ANTI-MONEY LAUNDERING POLICY, PROCEDURE AND INTERNAL CONTROL RULES OFPLANTA PAYMENT SERVICES PROVIDER L.L.C
Business License number: 1119653
Legal address: Bur Dubai Umm Hurair 2, Dubai, United Arab Emirates

These Rules are based on:
- Central Bank of the UAE Regulations 24/2000, subsequent amendments, and changes.
- FATF 40 Recommendations
- Federal Decree-law No. (20) of 2018 ON ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM AND FINANCING OF ILLEGAL ORGANIZATIONS
- Cabinet Decision No. (10) of 2019 CONCERNING THE IMPLEMENTING REGULATION OF DECREE LAW NO. (20) OF 2018 ON ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM AND ILLEGAL ORGANIZATIONS
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The Rules are introduced to all employees of PLANTA PAYMENT SERVICES PROVIDER L.L.C whose duties include the establishment of business relationships or carrying out transactions and their monitoring. PLANTA PAYMENT SERVICES PROVIDER L.L.C shall regularly check whether the Rules are up-to-date and make necessary changes upon amendments to the regulations in force.
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OBJECTIVES OF AML/CDD/CFT POLICY
The objective of this policy is to ensure that the products and services of the Company are not used to launder the proceeds of crime and that all of the Company’s staff is aware of their obligations and the need to remain vigilant in the fight against money laundering/terrorist financing. The document also provides a framework to comply with applicable laws and regulatory guidelines, especially related to the detection and reporting of suspicious activities.
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MONEY LAUNDERING
Definition: Money Laundering is the criminal practice of processing ill-gotten gains or“dirty” money, through a series of transactions, in this way the funds are “cleaned” sothat they appear to be the proceeds from legal activities, it is also the process to changethe identity of illegally obtained money by using banking channel so that it appears tohave originated from a legitimate source.

STAGES OF MONEY LAUNDERING
Money laundering can be a diverse and often complex process. The first step in thelaundering process is for criminals to attempt to get the proceeds of their crimes into abank or other financial institution, sometimes using a false identity. The funds canfurther be transferred to other accounts, locally or internationally or use it to buy othergoods or services. It eventually appears to be like legally earned money and becomes difficult to trace back to its criminal origin. The criminals can then invest or spend it or,as is often the case, use it to funded more crime.
The laundering process is often described as taking place in three stages:
1. Placement
2. Layering
3. Integration.
4. Placement
The first stage is referred to as Placement. At this stage Illegal funds or assets are firstbrought into the financial system. When illegal funds are placed in the financial system,they become more liquid. There are numerous Placement techniques, including thefollowing:
*Smurfing
*Alternative Remittances
*Electronic Transfers
*Asset Conversion
*Bulk Movement
*Securities Dealing
Smurfing: involves the deposit of small amounts of illegal cash into account(s). Typically,smurfing deposits are in small amounts in order to avoid Regulatory requirements ofreporting cash transactions ‘Alternative Remittances : It refers to the transfer of funds through ‘alternative’ or illegalmoney transfer system. These systems are unregulated and illegal, but they are used totransfer both legitimate and illegal funds. Alternative Remittances also goes by thenames of underground or parallel banking. There are very large networks of thesesystems in operation around the world.

Electronic Transfers: In the money laundering context, an electronic transfer involvesthe transfer of money through electronic payment systems that do not require sendingfunds through a bank account. If the amount is below the CTR (Cash TransactionReporting) limit then it will not be reported as per prevailing regulations.

Asset Conversion: Asset Conversion simply involves the purchase of goods. Illegalmoney is converted into other assets, such as real estate, diamonds, gold and vehicles, which can then be sold and proceeds can be deposited in the account.Bulk Movement: involves the physical transportation and smuggling of cash and monetary instrument such as money orders and checks.

