIDELINES FOR IDENTIFYING SUSPICIOUS CUSTOMERS ................... 11
SEND EXCHANGE EST.
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Anti-Money Laundering
Policies, Procedures and
Controls
Based on Regulation Concerning Procedures for
Anti-Money Laundering Circular No. 24/2000
Dated 14.11.2000, its Amendment dated
13.06.2006 & Addendum vide Notice
No.2922/2008 dated 17.06.2008 Of The Central
Bank of UAE
SECTION A- POLICY STATEMENT
The combat against Money Laundering is a priority for SEND Exchange. We recognize that the
combat against Money Laundering is a challenge, which has to be continuously addressed by
relentless team effort.
In line with Central Bank of UAE’s revised Regulation, we at SEND Exchange support the major
international organizations, which collectively set and enforce standards for Anti-Money Laundering
policies and programs such as Financial Action Task Force (FATF) established by countries of the
group of seven (G7), UN, The EU, The Organization of American States - The Office of Foreign
Assets Control (OFAC) and the Local Regulatory Authority. These organizations are increasingly
insistent that compliance be assessed in terms of implementation and not simply concurrence with the
policies standards or guidelines established.
Our cooperation to our regulators is in its entirety, wherein we aim to maintain the highest operating
standards to safeguard the interest of our customers, our staff and the communities where we operate.
In conducting business with due skill, care and diligence, SEND Exchange seeks always to comply
with both the letter and spirit of relevant laws, rules, regulation, codes and standards of good practice.
We aim to promptly address any irregularities that may arise, as we believe in transparency in our
financial and regulatory reporting with prompt disclosure of any breaches.
SECTION B- PROCEDURES
The Following is a List of Procedures, which should strictly be followed:
1. Know Your Customer
1.1 SEND Exchange will deal with customers with acceptable IDs. (Emirates ID,
Labour Card, Passport, Trade License) Customer Registration/card creation in our
Symex system is mandatory for all transactions of AED 2,000/- and above (equivalent
in other currencies). No transaction shall be undertaken before completion of the
registration process.
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1.2 The History of Transactions done by the customers can be accessed at any point of
time.
1.3 The customer’s name should be recorded exactly as detailed on the original
identification document.
2. Registration
2.1 Individual Customer shall fill in Form No.1 request slip for Wire Transfer/FC purchase
and sale with Original ID and the staff should attach a copy of ID as proof of identity.
2.2 Modifications, additions and deletions to Form No.2 shall be done through a separate
form
3. Identification of the Customer
3.1 While conducting a transaction the staff shall identify the customer with any one of the
valid ID mentioned in (1.1)
a) the date of birth and legal name by taking a copy of current valid official
original identification document (e.g. Passport, Labour Card, Driving License,
Emirates ID)
b) the permanent residential address by taking a copy of recent utility bill, bank
statement or similar statement from another licensee or financial institution, or
some form of official correspondence or official documentation card, such as
CPR, from a public / governmental authority, or a tenancy agreement or record
of home visit by an official from the Exchange.
c) Where appropriate, direct contact with the customer by phone, letter or email to
confirm relevant information like residential address.
3.2 If a customer gives his passport as ID, the staff shall also note down the visa details of
the customer.
3.3 The Staff should sight the above document in original and should stamp “True Copy of
the Original” on the photocopy with the initial of the concerned staff.
3.4 Inspection of all documents should be carefully done. The photo, name, signature,
expiry date, etc., given in all the documents and papers should be carefully tallied.
3.5 Every time the staff should sight the original identity of the customer and counter check
the same with the information available in the customer database.
3.6 The staff should not be satisfied with vague information about the identity of the
customer for whom they carry out the transaction, but should attempt to determine the
beneficial owner(s) of the transaction. In case the customer is acting on the behalf of a
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third party, an undertaking to that effect must be obtained from him prior to conducting
any transactions. (Form No.3)
3.7 If the customer is on transit / visit visa, extra caution should be taken and should only
be approved by the Branch Compliance Officer / Manager. Apart from a valid ID and
Visa copy, customer has to declare the details like Purpose of Transaction and Source of
Fund.
