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Compliance Policy

Last Updated: 1st September 2024

Sen & Ray LLC-FZ is committed to maintaining the highest standards of compliance with applicable laws and regulations related to anti-money laundering (AML) and sanctions. As a Designated Non-Financial Business and Profession (DNFBP) operating in the UAE, we are resolute in our compliance with the requirements of the UAE Executive Office for Control and Non-Proliferation, the United Nations Security Council (UNSC), the U.S. Office of Foreign Assets Control (OFAC), the European Union Council, and the UK Sanctions List under the Sanctions and Anti-Money Laundering Act 2018.

This policy outlines the governance framework, risk assessment processes, monitoring and reporting mechanisms, and training protocols that underpin our compliance program.

Governance Framework and Management Oversight

  1. Accountability:
    • The Board of Directors assumes ultimate responsibility for ensuring compliance with AML and sanctions regulations.
    • A designated Compliance Officer (CO) & Money Laundering Reporting Officer (MLRO) is appointed to oversee the day-to-day implementation of this policy.
  2. Resourcing:
    • Adequate resources, including personnel and technology, will be allocated to ensure effective monitoring, surveillance, and compliance management.
    • The CO & MLRO will report directly to senior management and provide periodic updates on compliance matters.
  3. Policies and Procedures:
    • Internal policies and procedures will be reviewed and updated annually to ensure alignment with evolving regulatory requirements.

AML and Sanctions Compliance Risk Assessment Framework

  1. Risk Identification:
    • Risks related to money laundering, terrorist financing, and sanctions breaches will be identified through comprehensive client due diligence (CDD) processes.
    • Special attention will be given to Politically Exposed Persons (PEPs), clients with high-risk profiles, and transactions involving high-risk jurisdictions.
  2. Risk Evaluation and Mitigation:
    • Risk assessments will be conducted for all clients, incorporating factors such as geographic location, industry sector, and transaction complexity.
    • Enhanced due diligence (EDD) will be performed for high-risk clients and transactions.
  3. Ongoing Review:
    • Risk profiles will be reviewed periodically and adjusted based on changes in client activity or external factors.

Monitoring and Surveillance

  1. Transaction Monitoring:
    • All transactions will be monitored for unusual or suspicious patterns. Automated systems will be employed to detect and flag potential risks.
  2. Sanctions Screening:
    • Clients and transactions will be screened against applicable sanctions lists, including the UAE Executive Office, UNSC, OFAC, EU, and UK lists.
    • No transactions or business relationships will be undertaken with individuals or entities appearing on these lists.
  3. Suspicious Activity Reporting (SAR):
    • All suspicious activities will be reported to the UAE Ministry of Economy within the prescribed timeframe.

Training and Awareness

  1. Employee Training:
    • All employees will receive mandatory AML and sanctions compliance training upon onboarding and annually thereafter.
    • Training will cover client due diligence, identifying PEPs, recognizing suspicious activities, and reporting obligations.
  2. Awareness Campaigns:
    • Periodic awareness initiatives will be conducted to reinforce the importance of compliance.

Reporting Requirements

  1. Regulatory Reporting:
    • Any suspicious activity or breach of sanctions regulations will be promptly reported to the Ministry of Economy.
    • An annual compliance report will be submitted as required by applicable regulations.
  2. Internal Reporting:
    • Employees must report any suspicious activities or compliance breaches to the CO immediately.

Policy Review and Updates

This policy will be reviewed annually or as required by changes in regulatory requirements. All updates will be approved by senior management and communicated to employees.

Contact Information

For questions about this Compliance Policy, please contact us at compliance@senandray.ae