Securities Dealing : Illegal funds are placed with securities firms which is used for buying bearer securities and other easily transferable instruments
2. Layering
Layering is the second stage of money laundering. In this stage illegal funds or assetsare moved, dispersed and disguised to conceal their illegal origin. There are numerous techniques and institutions that facilitate layering, including the following:* Offshore Banks* Shell Corporations* Trusts* Walking Accounts* IntermediariesOffshore Banks : Offshore Banks accept deposits from non-resident individuals and corporations. A number of countries have well-developed offshore banking sectors; insome cases, combined with loose anti- money laundering regulations.Shell Corporations : A Shell Corporation is a company that is formally established under applicable corporate laws, but does not actually conduct a business. Instead, it is usedto engage in fictitious transactions or hold accounts and assets to disguise their actual ownership.

Trusts : Trusts are legal arrangements for holding specified funds or assets for aspecified purpose. These funds or assets are managed by a trustee for the benefit of aspecified beneficiary or beneficiaries. Trusts can act as layering tools as they enablecreation of false paper trails and transactions. The private nature of trusts makes themattractive to money launderers.Walking Accounts : A Walking Account is an account for which the account holder hasprovided standing instructions that upon receipt all funds should be immediatelytransferred into one or more accounts. By setting up a series of walking accounts,criminals can automatically create several layers as soon as any fund transfer occurred.Intermediaries : Lawyers, accountants and other professionals may be used asIntermediaries or middlemen between the illegal funds and the criminal. Professionalsengage in transactions on behalf of a criminal client who remains anonymous. Thesetransactions may include use of shell corporations, fictitious records and complex papertrails.3. IntegrationIntegration is the third stage of money laundering process. In this stage, illegal fundsare successfully legitimized by mixing with legitimate funds in the financial system.There are various Integration techniques, including the following:* Import /Export Transactions* Business Recycling* Asset Sales & Purchases* Consultants* Credit & Debit Cards* Corporate FinancingsImport /Export Transactions to bring illegal money into the criminal’s country ofresidence, the domestic trading company will export goods to the foreign tradingcompany on an over-invoiced basis. The illegal funds are remitted and reported asexport earnings. The transaction can work in the reverse direction as well.Business RecyclingLegitimate businesses also serve as conduits for money laundering. Cash-intensiveretail businesses, real estate, jewelers, and restaurants are some of the most traditionalmethods of laundering money. This technique combines the different stages of themoney laundering process.Asset Sales & PurchasesThis technique can be used directly by the criminal or in combination with shellcorporations, corporate financings and other sophisticated means. The end result is thatthe criminal can treat the earnings from the transaction as legitimate profits from thesale of the real estate or other assets.ConsultantsThe use of consultants in money laundering schemes is quite common. The consultantcould be fake. For example, the criminal could himself be the consultant. In this case,the criminal is channeling money back to himself. This money is declared as incomefrom services performed and can be used as legitimate funds.Credit & Debit Cards:Credit cards are an efficient way for launderers to integrate illegal money into thefinancial system. By maintaining an account in an offshore jurisdiction through whichpayments are made, the criminal ensures there is a limited financial trail that leads tohis country of residence.Debit Cards Individuals first transfer illegal funds into an offshore account and alsosigns up for a debit card from the bank to utilize the funds.Corporate FinancingsCorporate financings are typically combined with a number of other techniques,including use of offshore banks, electronic funds transfers and shell corporations.The three basic stages may occur as separate and distinct phases. They may also occursimultaneously or, more commonly, may overlap.SOURCES OF MONEY LAUNDERING:Money laundering may not just involve wealth related to Drug Trafficking / Terrorismfinancing. List of crimes identified by Financial Action Task Force (FATF) as generatorsof criminal wealth also included:1. Illegal arms sales2. Gun running3. Organized crime including drug trafficking and prostitution4. Embezzlement5. Smuggling (including movement of nuclear materials)6. Counterfeiting (including making of imitation and copies of original products/goods)7. Fraud, especially computer-supported fraud8. Benefiting from insider trading.9. Bribery and