3.8 Individual bring Cash from other country above AED 100,000/-(or equivalent in other
currency) please take copy of Customs Cash Declaration made at Airport.
3.9 Tourists should show proof of temporary residence in U.A.E (e.g Hotel key or
Confirmation) where required. For transactions above AED 40,000/- proof of permanent
Residential address is required. If the tourist cannot show such proof, then refuse the
Transaction.
3.10 Before accepting a “POLITICALLY EXPOSED PERSON” (PEP) as a customer,
prior approval of the Senior Management must be taken. When an existing customer is
PEP or subsequently becomes PEP, it must be immediately brought to the notice of the
Senior Management.
3.11 While dealing with corporate entities, the following details should be obtained,
recorded and attached with Form:
a) Entity Name
b) Legal Form
c) Full Registered address
d) Type of business activity
e) Trade License details
f) Names of Directors/Partners/Proprietor
g) Names of authorized signatories of cheques (if other than the above.
h) Name of the representative
The details given must be verified by obtaining copies of the following documents which
shall be attached with the form.
Trade License / certificate of incorporation and / or C.R. or trust deed
Identities of the Directors/Partners/Proprietor
Identities Identification documentation of the authorized signatories, if
any (other than the above).
Letter of representation authorizing the representative to act on behalf of
the company
Identity of the representative
Memorandum & Articles of Association
Partnership agreement
3.12 The customer, the concerned staff and the cashier are required to sign (Full Signature)
the application to execute any transaction. “No Signature No Transaction”.
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3.13 All payments and transfers performed on behalf of CHARITIES registered in UAE
must be brought to the notice of the Compliance Officer who will in turn report the
matter to Central Bank of the UAE’s AML Compliance Unit. Payments will always be
made by a cheque drawn on a bank licensed in UAE, to Charities without calling for any
certificate.
3.14 Mode of receipt is recorded in all the transfers for above AED 40,000/- (Cash, Foreign
Currency, Bank Cheque) and wire transfers for USD 1000/- and above.
3.15 Obtain updated copies of the identification documents at least every 2 years.
4. Bank Account
4.1 Our Correspondent Bank account numbers and details should not be disclosed to
anyone without the written confirmation of the Chief Compliance Officer.
4.2 Unauthorized inward wire transfers directly from the customers shall not be accepted.
Any unauthorized credit to our account shall be returned back to the originator’s bank
after deduction of charges.
5. Large Value Transactions
5.1 Apart from a valid ID, customer has to declare the details like Purpose of Remittance
and Source of Fund.
5.2 Exchange of Foreign Currency for above AED 40,000- shall be done by collecting
copy of the customer identity and other details like address, nationality, purpose of
transaction and source of fund.
5.3 While dealing in wholesale foreign currency market, SEND Exchange shall deal only
with financial institutions regulated by their respective Central banks / monetary
authorities.
5.4 Copies of their trade license / C.R. & Central Bank license shall be collected from the
financial institutions.
5.5 All Remittance transactions of AED 40,000/- and above conducted across the counter
shall be approved by the Compliance Officer/ Branch Manager.
5.6 While dealing in wholesale foreign currency market, SEND Exchange shall deal only
with financial institutions regulated by their respective Central banks / monetary
authorities.
5.7 Copies of their trade license / C.R. and Central Bank license shall be collected from the
financial institutions.
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5.8 Large Remittances to NCCT Countries (Refer Exhibit – (B)) shall be handled with extra
caution.
6. Watch List
6.1 The Manager/Compliance Officer will continually obtain information of Black Listed
Entities and Individuals from the Central Bank of U.A.E
6.2 Names of the Black Listed Entities / Individuals and Charitable / Religious
Organizations are available at the teller stations and with the Manager.
6.3 The Compliance Department shall furnish available details to the Central Bank of U.A.E
or any other regulatory authority against any request for information within a reasonable
period of time.
6.4 The exchange house, its directors, officers and employees shall not under any
circumstances disclose or warn (tipping off) their customers, the beneficial owner or
other subjects of STR when information relating to them is reported to the Enforcement
Unit / Regulatory Authority.
