Anti-Money Laundering and Counter-Terrorism Financing Policy

Article One

"Preamble"

............ Company is committed to combating money laundering and terrorist financing in accordance with the regulations and legislation issued by the competent authorities, and in alignment with the best international practices in combating money laundering and preventing terrorism financing. We are fully prepared to disclose any suspicious activities related to money laundering, including financial fraud and the financing of terrorist operations and illegal organizations, as well as to notify the relevant authorities in accordance with the applicable regulatory frameworks.


We continue to conduct our business in accordance with high levels of transparency, reliability, and integrity, within the framework of absolute compliance with all internationally applicable laws and regulations.


We have previously adopted the best practices of anti-money laundering in all our operations, supported by our advanced infrastructure and innovative solutions, which ensure our complete and continuous compliance with anti-money laundering policies.

AML Compliance Policy Declarations

The company is committed to the laws and regulations that reflect the relevant recommendations. The company ensures the continued detection of financial violations and supports anti-money laundering policies, procedures, and controls, and enhances the necessary and continuous monitoring through the implementation of internal and external audit programs. The company is committed to implementing anti-money laundering and counter-terrorism financing programs, which are as follows:

According to four main pillars:

In addition to verifying the identity of parties to ensure compliance with applicable sanctions against individuals and entities, through the implementation of an automated system for screening customer names against sanctions lists issued by the relevant authorities, as well as verifying all parties to transactions through the screening system to ensure compliance with sanctions.

Anti-Terrorism and Anti-Money Laundering Procedures

First // Monitoring Financial Transactions

The company ensures “continuous monitoring” of financial transactions to track unusual or potentially suspicious activities based on the customer's profile or behavior. Our agents form our first line of defense, and we ensure that they are empowered to report any unusual behaviors or transactions through our internal channels. This process is complemented by a comprehensive review of transactions by the second line of defense, and continuous monitoring of customer transactions and behavior is carried out.

Second // Reporting Unusual/Suspicious Financial Transactions

All members of our team are fully trained and equipped to report any unusual or suspicious transactions through the compliance officers using our advanced internal regulations. The officers conduct a comprehensive investigation and take all necessary measures before notifying the relevant authorities about the transaction. The company adopts advanced mechanisms to verify the customer's identity in accordance with the regulatory frameworks for combating money laundering and terrorist financing, locally and internationally, regardless of the amount involved in the transaction. The company also enforces strict policies regarding customer due diligence. New employees are trained on anti-money laundering and counter-terrorism financing policies and procedures shortly after joining the company, and the training is followed up annually.

Third // Maintaining Confidential Records and Documents

All records, documents, and information related to customers, in addition to financial transaction data and other related documents, are retained for no less than 5 years, in compliance with applicable laws and regulations. The company also maintains the confidentiality of the information provided by customers, including their transfer records.

Fourth // Independent Review of the Compliance and AML Department

The Compliance and Anti-Money Laundering Department is subject to independent reviews by the company’s competent authorities and by investigators from the competent bodies, ensuring that compliance programs are continuously updated and meet legislative requirements.