kickbacks10.Tax evasion11.Under and over-invoicing of trade transactions.12.Bogus trade transactions to launder money through round-tripping13.Facilitating illegal immigration14.Real Estate TransactionsTERRORIST FINANCINGTerrorist Financing can be defined as the financial support, in any form, to terrorism orof those who encourage, plan, or engage in terrorism. A terrorist group, like any othercriminal organization, builds and maintains an infrastructure to develop sources offunds and channel them to those who provide materials and or services to the terroristorganization.THE NEED TO COMBAT MONEY LAUNDERING (ML) AND TERRORISTFINANCING (TF)The prevention of ML and TF from the point of view of the Company has three dimensions:* Ethical - taking part in the prevention of crime.* Professional - ensuring that the Company is not involved in recycling the proceeds ofcrime that would call into question its reputation, integrity and, if fraud is involved, itssolvency.* Legal - complying with Laws and Regulations that impose a series of specificobligations on financial services and their employees. The need also arises due to thesevere nature of consequences of ML and TF. Following are some examples:- Unexplained changes in supply and demand for money,- Contamination of legal financial transactions,- Systemic risk,- Unlawful enrichment by perpetrator of crime,- Weakening of the social, collective ethical standards,- Drug trafficking, Human trafficking,- Political corruption,- Terrorism crimes cause a great deal of human misery.REGULATORY OVERSIGHT & COMPLIANCE RISKSThe company has used Central Bank of the UAE Regulations 24/2000,subsequent amendments/changes, UAE and DMCC applicable laws and the bestpractices and recommendation, to formulate its own AML/CDD/CFT Policy. Theconsequence of contravening the Regulations or failing to comply can be significant andinclude disciplinary measures, imprisonment or fine or both under local laws as well asthe loss of reputation for the company.Notwithstanding the statutory and regulatory penalties, increased vigilance byManagement and staff will protect the company from the following risks:• Reputational• Operational• Legal• FinancialReputational risk: The reputation of a business is usually at the core of its success. Theability to attract good employees, customers, funding and business is dependent onreputation. Even if a business is otherwise doing all the right things, if customers arepermitted to undertake illegal transactions through that business, its reputation couldbe irreparably damaged. A strong AML/CDD/CFT policy helps to prevent a business frombeing used as a vehicle for illegal activities.Operational risk: This is the risk of direct or indirect loss from faulty or failed internalprocesses, management and systems. In today's competitive environment, operationalexcellence is critical for competitive advantage. If AML/CDD/CFT policy is faulty or poorlyimplemented, then operational resources are wasted, there is an increased chance ofbeing used by criminals for illegal purposes, time and money is then spent on legal andinvestigative actions and the business can be viewed as operationally unsound.Legal risk: If a business is used as a vehicle for illegal activity by customers, it faces therisk of fines, penalties, injunctions and even forced discontinuance of operations.Financial risk: If a business does not adequately identify and verify customers, it mayrun the risk of unwittingly allowing a customer to pose as someone they are not. Theconsequences of this may be far reaching. If a business does not know the true identityof its customers, it will also be difficult to retrieve money that the customer owes.CUSTOMER DUE DILIGENCE(CDD)Customer due diligence is a complex of procedures that helps us to establish customer’sidentity, the nature of the business, intentions for future relationships and compliancewith the data provided. The purpose of CDD is to prevent the use of illegallyobtained assets and property in the economic activity of the Company. CDD isbased, first and foremost, on applying the KnowYour-Customer (“KYC”) principle, underwhich a customer shall be identified and respective transactions shall be assessedbased on the customer’s expected business activity. In addition, CDD serves to identifyunusual circumstances in the customer’s activity whereby an employee of the Companyhas reason to suspect, or has a knowledge based on facts regarding moneylaundering or terrorist financing.In accordance with DMCC recommendations, we should undertake due diligence in thefollowing cases:• establishing the business relationship;• carrying out occasional transactions in favour of a customer for amounts equal to orexceeding AED 55,000, whether the transaction is carried out in a single transaction orin several transactions that appear to be linked;• carrying out occasional transactions in the form of wire transfers for amounts equalto or exceeding AED 3,500;• where there is a suspicion of Money Laundering, Terrorist Financing;• where there are doubts about the veracity or adequacy of previously obtainedcustomer's identification data;• on an annual basis;• at periodic intervals based on company status and circumstances.We adopt a risk based approach to determine the extent of additional due diligencemeasures with the level of risk posed by the customer type, business relationship,transaction, product/service or geographical location.Risk factors:Risk category Risk FactorClient risk (for Directors, UBO’s and othermanagers and shareholders of the entity)*Whether the person is subject tointernational sanctions (UN, EU, OFAC,etc.).