6.5 The FATF (Financial Action Task Force) recommends that we should give special
attention to business relations and transactions with persons including companies and
financial institutions from the Non Cooperative Countries and Territories (NCCT)
6.6 High Risk Countries
For the countries below, it shall be forbidden to accept and transactions with the
destination or origin being from the countries listed below. In case of commercial
transactions, any transaction in direct or indirect support of any commercial trade
with these countries shall be rejected and the customer shall be blacklisted by
addition to the internal watch list.
Iran
Democratic People’s Republic of Korea (DPRK)North Korea
Algeria
Ecuador
Myanmar
Syria
Sudan
AML and Compliance approval for all transactions related directly or indirectly to the countries
listed below. Enhanced due diligence shall be mandatory and all supporting documents along
with the clear purpose of payment shall be obtained
Albania
Belarus
Bosnia and Herzegovina
British Virgin Island (BVI)
Burma (Myanmar)
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Congo
Cote D’lvoire (Ivory Coast)
Cuba
Eritrea
Iraq
Kosovo
Lebanon
Liberia (former Regime of Charles Taylor)
Libya
Macedonia
Montenegro
North Korea
Serbia
Somalia
Yemen
Zimbabwe
7. Reporting of Suspicious Transactions
7.1 It is the duty of all staff / officers to report suspicious and unusual transactions to the
Compliance Officer/Manager.
7.2 When an employee suspects a transaction to be suspicious, he/she should report his
suspicions to their Compliance Officer/Manager, who will investigate and if found
suspicious, will report the case in STR to the Central Bank of UAE.
7.3 The Exchange shall maintain records for five years relating to Suspicious Transaction
Reports made to or by the Compliance Officer and records of consideration of those
reports and of any action taken as a consequence.
7.4 Failure to report suspicious and unusual transaction to the Compliance shall attract
legal and disciplinary action.
7.5 The Compliance Officer shall investigate and forward the “STR” (Suspicious
Transaction Report) to relevant authorities.
8. Monitoring and Control
8.1 The Compliance Officer shall be appointed by the Management. The Compliance
Officer shall report to the General Manager on all matters relating to compliance. The
responsibilities of the Compliance Officer are:
a) Monitoring the execution and implementation of the AML / CFT regulations issued
by the Central Bank of UAE and our internal policies and procedures throughout the
organization.
b) Prepare internal Suspicious Transaction Reports (STR) and investigate and report
to the regulatory authority, if required.
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c) To take reasonable steps to establish and maintain adequate arrangements for awareness
and training of employees.
d) Coordinate with the local regulatory authorities in money laundering issues.
e) Respond promptly to any reasonable request for information made by the Enforcement
Unit or regulatory authority.
f) Record keeping as required by our policy.
g) Reporting any suspicious transaction directly to the branch Manager.
h) Monitoring continuously on an on-going basis transactions of PEP and high risk customer
accounts if any.
i) For transactions above AED 40,000/-, verify the source, background and the purpose and
document the findings. In case of one-off transaction where there is no ongoing account
relationship, a STR must be filed. He shall take instructions from the branch Manager and
shall report to him on all matters regarding compliance.
8.2 The Exchange’s directors, officers and employees must not warn or inform their
customers when information relating to them are being reported to / investigated by the
relevant authorities.
External Auditor shall audit annually the adequacy and the compliance of the policies, procedures and control and shall report to the Management and the Central Bank of the UAE.
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9. Record Keeping
9.1 The objective of record keeping is to ensure that we are able to provide the basic
information about customer and to reconstruct the individual transactions undertaken at
the request of the relevant authorities at any given time.
9.2 Transaction records, STR and staff training records should be kept for a minimum
period of five years, unlimited for all cases under police, Courts, Central Bank or any
other investigations and made available to the relevant authorities as and when
demanded.
9.3 The documents may be retained in original or stored on microfilm or in the computer
as electronic media.
10. New Staff Recruiting Procedures
The Human Resource Department will scrutinize all new employees by checking their
references. Perform background checks on all (past and present) SEND Exchange Employees.
