Anti-Money Laundering Policy

1. Policy Statement

AMANA CORPORATE is committed to the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. We maintain a comprehensive AML program designed to detect, prevent, and report money laundering and terrorist financing activities in accordance with UAE Federal Law No. 20 of 2018 and related regulations.

2. Regulatory Framework

Our AML program complies with:

• UAE Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism
• UAE Central Bank AML/CFT guidelines and circulars
• Financial Action Task Force (FATF) recommendations
• UAE Cabinet Resolution No. 10 of 2019 on AML/CFT Executive Regulation
• UN Security Council resolutions on sanctions

3. Customer Due Diligence (CDD)

Standard CDD Measures:

• Customer identification and verification using reliable, independent sources
• Verification of beneficial ownership for corporate customers
• Understanding the purpose and intended nature of business relationships
• Ongoing monitoring of business relationships and transactions

Enhanced Due Diligence (EDD):

Applied to high-risk customers including:

• Politically Exposed Persons (PEPs) and their associates
• Customers from high-risk jurisdictions
• Complex corporate structures
• High-value transactions or relationships
• Customers engaged in high-risk business activities

4. Prohibited Activities

We strictly prohibit and will report any activities that may involve:

• Money laundering or terrorist financing
• Sanctions evasion or violations
• Fraudulent activities or misrepresentation
• Structuring transactions to avoid reporting requirements
• Use of accounts for illicit purposes
• Dealings with sanctioned individuals or entities

5. Transaction Monitoring

Our monitoring program includes:

• Real-time screening against sanctions lists
• Automated transaction monitoring systems
• Manual review of flagged transactions
• Pattern analysis and behavioral monitoring
• Regular review of customer risk profiles

6. Suspicious Activity Reporting

We maintain procedures for identifying and reporting suspicious transactions to the UAE Financial Intelligence Unit (FIU) within the prescribed timeframes.

Suspicious Activity Indicators:

• Unusual transaction patterns or amounts
• Transactions inconsistent with customer profile
• Reluctance to provide required documentation
• Requests for unusual payment methods
• Connections to high-risk jurisdictions
• Media reports or adverse information

7. Record Keeping

We maintain comprehensive records including:

• Customer identification documents and due diligence records
• Transaction records and supporting documentation
• AML training records and certifications
• Suspicious transaction reports and related correspondence
• Risk assessments and monitoring reports

Records are retained for a minimum of five years or as required by UAE regulations.

8. Training and Awareness

All staff receive regular AML training covering:

• UAE AML/CFT laws and regulations
• Company AML policies and procedures
• Recognition of suspicious activities
• Reporting procedures and obligations
• Sanctions compliance requirements

9. Independent Testing and Audit

Our AML program is subject to:

• Annual independent compliance testing
• Regular internal audits and reviews
• Regulatory examinations by UAE authorities
• Continuous monitoring and improvement