*Whether the person is a politicallyexposed person1 (“PEP”).*Whether the person is represented by alegal person (e.g. introducer, attorney).*Whether a third party (individual) is thebeneficial owner of the transaction.Client risk (for legal entities) Product/ Service risk2 *Circumstances (including suspicioustransactions identified in the course of aprior business relationship) resultingfromthe experience of communicating with theperson, its business partners, owners,representatives and any other persons.*The duration of the operations and thenature of business relationships.*The type and nature of the services usedorproducts consumed by the person outsidethe Company.*The nature of the personal activities of anindividual.*Whether the origin of the person’s wealthor the source and origin of the funds usedfor a transaction can be easily identified.*Turnover of the customer base*Whether the person’s customer base hasincreased rapidly.*Whether the person provides its servicestoanonymous customers.*The legal form, management structure,fieldof activity of the person, includingwhetherit is a trust fund, civil law partnership oranother similar contractual legal entity oralegal person with bearer shares.*Whether the identification of thebeneficialowner is impeded by complex andnontransparentownership structure.*Whether the service or product may berelated to criminal activity.*Nominal shareholders, directors,selfdeclaredultimate beneficial owners.*Nature of services provided to thecustomer.*Individual / account type transactionlimits.Geographical risk3 *Whether the country applies legalprovisions that are in compliance with theinternational standards of prevention ofmoney laundering and terrorist financing.*Whether there is a high crime rate (incl.drug-related crime rate) in the country.*Whether the known organised crimegroupsexploit the country to pursue theiroperations.*Whether the country engages inproliferation of weapons of massdestruction.*Whether there is high level of corruptioninthe country.*Whether international sanctions havebeenor are being imposed on the country.*Whether other measures have beentakenagainst or positions of internationalorganizations have been expressed onthecountry.Interface / Delivery channel risk Whether the person has been identifiedface-to-face or remotely.1 Individuals who have, or have had, a high political profile, or hold, or have held, publicoffice, can pose a higher money laundering risk to the Company as their position maymake them vulnerable to corruption. This risk also extends to members of theirimmediate families and to know close associates. More info listed below.2The Company would not do business with entities that provide such activities:*Collecting donations as a charity or non-profit organization, NGO’s* Dating (newly incorporated, not known );* Drug paraphernalia - product or accessory that is intended or modified for making,using, or concealing drugs, typically for recreational purposes;* Drugs / Illicit substances, steroids and certain controlled substances or otherproducts that present a risk to consumer safety;* Encourage, promote, facilitate or instruct others to engage in illegal activity;* Extractive Industries;* High Risk File hosting / sharing and cyberlockers;* Infringe any duly registered copyrights/trademarks or other violation of intellectualproperty rights;* Unregulated pharmaceuticals, illegal drugs and or unlicensed drug related activity;* Involve offering or receiving payments for the purpose of bribery or corruption anyform of high yield financial investments (get rich quick schemes);* Items that encourage, promote, facilitate or instruct others to engage in illegalactivity;* Oil & Gas Industries;* PC Support sold via outbound telemarketing;* Pyramid or Ponzi schemes;* Relate to the sale of dangerous or hazardous goods;* Replicas;* Sale of government ID’s or documents;* Services associated with prostitution, escort;* Stolen goods including digital and virtual goods (fictitious social media likes, spamemails);* Unlicensed lottery and gambling;* Unregulated crypto companies;* Unregulated Forex;* Violate any law, statute, ordinance or regulation;* Weapons, firearms and ammunitions;3The Company would not do business with entities and individuals from such countries:Afghanistan, El Salvador, Mali, Sierra Leone, American Samoa, Equatorial Guinea,Moldova, Somalia, Aruba, Eritrea, Myanmar, Sudan, Ethiopia, Morocco, South