Anti Money Laundering Policy (AMLP)

PLANTA PAYMENT SERVICES PROVIDER L.L.C

  • Business License Number: 1119653
  • Legal Address: Bur Dubai, Umm Hurair 2, Dubai, United Arab Emirates

Introduction

This document outlines the Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Customer Due Diligence (CDD) policies of PLANTA Payment Services Provider L.L.C. The rules are aligned with:

  1. Central Bank of the UAE Regulations: 24/2000 and subsequent amendments.
  2. FATF Recommendations: The 40 Recommendations.
  3. Federal Decree-Law No. (20) of 2018: On Anti-Money Laundering and Combating Terrorism Financing.
  4. Cabinet Decision No. (10) of 2019: Concerning the implementation of Decree-Law No. (20).

These rules apply to all employees whose roles involve establishing business relationships, executing transactions, or their monitoring. Updates to this document are made regularly to reflect regulatory changes.

Objectives of the AML/CFT Policy

The primary objective is to ensure the Company's products and services are not used for money laundering or terrorist financing. Specific goals include:

  • Ensuring compliance with applicable laws and regulatory guidelines.
  • Promoting vigilance among employees in detecting and reporting suspicious activities.
  • Providing a robust framework for identifying, assessing, and mitigating financial crime risks.

Money Laundering

Definition

Money laundering involves processing illicit funds to make them appear legitimate. This process disguises the true source of the money, enabling its integration into the legal economy.

Stages of Money Laundering

  1. Placement: Introducing illegal funds into the financial system.
    • Methods: Smurfing, alternative remittances, electronic transfers, asset conversion, bulk movement, securities dealing.
  2. Layering: Obscuring the origin of funds through multiple transactions.
    • Techniques: Offshore banks, shell corporations, trusts, intermediaries.
  3. Integration: Incorporating laundered funds into the legal economy.
    • Examples: Asset sales, business recycling, import/export transactions, corporate financing.

Terrorist Financing

Terrorist financing involves providing financial support to individuals or groups engaging in terrorism. Like money laundering, it uses sophisticated methods to disguise the source and destination of funds.

Regulatory Compliance and Oversight

PLANTA Payment Services Provider L.L.C complies with:

  • Central Bank of the UAE Regulations 24/2000 and updates.
  • UAE and DMCC laws.

Key Compliance Risks

  1. Reputational Risk: Loss of trust from customers and stakeholders.
  2. Operational Risk: Inefficient processes or systems exposing the Company to illegal activities.
  3. Legal Risk: Fines, penalties, or operational bans due to non-compliance.
  4. Financial Risk: Potential losses from fraudulent or unverified transactions.

Customer Due Diligence (CDD)

CDD involves identifying the customer, understanding the nature of their business, and ensuring compliance with regulatory requirements.

When to Apply CDD

  • Establishing a business relationship.
  • Transactions exceeding AED 55,000 (single or linked).
  • Wire transfers exceeding AED 3,500.
  • When suspicious activities are detected.
  • At periodic intervals, based on risk assessment.

Risk-Based Approach

Additional due diligence measures are applied based on:

  • Client Risk: Politically exposed persons (PEPs), complex ownership structures, etc.
  • Product/Service Risk: Services prone to anonymity or high-value transactions.
  • Geographical Risk: High-risk countries or jurisdictions with weak AML frameworks.

Enhanced Due Diligence (EDD)

EDD is applied in high-risk scenarios, such as:

  • Unusual transaction patterns.
  • Use of nominee shareholders or bearer shares.
  • Customers from high-risk jurisdictions.

EDD Measures

  • Obtain additional verification documents (e.g., utility bills, bank statements).
  • Conduct periodic reviews every 30–90 days.
  • Monitor transactions closely for anomalies.

Transaction Monitoring

Transactions are monitored to identify suspicious activities, including:

  • Payments involving PEPs or sanctioned entities.
  • High-value or multiple-currency transactions.
  • Payments from or to high-risk jurisdictions.

Record-Keeping

Records are maintained for a minimum of five years, including:

  • Customer identification documents.
  • Transaction details.
  • Internal and external suspicious activity reports.

Reporting

The Compliance Officer is responsible for:

  • Investigating and reporting suspicious activities to the Financial Intelligence Unit (FIU).
  • Using the goAML system for STR filings.
  • Submitting copies of STRs to DMCC where required.

Role of the AML Compliance Officer

The Compliance Officer ensures adherence to AML/CFT regulations by:

  • Collecting and analyzing information related to suspicious transactions.
  • Reporting to the FIU.
  • Conducting employee training on AML/CFT policies.

Outsourcing

The Company may engage third parties for specific AML-related activities, such as Enhanced Due Diligence. However, responsibility for compliance remains with PLANTA Payment Services Provider L.L.C.

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