All future and current employees will sign a Form consenting for the company to investigate
into the background of the employees if needed.
11. Training & Record
11.1 Training program for all SEND Exchange staff shall be conducted regularly. The
training shall include the following:
a) Responsibility of the employees under Central Bank of the UAE regulations for obtaining
sufficient evidence of identity (KYC), recognizing and reporting knowledge or suspicion
of money laundering.
b) Duties and responsibilities of the Compliance Officer.
c) Procedure for reporting of suspicious transactions.
d) Potential effect on the company, on its employees and customers if there is any breach of
law or regulation.
e) Ways to identify suspicious transactions.
f) Storing records.
11.2 The Head Office is also required to maintain records showing the dates when Anti-
Money Laundering training was given, the nature of the training and the names of the
staff who received the training.
11.3 Relevant new employees will be given AML / CFT training within 3 months of
joining the organization.
11.4 A meeting of staff members will be held once or alternate month to discuss training
methods, procedures and policies as well as current key issues.
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12. Correspondent Relationship
The Company should gather sufficient information about the correspondent banks’ with whom
they are going into relationship. The Company should pay attention to the quality of supervision
by the relevant supervisory authorities when establishing correspondent relationships with foreign
banks. Particular attention should be paid when entering into or continue a correspondent banking
relationship with a bank incorporated in a jurisdiction in which it has no physical presence or
located in jurisdictions that have been identified by FATF as being “non-co-operative”. The
Company should establish that the banks have due diligence standards and employ due diligence
procedures with respect to transactions carried out through the accounts. The Company will not
enter into Correspondent relationship with shell banks.
13. Agency Relationship
When entering into an agency relationship, the Company should ensure that the agent is properly
regulated and is subject to Anti-Money Laundering laws and regulations of his regulatory
authority. An undertaking to the effect that it is abiding by the AML / CFT regulations and
procedures of its regulatory authority should be obtained.
Particular attention should be paid when entering into or renewing an agency relationship
with an agent located in jurisdictions that have been identified by FATF as being “non co-
operative”.
14. Privacy Policy
SEND Exchange is committed to respecting and protecting the information furnished by its
Customers having great regard to maintaining their privacy. The information collected is meant
strictly for completion of transactions and shall not be shared with any internal or external
agencies except as may be required or solicited by the regulatory authorities.
SECTION C- GUIDELINES FOR IDENTIFYING SUSPICIOUS CUSTOMERS
“Suspicious activity” is a difficult concept to define because it can vary from one transaction
to another based upon on all the circumstances surrounding the transaction. For example,
transaction by one customer may be normal because of the knowledge of that customer, while similar transactions by another customer may be suspicious. Many factors are involved in determining
whether transactions are suspicious, including the amount, the location of the business, comments
made by the customer, the customer’s behaviour, etc. Customers like those mentioned below may warrant attention. Just because a customer appears on the
list does not mean that he/she is involved in illegal activity. It only means that the transaction of the
customer requires closer scrutiny.
- Customers sending or receiving frequent amounts that are much greater than what would
be expected for the customer.
- Customers avoiding thresholds.
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- Customers transferring money repeatedly in order to make each transaction unnoticed;
but the total of the transfers together form a large amount.
- Customers trying to change large quantities of small value currency into large value
currency.
- Repeated exchange of cash from one currency to another while the nature of the
customer’s activity does not require such transfers.
- Customers conducting suspicious transactions may appear nervous, rushed or defensive to
questioning about his remittance.
- Customers who may be reluctant to show ID.
- Customers concealing the beneficial owner of funds.
- Two customers coming together but sending money transfer separately to the same
beneficiary or coming together for receiving money transfer from the same remitter.
- Large number of individuals transferring money to the same beneficiary without
appropriate reasons or explanations.
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Form No. 1
(Ref. Clause 2.1 of AML Policy & Procedures)
SEND Exchange
Details Entry Form
(For Individual Customer Only)
Date:
Customer's Details:
Customer's Name:
Nationality: Date of Birth :
House /P. O. Box No.: Street: Emirates:
Mobile Tel. No.: Office Tel. No.: Res. Tel. No.