Sudan,Bahamas, Fiji, Mozambique, Sri Lanka, Bangladesh, Ghana, Nicaragua, Syria, Guinea,Nigeria, Trinidad and Tobago, Guinea-Bissau, Niger, Tunisia, Botswana, Guam, NorthKorea, Turkmenistan, Burkina Faso, Guyana, Oman, Uganda, Burundi Haiti, Pakistan, USVirgin Islands, Cambodia, Iran, Palestine, USA, Central African Republic, Iraq, PanamaVenezuela, Congo, Jamaica, Yemen, Congo Democratic Republic, RussianFederation(Crimea only) Zambia, Cuba, Laos, Samoa, Zimbabwe, Dominican Republic,Lebanon, Libya.SIMPLIFIED DUE DILIGENCE (SDD)The Company may decide to conduct a simplified due diligence, if the customer does notmeet any of these risk criteria. In this case, the customer should provide us the followingdata set:a) to verify the identity of an individual who performs management functions in anorganization or is a shareholder:* applicant’s full name (as per NID or passport);*date and place of birth;*nationality;*physical address (residential and business);*contact details (E-mail, phone number);*ID or passport*PEP status*US Citizen statusb) for verification of the identity of a legal entity:*full business name, including any trading name;*registered or business address with contact details;*place of incorporation or registration;*valid commercial or professional license;*the identity of the directors, managers, shareholders, signatories or equivalent personswith executive authority in respect of the legal entity;*ultimate beneficial owners;*copy of memorandum and articles of association.In the case of SDD we also:*reducing the degree of on-going monitoring and scrutinizing transactions, based on areasonable monetary threshold (55000 AED/15000 EURO or USD for occasionaltransactions);*not collecting specific information or carrying out specific measures to understand thepurpose and intended nature of the business relationship, but inferring the purpose andnature from the type of transactions or business relationship established;*undertake the periodic review of a business relationships less frequently than usual,including reassess the customer’s risk profile every year after establishment of thebusiness relationships.ENHANCED DUE DILIGENCE (EDD)The customer's risk level is usually high, when assessing the risk categories on thewhole it seems that the customer's operations are not ordinary or transparent; thereare risk factors of impact due to which it may be presumed that the likelihood of moneylaundering or terrorist financing is high or considerably higher. The customer's risk levelis also high if a risk factor as such calls for this. A high risk does not necessarily meanthat the customer is laundering money or financing terrorists.If the Company feels that the risk level of a customer or a person participating in atransaction is high, the Company shall apply customer due diligence measures pursuantto the enhanced procedure in order to adequately manage the respective risks. Thefollowing are deemed situations increasing risks related to the customer as a person:*the business relationship based on unusual factors, including in the event of complexand unusually large transactions and unusual transaction patterns that do not have areasonable, clear economic or lawful purpose or that are not characteristic of the givenbusiness specifics;*the customer is a legal person or a legal arrangement, which is engaged in holdingpersonal assets;*the customer is a cash-intensive business;*the customer is a company that has nominee shareholders or bearer shares or acompany whose affiliate has nominee shareholders or bearer shares;*the ownership structure of the company appears unusual or excessively complex,given the nature of the company’s business.The following are deemed situations increasing risks related to the product, service,transaction or delivery channel:*private banking;*provision of a product or making or mediating of a transaction that might favouranonymity;*payments received from or sent to third parties;*new products and new business practices, including new delivery mechanism, and theuse of new or developing technologies for both new and pre-existing products.When the customer meets one of the risk criteria, the Company must conduct EDD. Inthis case we should request additional data set:a) for individuals:*Selfie with passport or ID;*Video-call;*Utility bill;*Bank statement;*Source of funds;*other necessary data.b) for legal entities:*Source of entity’s funds*Expected turnover*Nature of business interest*Authorized representatives (other than controlling persons) and their legal Capacity*Other information which may be required for conducting identification and verificationof the legal entity.In case of EDD we also:*conducting enhanced monitoring of the business relationship, by increasing the numberand timing of controls applied, and selecting patterns of transactions that need furtherexamination.