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AML Policies

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

Company Policy

Malik Exchange is regulated by the Central Bank of the UAE (CBUAE) and is fully committed to complying with all applicable laws and regulations regarding Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT).

We adhere to the following local and international AML/CFT laws, standards, and best practices:

Local Laws and Regulations

  1. Federal Law No. (4) of 2002 regarding criminalization of Money Laundering.
  2. Federal Law No. (1) of 2004 on Combating Terrorism Offenses.
  3. Federal Law No. (9) of 2014, amending provisions of Federal Law No. (4) of 2002 on AML and CFT.
  4. Federal Law No. (7) of 2014 on Combating Terrorism Offenses.
  5. Federal Decree-Law No. (20) of 2018 on AML, CFT, and Financing of Illegal Organizations.
  6. The Standards for the Regulations Regarding Licensing and Monitoring of Exchange Business.

International Standards and Best Practices

  1. Financial Action Task Force (FATF) Recommendations.
  2. Middle East & North Africa Financial Action Task Force (MENAFATF).
  3. Bank Secrecy Act (USA).
  4. USA Patriot Act.
  5. Office of Foreign Assets Control (OFAC) – US Department of the Treasury.
  6. United Nations Security Council (UNSC).
  7. HM Treasury – United Kingdom.

Policy Declaration

At Malik Exchange, we are dedicated to operating our business with integrity, adhering to the law, and implementing robust security measures. We have implemented comprehensive AML & CFT policies and procedures, advanced sanction screening, and AML monitoring systems to detect, prevent, and report risks associated with Money Laundering and Terrorism Financing.

To enhance our compliance capabilities, Malik Exchange utilizes:

  • World-Check for sanction and Politically Exposed Persons (PEP) screening.
  • Kharon for sanctions-related risk intelligence and due diligence.
  • A dedicated AML solution integrated with our in-house system for real-time sanctions screening and transaction monitoring.

Our policies ensure the highest standards of Know Your Customer (KYC) principles, and we continuously update our systems to comply with regulatory frameworks and guidelines.

Mission of the Compliance Department

“Compliance is a journey, not a destination.”
The Compliance Department’s mission is to implement and sustain the most effective compliance program across the organization.

Appointment of Compliance Officer

The Board of Directors at Malik Exchange has appointed a Senior CAMS-Certified Compliance Officer to oversee the AML/CFT framework, as approved by the Central Bank of the UAE. Additionally, an Alternate Compliance Officer and a team of experienced compliance professionals support the department’s operations.

The Designated Compliance Officer reports directly to the Board of Directors and acts as the primary liaison with the Central Bank of the UAE and UAE law enforcement authorities.

Know Your Customer (KYC) Policy

Malik Exchange’s KYC policy ensures thorough customer identification. All identity documents are verified, retained as necessary, and their validity is checked prior to acceptance.

Customer Due Diligence (CDD)

CDD involves collecting relevant details about customers to ensure transactions align with their profiles and business activities. This includes verifying the source of funds and ensuring transactions are legitimate.

Enhanced Due Diligence (EDD)

For higher-risk customers, EDD measures are applied to gather additional information and ensure the legitimacy of their transactions and funds.

Risk-Based Approach (RBA)

Malik Exchange adopts a Risk-Based Approach, aligning with FATF standards. This ensures resources are prioritized to address higher-risk areas in the business, such as high-risk geographies, customer types, and services.

Staff Training

Malik Exchange provides comprehensive AML & CFT training programs to all employees, senior management, and the Board of Directors. Training covers:

  • Overview of Money Laundering and Terrorism Financing.
  • Typologies, trends, and Central Bank of UAE requirements.
  • KYC, EDD, and Risk-Based Approach.
  • Suspicious transaction detection and reporting.
  • Legal obligations of employees.

Training is conducted during onboarding and updated regularly.

Suspicious Transaction Reporting (STR)

Staff are required to report suspicious transactions to the Compliance Department via the Branch Compliance Officer or Branch Manager. This must be done without compromising customer or company reputation.

Record-Keeping

Malik Exchange maintains transaction records for a minimum of five years from the transaction date. Records are readily available to the Central Bank of the UAE or other regulatory bodies upon request, ensuring confidentiality and compliance.