AL ZAROONI EXCHANGE AML POLICY

PURPOSE OF TRAINING – MANUAL The purpose of this manual is to assist all employees in the detection of potential money laundering or other suspicious activities, and in  compliance with applicable laws and regulations of United Arab Emirates (Federal Law No.-(4) of 2002 regarding Criminalization of Money Laundering). This Manual describes certain forms that you may need to file including: Money-transfer for Moneychangers -  outgoing transfers of and above AED 2,000 (or equivalent in other currencies). Receipt of Transfer in Cash – incoming transfers (for amounts of AED 40,000 thousand (or equivalent in other currencies). Suspicious Transaction Report (STR), which is used to report suspicious financial transactions or those indicating possible Money Laundering

What is Money Laundering? refers to any transaction aimed at concealing and/ or changing the identity of illegally obtained money so that it appears to have originated from legitimate sources, where infact it has not”. Some of the illegal activity money is derived from includes: Terrorism, piracy and kidnapping Drugs Illicit dealing in fire-arms and ammunition Bribery, embezzlement, and damage to public property Fraud, breach of trust and related offences Offences committed in violation of the environmental laws Any other related offences referred to in international conventions to which the State is a party

What is Money Laundering? United Arab Emirates has a number of laws and regulations designed to prevent money laundering, including the Federal Law No.-(4) of 2002 regarding Criminalization of Money Laundering. These laws apply to Al Zarooni Exchange, its Board Members and employees. Failure to comply with these laws, and the regulations that implement them, may result in criminal prosecution. As a reference, a copy of the Money Laundering Laws and Circulars is inserted in the last pages of the manual. The following pages outline your responsibilities in the identification and reporting of potential money laundering activity.  In addition, this manual contains blank copies of the various forms that you may be required to fill out and certain files that you may need to keep. It is important that all forms and records be properly and accurately completed. It is also important to maintain any required files in a well- organized manner.  You should know where to find the file, and the file should contain all relevant documents

ACCEPTABLE FORMS OF IDENTIFICATION “Know Your Customer” - (KYC) For most transactions, you will be required to verify the identity of the customer.  You are required to examine original official picture identification for this purpose.  The following is a list of acceptable forms of identification:  Valid Passport Emirates ID Driving License (UAE) Military ID is the only ID which is not acceptable as per the Central Bank of UAE

Obtaining Proper ID Data & MAINTAINING RECORDS You are required to record the following information on the customer (individual, business or organization): Full Name as it appears on Identification document. Address, P.O. BOX Identification type, number, issue date & issue place. Transaction type Transaction date Name or initials of the employee who handling the transaction Additional information required on the sale of a draft/travelers cheques: Serial Number(s) of travel checks. Total Number of cheques purchased in the transaction Amount of each purchase A copy of the draft/travelers cheques Additional information required if transaction is a wire transfer: Amount of the transfer Reference number for the transfer The transfer instructions given by the customer A signed copy of the outward remittance form

Obtaining Proper ID Data & MAINTAINING RECORDS Please be certain to write down the type of identification, the issuing authority (including the country) and the relevant identification numbers, date & place of issue for each customer/transaction. With respect to all transactions that are discussed in this manual, if the transaction is being undertaken by one person, on behalf of another, you will need to obtain identification information from both individuals. If a person is making a transaction on behalf of an organization or company, you must obtain a copy of the trade license issued by the relevant authority and verify the name and address of the organization or company. It is Al Zarooni Exchange’s policy to do business only with companies and organization that are known to it, or are well- known nationally or internationally.  If you are in doubt about an organization or company, please contact the Compliance Officer.

TRANSACTIONS AND THE LAW The law requires us to follow certain procedures and guidelines regarding financial transactions: Complete the required forms regarding certain transactions and file in a separate place for possible future request by the Central Bank or authorities. Monitor and report any unusual or suspicious transactions of any size taking place where we have reasons to believe the money is derived from or is for illegal activities. Retain records of transactions for at least five years  good record keeping practice

TRANSACTIONS OF INTEREST The particular financial transactions outlined below are of great importance to us and the Central Bank. When a customer approaches you with a transaction involving a certain amount of funds, you are by law required to follow certain procedures and guidelines. The steps you are required to take are also discussed here. You must follow these steps.

Money Exchange Transaction AED 40,000 and above (or equivalent in other currencies) Exchange of Small Currency Denomination notes by larger ones   The law requires that you: Obtain as much identification from the customer as possible and file properly. Fill out the “Exchange of Small Currency Denomination Notes by Large Ones” form completely and accurately

Outward Remittance Outward Remittance If the transaction is AED 2,000 and above (or equivalent in other currencies)   The law requires that you: obtain proper identification and make copies and keep full records of all transactions (with copies of identification provided) Fill out the “Money Transfer for Moneychangers” form. Obtain customer signature. Maintain a complete record  of transaction. Inward Remittance Transaction If the transaction is AED 40,000 and above (or equivalent in other currencies) Fill out the “Receipt of Transfer in Cash” form completely and accurately. Maintain a complete record  of transaction separately

Funds Deposited into our Bank Account You may accept transfer funds that are directly deposited into our bank account under the following conditions:   The law requires that you: Verify proper ID documents through FAX or other acceptable means. Verify through bank deposit slips, etc

Foreign Politically Exposed Person (FPEP) A foreign politically exposed person is defined as senior official in the executive, legislative, administrative, military or judicial branches of a foreign government, immediate family members and close associates of such members. Branch should obtain written approval from senior management before doing transactions for Foreign Politically Exposed Persons (FPEP s)

Suspicious transactions The law requires that you report any suspicious activity or transactions involving your customers.  A transaction is suspicious and should be reported if: You have reason to suspect that the transfer involves funds derived from illegal activity, is intended to fund illegal activity, or is intended to  disguise the source or destination of the funds for illegal reasons The transaction is structured to avoid reporting requirements The transaction has no business or other apparent lawful purpose You are required to report any suspicious transaction (or group of suspicious transactions). In the event that you suspect a transaction, the law requires that you: Obtain proper identification and make copies Fill out the “Suspicious Transaction Report” completely and accurately. Submit it to management so they can forward it to the authorities. Maintain a complete file of transaction. You may not tell your customer that you are filing a suspicious activity report for his or her transaction.

