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OROZAIN BULLION AND JEWELLRY TRADING L.L.C Gold is committed to adhering to and strictly upholding all legal obligations regarding anti-money laundering, including those mandated by the UAE and other competent international bodies. We abide by the regulations established by international institutions like the FATF, UN, EU, Organization of American States' Office of Foreign Assets Control (OFAC), and local regulatory bodies such as the Central Bank of the UAE. These organisations collectively define and enforce standards for anti-money laundering and counter-terrorist financing policies and programmes.

The regulatory agency responsible for mandating the establishment of AML regulations in the UAE is the Central Bank of the UAE, or more specifically, the Anti-Money Laundering and Suspicious Cases Unit (AMLSCU) of the Central Bank. Since 2001, the UAE Government (UAEG) has taken actions to enhance cash flow monitoring through the UAE financial system and to support global efforts to prevent financing terrorism.

Law No. 1/2004, the counterterrorism law, and Law No. 4/2002, the anti-money-laundering law, serve as the pillars for the UAE's counterterrorism financing (CTF) and anti-money-laundering (AML) initiatives. Although the Anti-Money Laundering Law makes money laundering a felony, Administrative Regulation No. 24/2000 specifies the guidelines financial institutions must follow while monitoring the activity of money laundering.

OROZAIN BULLION AND JEWELLRY TRADING L.L.C Gold AML POLICY

To stop money laundering (ML) and terrorism-related operations, OROZAIN BULLION AND JEWELLRY TRADING L.L.C Gold is firmly committed to upholding all national and international laws and regulations. In order to support the battle against money laundering and the financing of terrorism, we have implemented the required procedural and control procedures. We are also dedicated to routinely reviewing and updating our anti-money laundering policies and controls.

ACCOUNT OPENING AND CUSTOMER IDENTIFICATION

A proper protocol is in place for creating new supplier or customer accounts. No transaction is considered if the new customer or supplier is not onboarded in accordance with the established procedures. Before opening any new account, the "Know Your Customer" and "Customer Due Diligence processes and criteria" are diligently maintained. Before approving the documents presented by the parties, the compliance department reviews them. The compliance department's permission is necessary to open an account. However, micro customers can make cash payments for small investment bars without having to open an account.

ESTABLISHMENT OF ULTIMATE OWNERSHIP

The ultimate beneficial ownership of corporate entities and other legal entities with which we conduct business is determined by obtaining and verifying copies of trade licences, documents instituting the company, licences for exporting and importing goods, passport copies, and any other documents deemed necessary for this purpose.

ENHANCED DUE DILIGENCE

When a transaction seems to have the potential to be suspicious, enhanced due diligence is undertaken. In such circumstances, concerned personnel makes sure to obtain additional identification documents or documentation proof.

INTERNAL REPORTING SYSTEM

As part of the internal reporting process for OROZAIN BULLION AND JEWELLRY TRADING L.L.C Gold, suspicious transaction incidents are reported concurrently to the compliance department. Before reporting such transactions to the AMLSCU at the UAE Central Bank, the Compliance department will first undergo a comprehensive investigation and take the necessary measures.

STAFF TRAINING AND RECRUITING

The HR department performs screening and seeks references from prior employers or institutions before each employee's appointment. Each employee is provided with a fundamental understanding of AML regulations and corporate policies upon appointment. All employees must follow the specified AML guidelines in this regard, and they are trained to do so. Within the organisation, there is also the opportunity for ongoing and concurrent training.

RECORD KEEPING

All records, including transaction data, client identity documents and relevant information, and any other linked documents, are retained for at least four years.

RESPONSIBLE GOLD POLICY STATEMENT OUR STATEMENT

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the supplement on Gold are strictly adhered to by OROZAIN BULLION AND JEWELLRY TRADING L.L.C Gold. We work cooperatively with all multilateral organizations to combat any interactions with governmental or non-governmental institutions that use forced labour, child labour, sexual violence, bribery, or any other elements that misrepresent the origin of minerals, taxes, fees, or royalties paid to the government for the processing of minerals.

We commit to maintaining industry best practices and follow the utmost moral and ethical principles at all times. We also adhere to our AML policy, which is in accordance with regulatory national and international standards.

IMPLEMENTATION OF THE POLICY STATEMENT

Robust and effective KYC process. At all levels, there should be a clear authority and responsibility delegation. System for evaluating risks and continuous transaction monitoring Keeping accurate, thorough records, and retaining them for at least four years. Ongoing staff training

ESCALATION SYSTEM

Anyone working for the business or in the supply chain is given access to a self-contained escalation system through which they may alert management to any discrepancies. Money laundering, dubious transactions that might be connected to terrorism financing, and dubious gold sourcing are a few examples of these irregularities. Such violations are escalated to regulatory authorities if necessary.

MEMBER OF DUBAI GOLD & JEWELLERY GROUP