The Lari Exchange
Management always gives high importance to AML /CFT and Regulatory Compliance
from the inception of the business.
The Lari Exchange’s
AML-CFT Compliance Program is designed to fulfill the requirements stipulated
by the Central Bank of the UAE, applicable international laws and
standards. These laws / standards include
but not limited to Federal Decree Law No. (20) of 2018, Cabinet Decision No
(10) of 2019, Cabinet Resolution No. 74 of 2020 and FATF recommendations on
Anti Money Laundering & combating terrorist financing etc.
Lari Exchange has
designed and implemented an effective as well as comprehensive compliance
policy and procedures based on CBUAE and international standards. The policy
covers all product and services of our exchange, and it is approved by the
partners/owners of the company.
The Policy and
procedures being reviewed and updated annually at minimum or there are any
changes in local and international laws or standards.
A designated Compliance
Officer has been appointed by Lari Exchange who has been given the specific
responsibility of managing its AML/CFT compliance program.
In accordance with
the international and regulatory standards for financial institutions, we are
committed to design an effective RBA policy to identify, assess and mitigate
the AML/CFT Risk involved for the operations of our exchange company.
We have designed a
robust risk assessment methods and process to identify the Risk involved with
the business relationship. Based on the
various risk factors involved, we classify our customers under different
category such as High Risk, Medium Risk and Low Risk.
Lari Exchange has
identified and assessed the money laundering and financing of terrorism (ML/FT)
risks associated with its business on a regular basis using following
perimeters:
a.
Customer Risk
b.
Counterparty Risk.
c.
Product Risk.
d.
Jurisdictional / Country Risk
e. Delivery Channel Risk.
The Know Your
Customer (KYC) principle in line with Central Bank of the UAE and international
standards constitutes the basis of the AML/CFT framework and is the key to
effective protection of financial institutions against financial crime. Lari
Exchange ensured that the funds involved in their transactions are originating
from legitimate sources and used for legitimate purposes using carrying out
effective KYC process.
These processes are
followed:
a.
Customer Identification (CID)
Process;
b.
Customer Due Diligence (CDD)
Process; and
c. Enhanced Due Diligence (EDD) Process.
Lari exchange is very
keen to conduct sanctions & PEP screening process and escalation procedures
as required by regulators, correspondent banks and international organizations.
We have designed robust system for the screening of customers and Transactions
against Local & International Sanctions and Politically exposed Person
(PEP).
Sanction & PEP
screening is conducting real-time with the use of an exclusive Screening system
where the Refinitiv’s World-Check database has been incorporated that contains
all mandatory list including CBUAE, OFAC, UNSC, EU, HM Treasury, List of PEPs
etc., and other required lists.
We have implemented
effective transaction monitoring system to identify the unusual transactions
through our exchange house. We have implemented an independent system to
monitor all transactions through our exchange and incorporated various monitoring rules with
the system which covers different parameters and typologies of transactions.
Lari Exchange has
designed systematic procedures for its employees to report internally
suspicious cases of money laundering or terrorist financing directly to the
Compliance Officer who then thoroughly investigate them. If there are
reasonable grounds for suspicion the Compliance Officer reports such cases to
the FIU through Online Portal (GoAML) provided by the CBUAE.
We have established
comprehensive AML/CFT compliance training for all employees including Partner
& Senior Management. The AML/CFT compliance training are provided to all
new joiners within thirty 30 days from the date of joining. Refresher training
is provided to all employees annually.
The purpose of an Independent
Review is to monitor the adequacy of the Lari Exchange AML-CFT Compliance
Program. The review determines whether the business is operating in compliance
with the requirements of the Central Bank of the UAE as well as the International
Standards.
Independent external
auditors evaluate the effectiveness of our AML-CFT Compliance Program annually
in addition to the periodical internal audit.