ID Type: ID No.: ID Issued By:
ID Issued At: ID Issue Date: ID Expiry Date:
Beneficiary's Account No. 1 (Bank):
Account Name: Account No.:
Bank Name: Branch Name :
Bank Address ………………………………………….…… Pin Code:
Drawn on Bank Name: Drawn on Branch Name:
Beneficiary's Account No. 2 (Residence):
Receiver’s Name: Door No.: Street Name:
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Place Name: District Name: State Name:
Country Name: Pin Code: Zip Code:
Residence Tel. No.: Mobile Tel. No.:
I hereby undertake to intimate the Company if there are any changes in my above details provided.
Customer’s Signature
Staff’s Signature Branch Manager’s Signature
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Form No. 2
(Ref. Clause 2.2 of AML Policy & Procedures)
SEND Exchange
Details Correction Request Form
(For Updating / addition / deletion of Form No. 1 & 2)
From
Customer Name: …………………………………..
Address and Tel ……………………….
Place ……………………………………
To:
The Manager
SEND Exchange
Branch Name ……………..
Dear Sir,
Kindly correct the following Customer’s Details in the system:
1. ………………………………………………………..
2. ………………………………………………………..
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3. ………………………………………………………..
4. ………………………………………………………...
5. …………………………………………………………
Kindly amend / add / delete the following Customer’s Account Details in the system:
Customer's Account No. ………….
Account Name: Account No.:
Bank Name: Branch Name:
Bank Address:………………………………………………………………………………
……………………………………………………… Pin Code:
Drawn Bank Name: Drawn Branch Name: Currency:
Customer’s Signature Staff’s Signature Branch Manager’s Signature
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Form No. 3
(Ref. Clause 3.6 of AML Policy & Procedures)
Letter of Representation
(For Individual Customer Only)
From
Name Mr. / Ms. …………………………………………….
Employer Name ……………………………………………………….
P. O. Box No. & Place ……………………………………………………….
Contact Telephone Numbers ……………………………………………………….
To
The Manager,
SEND Exchange
Branch …….…………………….
Dear Sir,
Reg.: Undertaking for Inward / Outward Remittance Transactions
I hereby authorize Mr. / Ms. …………………………………., bearer of this letter, holding Passport /
Labor Card / Driving License No. …………………………, to send / receive money on behalf of me
and sign the necessary transaction vouchers. His / her original identity will also be produced by him /
her along with the copy of my passport / ID.
I, hereby confirm that this transaction is for …………………………………. purpose only.
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The bearer of this letter will sign as: ………………………………
Thanking you,
Yours faithfully,
Signature: ……………………….
Name: ………………………………………
Date: ………………………….
Enclosed:
Copy of the Remitter’s ID. b) Copy of the Representative’s ID
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Form No. 3
(Ref. Clause 3.6 of AML Policy & Procedures)
Letter of Representation
(For Corporate Customer Only)
From
Company Name M/S. …………………………………………….
P. O. Box No. & Place …………………………………………………..
Telephone and Fax Numbers …………………………………………………..
To
The Manager,
SEND Exchange,
Branch………………………..
Dear Sir,
Reg.: Undertaking for Business Transactions
We hereby authorise Mr. / Ms. …………………………………., bearer of this letter, holding
Passport / Labour Card / Driving License No. …………………………, to send / receive / exchange
money on behalf of our company and sign the necessary transaction vouchers. His / her original
identity will also be produced by him / her along with the copy of our Trade License and the copy of
my Passport.
We are engaged in the …………….…………………………… business and we hereby confirm that
the amount sending / receiving / exchanging through your company are for our normal business
purposes only.
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Any change in the status of our above representative, if any, will be intimated to you in writing
immediately.
The bearer of this letter will sign as: …………………………………
Thanking you,
Yours truly,
For M/S. …….………………………………………………..
Signature: ………………………………
Name & Designation: ………………………………………………...…
Date: …………………………..
Enclosed: 1. Copy of the Trade License Company Stamp
2. Copy of the Partner / Manager’s ID
3. Copy of the Representative’s ID