Suspicious transactions You are not permitted to “close your eyes” to information that is suspicious.  All Suspicious Transaction Reports should be sent to this address: The Manager-in-charge Anti-Money Laundering and Suspicious Cases Unit Abu Dhabi Tel: 02 - 666 9437 Abu Dhabi Fax: 02 - 666 9427 Dubai and other Emirates Tel: 8002233, Fax: 8002223 You are required to maintain a file with a copy of your suspicious activity report and the underlying information and documents concerning the transaction for five years. 

Detecting Suspicious Transactions Suspicious” is not easy to define.  You should use your common sense concerning when a transaction is suspicious to you, taking into account your knowledge of the customer and your observations of the transaction.   Knowing your customers – their businesses, their reasons for sending funds, their relationships to the persons who are receiving the funds – is your best protection and will enable you to identify transactions that are suspicious.  In addition, it is ALWAYS a suspicious activity for someone to ask you to structure a transaction to avoid reporting requirements.  If you are asked to structure a transaction, or if the customer attempts to structure a transaction without asking you, you should fill out a suspicious activity report.  you should always pay special attention to : a customer frequently sending or receiving money a customer reluctant to provide information required. a customer inconsistent in the information provided. a customer nervous and impatient when  transacting. a customer with bundles of new notes.  

Detecting Suspicious Transactions You should not tell your customer that you are filing a suspicious activity report for his or her transaction.  you are not permitted to “close your eyes” to information that is suspicious.   STRUCTURING A TRANSACTION - ILLEGAL CONDUCT “Structuring” occurs when a customer divides his or her money into several smaller transactions in order to avoid the reporting requirement. It is a crime for a person to “structure” transactions in order to avoid a reporting requirement. It is also a crime for you or any of our employees to advise a customer that he or she should structure his or her transactions in order to avoid a reporting requirement, or to agree to do so. It is crime for the customer to offer to pay you to structure a transaction. 

Transactions not to be completed The following transactions should not completed in the event that the customer: Refuses to provide the required information or identification. Provides suspicious documents for identification. Attempts to pay in what appears to be counterfeit bills.   You must keep the records for at least 5 years, and you must permit law enforcement to review them upon request.

Prohibited Beneficiaries There is a  published list of persons and certain foreign governments and foreign banks that you should not process a transaction for. These persons are called “specially designated nationals and blocked persons.”  they are listed on the US treasury department’s website  and the Central Bank directs us to use it. The website is: http://www.ustreas.gov/offices/eotffc/ofac/sdn/index.html  The list is updated regularly, and you should become familiar with it.   we recommend that you print or download an updated copy of the list every week.  it is illegal to attempt to transfer money to anyone listed on the list.  it is your responsibility to maintain an updated list of these persons and to check each transaction against the list to make certain that the recipient is not a prohibited person.  you will have received a current copy of the list as part of your training.  if, in the future, you are unable to locate updated copy of the list, you should contact the compliance officer for assistance.

EMPLOYEE TRAINING Al Zarooni Exchange is responsible for training its employees in detecting and reporting money laundering conduct or any other suspicious activities.  Employees should read, and have continuing access to, this Manual.  Each employee is required to sign a certification that he or she has read this manual and has attended a training session on complying with money laundering laws. A copy of this manual is to be kept in the office.  You will be receiving updated information if and when legal requirements change or if new information becomes available.  The management will explain these updates to you and make certain that you receive the copies of relevant material. Al Zarooni will provide regular training to you, both as to new requirements and to refresh your understanding of existing requirements.  In addition, AlZarooni Exchange will conduct regular check-ups on your compliance with money laundering law. Al Zarooni is required to appoint someone as the Anti-Money Laundering Compliance Officer. Please contact the compliance officer if you have any questions answered or clarified.  

The best policy is to: Know Your Customer Know Your Transactions Know Your Procedures Know Your Documents           Know Your Responsibility Know Your Money knowing and properly identifying the customers – “KYC” policy Acceptable identifications documents. copying of identification documentation. keeping records – proper filing system. completing certain forms when required. screening certain kind of transactions - suspicious Keeping logs of certain transactions – trigger amounts Illegal transactions Reporting to Central Bank. Answering inquiries from the UAE authorities and Central Bank. Penalties for not following procedures. Good record keeping policies - 5 years minimum    United Arab Emirates has a number of laws and regulations designed to prevent money laundering, including the Federal Law No.-(4) of 2002 regarding Criminalization of Money Laundering.   These laws apply to Al ZarooniExchange and its employees. Failure to comply with these laws, and the regulations that implement them, may result in criminal prosecution.

This training manual is written for Al Zarooni Exchange. AL ZAROONI EXCHANGE  ANTI-MONEY LAUNDERING COMPLIANCE AND TRAINING MANUAL This training manual is written for Al Zarooni Exchange. Licensed to conduct: Purchase and sale of foreign currencies in the form of banknotes, coins    and travelers checks. Handling of remittance business. It will be revised periodically to reflect any changes to the laws governing compliance with Anti-Money Laundering laws and Circulars put forth by the UAE authorities and the Central Bank.