AML Policy

Declaration

Index Exchange adheres to Federal Decree-Law No. 20 of 2018, Cabinet Decision No. 10 of 2019, and The Standard for Exchange Houses issued by the Central Bank of UAE (CBUAE), particularly Chapter 16, which outlines robust AML/CFT governance requirements. Our policies align with international frameworks like FATF Recommendations, ensuring comprehensive measures to mitigate money laundering (ML), terrorism financing (TF), and proliferation financing (PF) risks.

Anti-Money Laundering & Combatting Financing of Terrorism and Proliferation (AML CFT CPF) Policies and Procedures

Our AML CFT CPF policies are developed in accordance with Federal Decree-Law No. 20 of 2018, CBUAE Standards for Exchange Houses, and FATF Recommendations. These policies focus on detecting, mitigating, and reporting financial crimes. With a Risk-Based Approach (RBA), Index ensures dynamic customer due diligence (CDD), enhanced due diligence (EDD), transaction monitoring, and sanctions screening to protect financial integrity.

International Laws, Best Practices, and Industry Standards

We integrate FATF Recommendations, UN Security Council Resolutions, and guidance from MENAFATF into our compliance framework. Our adherence to The Standard for Exchange Houses (Chapter 16) ensures compliance with UAE’s regulatory framework and global best practices, including adopting rigorous AML/CFT measures and aligning with international financial crime prevention standards.

UAE National Risk Assessment

Index Exchange incorporates insights from the UAE National Risk Assessment (NRA), as mandated by CBUAE Standards for Exchange Houses, to address risks specific to ML, TF, and PF. This assessment informs our compliance strategy, enabling robust mitigation measures that align with FATF guidance and UAE Cabinet Decision No. 10 of 2019.

UAE Sectorial Risk Assessment

In alignment with Federal Decree-Law No. 20 of 2018 and The Standard for Exchange Houses (Chapter 16), our policies incorporate findings from the UAE Sectorial Risk Assessment (SRA). This approach identifies and addresses sector-specific risks, ensuring effective compliance tailored to the unique challenges of the exchange sector.

Mission of Compliance Department

Our Compliance Department is tasked with maintaining adherence to Federal Decree-Law No. 20 of 2018, CBUAE Standards for Exchange Houses, and FATF Recommendations. It aims to foster a culture of compliance, ensure regulatory adherence, and implement proactive measures to prevent the misuse of financial services for illegal activities.

Tone at the Top

Leadership at Index Exchange recognizes compliance as a strategic priority. Guided by CBUAE Standards for Exchange Houses (Chapter 16) and Cabinet Decision No. 10 of 2019, senior management emphasizes integrity and accountability in all operations, establishing a compliance culture that aligns with regulatory and ethical standards.

Appointment of Compliance Officer

Our Compliance Officer is appointed in accordance with CBUAE Standards for Exchange Houses and Chapter 16, ensuring full independence and authority. This role includes overseeing AML/CFT frameworks, reporting suspicious transactions to the Financial Intelligence Unit (FIU), and ensuring adherence to regulatory obligations.

Correspondent Banks & Money Transfer Operators (MTOs)

Index Exchange maintains relationships with Correspondent Banks and Money Transfer Operators (MTOs) in compliance with CBUAE Standards for Exchange Houses, FATF Recommendation 13, and UAE Federal Decree-Law No. 20 of 2018. These partnerships are subject to thorough due diligence, including risk assessments, monitoring of transactions, and alignment with international sanctions. Our policies ensure that these relationships adhere to global best practices, preventing misuse of financial services for ML or TF.

Compliance Function

Our Compliance Function operates independently, in alignment with The Standard for Exchange Houses (Chapter 16) and FATF Recommendations. It is tasked with managing compliance risks, monitoring adherence to policies, and ensuring the organization meets its obligations under UAE law and international standards.

Know Your Customer (KYC)

Our KYC policies are guided by CBUAE Standards for Exchange Houses, Federal Decree-Law No. 20 of 2018, and FATF Recommendations. These measures ensure accurate customer identification, verification of ultimate beneficial ownership (UBO), and monitoring of activities to prevent misuse of financial services.

Customer Due Diligence (CDD)

In compliance with Federal Decree-Law No. 20 of 2018 and CBUAE Standards for Exchange Houses, CDD measures validate customer identities, ensuring legitimacy of transactions. Continuous monitoring identifies and mitigates risks, safeguarding against ML, TF, and PF.

Enhanced Due Diligence (EDD)

EDD is applied to high-risk customers as per The Standard for Exchange Houses (Chapter 16) and UAE regulations. It includes additional verification, stricter scrutiny of source-of-funds documentation, and ongoing monitoring to mitigate heightened ML/TF risks.

Sanction Screening

Our sanctions screening complies with CBUAE Notice 103/2020 and FATF Recommendation 7. Systems ensure comprehensive checks against UN, OFAC, EU, and UAE sanctions lists, preventing breaches and ensuring compliance with global standards.

Transaction Monitoring

In accordance with The Standard for Exchange Houses (Chapter 16), transaction monitoring systems detect and flag unusual patterns. This proactive approach aligns with FATF Recommendation 10, ensuring timely reporting of suspicious activities to the FIU.

Suspicious Transactions Reporting

Suspicious Transaction Reports (STRs) are filed under Federal Decree-Law No. 20 of 2018 and CBUAE Standards for Exchange Houses. Our reporting framework ensures compliance with FIU requirements and supports the global fight against financial crime.

Risk-Based Approach

Our Risk-Based Approach (RBA), as outlined in The Standard for Exchange Houses (Chapter 16) and FATF guidelines, ensures proportional resource allocation based on risk levels. This methodology enhances operational efficiency while mitigating ML/TF risks.

Gap Analysis, Trend, and Typology Assessments

Regular gap analyses and typology reviews, as required by CBUAE Standards for Exchange Houses, identify vulnerabilities and emerging threats. These assessments, aligned with FATF recommendations, enable dynamic improvements to our compliance framework.

Whistleblowing

Our whistleblowing mechanism, compliant with Federal Law No. 2 of 2015, encourages employees to report compliance concerns anonymously. Reports are investigated confidentially, ensuring accountability without fear of retaliation.

Confidentiality

Index Exchange complies with Federal Decree-Law No. 20 of 2018 and FATF Recommendations to protect the confidentiality of customer data. Robust safeguards prevent unauthorized disclosures and ensure data integrity.

Staff Training

Comprehensive staff training programs, mandated by The Standard for Exchange Houses (Chapter 16) and FATF guidelines, equip employees with the knowledge and tools to fulfil AML/CFT obligations. Training covers regulatory updates, emerging risks, and compliance responsibilities.

Record-Keeping

Record-keeping practices comply with Federal Decree-Law No. 20 of 2018 and CBUAE Standards for Exchange Houses, ensuring accurate retention of customer and transaction data for at least five years to facilitate audits and investigations.

Independent Review of the Compliance & AML Department

Regular independent reviews, as required by The Standard for Exchange Houses (Chapter 16), assess the effectiveness of AML/CFT frameworks. These audits ensure alignment with UAE regulations and FATF standards, enabling continuous improvement in compliance measures.