AML Policy

FundingEra FZCO is committed to preventing money laundering (ML), terrorist financing (TF), and sanctions evasion. This policy sets out our risk‑based controls across onboarding, payments, simulated trading, payouts, and partner engagement.

1) Purpose & Scope

Define principles, responsibilities, and controls to meet UAE AML/CFT laws and international standards.
Apply to all FundingEra operations and any controlled affiliates, staff, contractors, and partners.
Cover customer onboarding, transaction monitoring, sanctions screening, record‑keeping, reporting, and training.

2) Legal & Regulatory Framework (UAE)

UAE Federal Law No. 20 of 2018 (AML/CFT) & Cabinet Resolution No. 10 of 2019 (Implementing Regulations).
UAE Federal Law No. 7 of 2014 (Combating Terrorism Crimes).
UAE Penal Code (Federal Law No. 3 of 1987, as amended) & Penal Procedures Law No. 35 of 1992.
UAE Federal Law No. 5 of 2012 (Cybercrimes) and relevant Central Bank / SCA guidance.
United Nations sanctions and any UAE‑adopted restrictive measures.

3) Definition of Money Laundering

Any intentional act to conceal, disguise, transfer, acquire, or use proceeds of crime, or assist offenders in evading justice. Willful blindness or failure to report suspicious activity may incur liability under UAE law.

4) Governance & Responsibilities

Board & Senior Management

Approve policy, set risk appetite, ensure resources & independence of Compliance.
Receive periodic AML/CFT MI (metrics) and incident reports.

Designated Compliance Officer (MLRO)

Owns policy & procedures; maintains goAML registration and regulator liaison.
Oversees KYC/CDD/EDD, sanctions screening, monitoring, and STR/SAR filings.
Leads training, QA testing, and annual program reviews.

Risk Management

Applies risk taxonomy across customers, geographies, products, channels, and PSPs.
Maintains risk scoring (Low/Medium/High) and recommends EDD/mitigations.

All Employees

Follow procedures, complete training, and escalate red flags to the MLRO immediately.

5) Risk‑Based Approach

Assess risks by customer type, geography, payment method, device/IP, behavior, and payout pattern.
Apply proportionate controls: SDD (low), CDD (standard), EDD (high) including approval by MLRO.
Review risk ratings periodically and on trigger events (e.g., data change, anomaly, sanction updates).

6) KYC / CDD / EDD Requirements

Standard CDD

Government‑issued photo ID (passport or national ID) — valid and legible.
Match of payer name to KYC profile; verified contact and country of residence.
Purpose and intended nature of relationship (simulated evaluation programs).

Enhanced Due Diligence (EDD)

Applied to PEPs, high‑risk geographies, inconsistent documentation, or anomalous behavior.
May require additional documentation, source‑of‑funds, video KYC, and senior approval.

Simplified Due Diligence (SDD)

Permitted for clearly low‑risk retail users and small payments; records retained.

KYC is performed via secure third‑party providers (e.g., Sumsub/Veriff/KYCAID). FundingEra does not store raw KYC images where the provider hosts them; data is handled per Privacy Policy.

7) Sanctions Screening & Restricted Jurisdictions

Screen customers, payments, and partners against UN Consolidated List and UAE Local Terrorist List; consider OFAC/EU/UK for risk context.
Immediate block and escalation for potential matches; no onboarding or payouts until cleared.
No services to comprehensively sanctioned or otherwise prohibited jurisdictions; availability may be restricted to manage risk.

8) Transaction Monitoring & Red Flags

Manual and automated reviews for: multi‑account/device/IP overlaps, VPN/proxy abuse, split payments, unusual volumes, rapid payouts, chargebacks.
Payments from or routed via restricted jurisdictions, anonymous wallets, or mismatched names.
Coordinated behavior suggesting group trading or account brokering.

Flagged activity is escalated to Compliance for investigation; accounts may be suspended pending outcome.

9) Suspicious Activity Reporting (goAML)

Employees must escalate suspicions immediately to the MLRO.
Where appropriate, the MLRO files STR/SAR via the UAE goAML platform and coordinates with competent authorities.
All reports are confidential; tipping‑off is prohibited.

10) Record‑Keeping & Training

Maintain KYC, transactions, investigations, STRs, audits, and training records for at least 5 years (or longer if required).
Annual AML/CFT training for all staff; enhanced sessions for risk‑exposed roles; onboarding training for new hires.
Document attendance and materials; track completion and effectiveness.

11) Third Parties & PSPs

Use only vetted payment service providers (PSPs) and KYC vendors with appropriate controls.
Contractual clauses must cover AML/CFT, data protection, and audit rights.

12) Breaches, Sanctions & Enforcement

Non‑compliance may lead to internal discipline, account termination, regulatory penalties, and potential criminal liability under UAE law.
UAE penalties for ML/TF offenses may include fines (AED 100,000–10,000,000) and imprisonment.

13) Data Protection

Personal data is processed in line with UAE law and FundingEra’s Privacy Policy, applying minimization, security, and access controls.

14) Policy Review & Updates

Reviewed at least annually, and upon material legal, product, or risk changes.
Updates communicated to staff; latest version published internally and, where relevant, on the website.

15) Contacts

Designated Compliance Officer (MLRO)

Email: support@fundingera.com
Website: www.fundingera.com
Address: IFZA Free Zone, Dubai Silicon Oasis, Dubai, United Arab Emirates