*undertake the periodic review of a business relationships more frequently than usual,including reassess the customer’s risk profile every 30-90 days after establishment ofthe business relationships.Politically Exposed PersonsIndividuals who have, or have had, a high political profile, or hold, or have held, publicoffice, can pose a higher money laundering risk to the Company as their position maymake them vulnerable to corruption. This risk also extends to members of theirimmediate families and to know close associates. PEP status itself does not, of course,incriminate individuals or entities. It does, however, put the customer, or the beneficialowner, into a higher risk category. The Company shall imply EDD to PEPs.A PEP is defined as an individual who is entrusted with prominent public functions, otherthan as a middle-ranking or more junior official. Individuals entrusted with prominentpublic functions include:* Heads of state, heads of government, ministers and deputy or assistant ministers;* Members of parliaments or of similar legislative bodies;* Members of supreme courts, of constitutional courts or of other high-level judicialbodies the decisions of which are not subject to further appeal, except in exceptionalcircumstances;* Members of courts of auditors or of the boards of central banks;* Ambassadors, charges affairs and high-ranking officers in the armed forces (otherthan in respect of relevant positions at Community and international level);* Members of the administrative, management or supervisory boards of State-ownedenterprises; and* Directors, deputy directors and members of the board or equivalent function of aninternational organization.Family members of PEPs:* The spouse, or a person considered to be equivalent to a spouse of a PEP;* The children and their spouses, or persons considered to be equivalent to a spouse, ofa PEP; and* The parents of a PEP.Persons known to be close associates of PEPs:* Natural persons, who are known to have joint beneficial ownership of legal entities orlegal arrangements, or any other close business relations, with a PEP; and* Natural persons who have sole beneficial ownership of a legal entity or legalarrangement which is known to have been set up for the de-facto benefit of a PEP. Publicfunctions exercised at levels lower than national should normally not be consideredprominent. However, when their political exposure is comparable to that of similarpositions at national level, for example, a senior official at state level in a federal system,firms should consider, on a risk-based approach, whether persons exercising thosepublic functions should be considered as PEPs.The following EDD measures in addition to the general CDD measures should be appliedto PEPs* obtains approval from the senior management to establish or continue a businessrelationship with the person;* applies measures to establish the origin of the wealth of the person and the sourcesof the funds that are used in the business relationship;* designation of custom transaction limits based on a verified source of funds/wealth;* monitors the business relationship in an enhanced manner.TRANSACTION MONITORINGMonitoring and identifying of unusual and suspicious transactions is an important partof customer due diligence measures applied by obliged entities, that allows to identifythe circumstances that may point to money laundering or terrorist financing in theactivity of customers. Also, the purpose of transaction monitoring is to identifytransactions with subjects of international sanctions and politically exposed personsand detect and notify of transactions whose limit or other parameters exceed theprescribed value over a certain period of time.Transaction monitoring measures can be divided into two categories: screening andanalysis.Transaction screening allows transactions to be monitored in real time, based on dataaccompanying the transaction. The following “red flags” may be identified upontransaction screening:* politically exposed persons involved in transactions;* transactions with persons whose name, alias, date of birth or other identifiableinformation match with data in lists of persons subject to international sanctions,adverse media, enforcement actions, etc.;* payments received from or sent to a high-risk country;* payment received from or sent to a third-party (non-customer of the Company)Transaction analysis helps to detect deviations in customer’s activity and identifyunusual transaction patterns which may be related to money laundering, terroristfinancing or other illegal activity. The following red flags may be identified upontransaction analysis:* single large international payments (e.g. whereby the sum ends with at least fourzeros);* accounts with the highest turnover in the period under review based on currencies;* the largest transactions in the period under review based on different currencies;* single transaction that exceed the limit, which are made by customers whoseturnover is small;* sudden increase in account activity without rationale;* transactions in multiple currencies;* transactions without apparent lawful or business