1. Purpose and Scope
VAULT IST DMCC (registration DMCC198149) is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This policy outlines the principles and procedures we follow to detect, prevent, and report suspected money laundering and terrorist financing activities across all of our operations and client-facing services.
2. Regulatory Framework
Our AML program is designed to comply with the applicable laws and regulations of the United Arab Emirates, including Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, as well as the regulations and guidance issued by the DMCC Authority. We also adhere to the recommendations of the Financial Action Task Force (FATF).
3. Know Your Customer (KYC)
We perform customer due diligence (CDD) on all clients prior to establishing a business relationship. This includes verifying the identity of individuals and beneficial owners, understanding the nature and purpose of the business relationship, and assessing risk on an ongoing basis. Enhanced due diligence (EDD) is applied where higher risk factors are identified, including for politically exposed persons (PEPs) and clients from high-risk jurisdictions.
4. Transaction Monitoring
We maintain systems and controls to monitor transactions processed through our platform for unusual or suspicious activity. Transaction patterns are reviewed against established risk indicators, and any activity that cannot be reasonably explained is escalated for further investigation by our compliance team.
5. Suspicious Activity Reporting
Where we identify or suspect money laundering, terrorist financing, or other financial crime, we file Suspicious Activity Reports (SARs) with the UAE Financial Intelligence Unit (FIU) in accordance with applicable law. All employees are trained to recognize red flags and understand their obligation to report suspicious activity internally without tipping off the subject of the report.
6. Record Keeping and Training
We retain all CDD documentation, transaction records, and internal reports for a minimum of five years from the end of the business relationship or the date of the transaction, whichever is later. All staff with client-facing or compliance responsibilities receive regular AML/CTF training, and our policies are reviewed and updated at least annually to reflect changes in legislation and risk exposure.