Anti-Money Laundering (AML) & Counter Financing of Terrorism (CFT) Policy

Effective Date: 6 June 2025
Company: AKV GOLD AND JEWELLERS L.L.C
License No.: 1329332 | Register No.: 526788
Address: S1-28 PROPERTY INVESTMENT OFFICE 4, Dubai Investment Park First, DUBAI, 111485
Email: office@akvgold.com | Phone: +971 503 956 811

1. Policy Statement

AKV GOLD AND JEWELLERS L.L.C (“the Company”) is committed to conducting business in full compliance with all applicable Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) laws and regulations in the United Arab Emirates and internationally. We maintain a zero-tolerance approach to money laundering, terrorism financing, fraud, or any illegal activity.

2. Objectives

Detect and prevent transactions involving proceeds of crime
Identify and mitigate the risk of terrorism financing
Ensure regulatory compliance under UAE Central Bank, DED, and FATF standards
Protect the integrity of financial systems and our client relationships
Maintain robust internal controls and due diligence

3. Regulatory Framework

This Policy complies with:

Federal Decree Law No. (20) of 2018 on AML and CFT
Cabinet Decision No. (10) of 2019 regarding implementing AML law
Guidelines issued by the UAE Central Bank and Executive Office for AML/CFT
FATF Recommendations
Any other applicable international standards or UAE legislation

4. Customer Due Diligence (CDD)

We conduct thorough Customer Due Diligence (CDD) before entering any business relationship:

Full identity verification (passport, Emirates ID, trade license)
UBO (Ultimate Beneficial Owner) declaration and documentation
Risk-based profiling (low, medium, high)
Source of funds and wealth confirmation
Sanctions screening (UN, UAE, OFAC, EU, etc.)

5. Enhanced Due Diligence (EDD)

For high-risk customers or transactions, we apply Enhanced Due Diligence, including:

Politically Exposed Person (PEP) checks
Additional verification of source of wealth
Approval by senior management
Closer transaction monitoring

6. Monitoring and Reporting

All transactions are reviewed for unusual, suspicious, or high-volume activity
Red flags are escalated to our Compliance Officer
Suspicious Transaction Reports (STRs) are filed with the UAE FIU (Financial Intelligence Unit) when required
Daily and periodic reviews are conducted on gold, jewellery, and high-value trade operations

7. Record-Keeping

The Company keeps detailed records for a minimum of five (5) years, including:

KYC and identity documents
Transaction logs
STR filings and internal investigation records
Correspondence and risk assessments

8. Sanctions Compliance

We do not engage in transactions or business with:

Sanctioned countries or individuals
Entities on blacklists from UAE, OFAC, EU, UN, HM Treasury, or any recognized regulatory body
We screen all clients and counterparties against updated sanctions lists.

9. Training and Awareness

AML/CFT training is mandatory for all employees annually
The Compliance Officer oversees periodic refreshers, testing, and reporting
Training includes case studies, red flags, internal procedures, and reporting lines

10. Internal Controls and Governance

Appointment of a qualified Compliance Officer
Periodic AML audits and compliance reviews
Whistleblower protection for internal reports
Escalation procedures for suspicious activity

11. Responsibilities

Senior Management: Overall oversight and accountability
Compliance Officer: Day-to-day implementation and liaison with regulators
All Employees: Must comply with AML/CFT procedures, report concerns, and complete training

12. Violations and Disciplinary Action

Non-compliance with this policy may result in:

Immediate suspension of transactions or client relationships
Internal disciplinary action
Regulatory reporting and potential legal consequences

13. Review and Updates

This policy is reviewed annually or upon changes in law or risk exposure. Updates are approved by management and communicated to all relevant staff.

14. Contact – Compliance Officer

For questions or to report suspicious activity:
Compliance Department
AKV GOLD AND JEWELLERS L.L.C
Email: office@akvgold.com
Phone: +971 503 956 811