purpose.If the customer is regularly unable to give the requested information about the natureof transactions or their purpose, the Company shall take measures which include givingwarnings and setting time limits. Thereafter the customer may be denied to execute anytransaction or business relationships may be limited or terminated.AML COMPLIANCE OFFICERThe Board shall appoint a compliance officer for performance of AML/CFT duties andobligations. The functions of a compliance officer may be performed by an employee ormember of the Board or several employees and/or a business unit with the relevantduties. If the functions of the compliance officer are performed by a business unit, thehead of the relevant business unit will be responsible for the performance of thefunctions.The position of a compliance officer within the Company shall allow for the performanceof the requirements provided by law for the prevention of money laundering andterrorist financing.The duties of the compliance officer include:* Organization of collection and analysis of information referring to unusual transactionsor transactions suspected of money laundering or terrorist financing in the activities ofthe Company (collection of information means collection of any and all suspicious orunusual notices received from the employees, contractual partners and agents of theCompany, and analysis of the information contained in them);* Reporting to the Financial Intelligence Unit (the “FIU”) in the event of suspicion ofmoney laundering or terrorist financing (notice being given in the manner agreed withthe FIU);* Periodic submission of written statements on implementation of the rules of procedureto the Board; and* Performance of other obligations related to the fulfilment of the requirements of thepolicy (including training employees and applying respective control mechanisms).The compliance officer shall have access to the information used for establishing abusiness relationship, including any information, data or documents reflecting theidentity and business activity of the customer. The management board also grants thecompliance officer the right to participate in the meetings of the management board ifthe compliance officer deems this necessary to perform their functions.The contact details of the compliance officer shall be communicated to the FinancialIntelligence Unit. The compliance officer shall inform the Financial Intelligence Unitwithin a reasonable term about the appointment of a new compliance officer or a changein contact details.REPORTINGThe compliance officer is advised to make every employee aware of his/her role andduty to receive or submit internal suspicious activity reports.The compliance officer is advised to investigate suspicious transaction reports (STR)internally and create an internal report outlining the outcome of its investigationincluding the decision on whether or not to file an external STR. Where appropriate, thecompliance officer is advised to make the STR to the FIU and provide a copy to DMCCA.If a compliance officer suspects or has reasonable grounds to suspect that fundsconcerning an actual or proposed transaction are the proceeds of any criminal activity,or are related to Money Laundering, Terrorist Financing activity, the compliance officermust file a written STR with the FIU.To file STR the goAML system should be used: https://services.cbuae.gov.ae/To file a copy of STR to DMCC: https://dmccpoc.force.com/DMCCHelpCentre/OUTSOURCINGThe Company has the right, considering special requirements and restrictions providedby law, to use the services of a third party under a contract the subject of which is thecontinuing performance of activities and continued taking of steps required for theprovision of services by the Company to its Customers [and third party services wouldbe use as addition to the Company standard procedures without relieving the companyof responsibility for fulfilling its obligations]. For the purposes of this section, thirdparties include, for instance, agents, subcontractors and other persons to whom theCompany transfers the activities relating to the provision of the services provided as arule by the Company in its economic activities.As an example, the Company can use external services,[in addition to its standardprocedures], to conduct an Enhanced Due Diligence if there are any suspicious aboutthe customer’s data.RECORD KEEPINGThe Company will principally retain the following records from an AML perspective:* Records of customer screening (PEPs & Sanctions);* Copies of, or references to, the evidence obtained of a customer’s identity for fiveyears after the end of the customer relationship;* Details of customer transactions for five years from the date of the relevanttransaction;* Records of all AML/CTF training delivered;* Details of actions taken in respect of internal and external suspicion reports;* Details of information considered by the MLRO or his nominee in respect of aninternal report where no external report is made.