Anti-Money Laundering (AML) Policy for Quick Trade Capital, Dubai

INTRODUCTION

Quick Trade Capital is dedicated to the highest standards of Anti-Money Laundering (AML) compliance. This policy outlines our firm’s commitment to preventing, identifying, and reporting any illicit activities, including money laundering and terrorism financing. As a proprietary trading firm based in Dubai, we adhere strictly to the regulations and guidelines established by the UAE authorities.

SCOPE

This AML policy is applicable to all employees, contractors, traders, and any third parties associated with Quick Trade Capital.

REGULATORY FRAMEWORK

Quick Trade Capital complies with the Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, as well as guidelines from the UAE Central Bank.

DEFINITIONS

• Money Laundering (ML): The process of disguising the origins of illegally obtained money to make it appear legitimate.
• Terrorism Financing (TF): Providing financial support for terrorist activities.

OBLIGATIONS

Risk Assessment

Considering the nature of our trading activities, we will:

• Continuously evaluate the risks of ML and TF related to our trading operations, counterparties, and regions involved.
• Monitor trading patterns for irregularities in size, volume, or frequency.
• Implement enhanced measures for high-risk traders or clients, which include:
  • Collecting additional information on their trading practices.
  • Understanding the source of significant or repeated fund transfers.
  • Intensifying the monitoring of their trading activities.

Internal Policies

We will develop and enforce comprehensive internal policies, procedures, and controls, taking into account our specific ML risks and business operations. These policies will be communicated effectively to all staff and traders.

Customer Due Diligence (CDD)

Our CDD procedures involve:

• Properly identifying and verifying customers during onboarding.
• Collecting necessary information such as:
  • Full name
  • Unique identification number (e.g., passport, national ID)
  • Residential address
  • Date of birth
  • Nationality
• For entities, we collect:
  • Full legal name and any aliases
  • Unique identification number of the connected party
• Utilizing external services to validate the authenticity of documents.
• Screening customers against relevant sanctions lists, PEP lists, and adverse media.
• Conducting ongoing monitoring of customer data.

Recordkeeping

We will retain all records of customer information and transactions for at least five years following the termination of the business relationship or the final transaction.

Reporting Suspicious Activities

We are committed to reporting any suspicious activities promptly to the UAE Financial Intelligence Unit (FIU). Types of reports include:

• Suspicious Transaction Reports (STR)
• Cash Transaction Reports (CTR)
• Reports on cash movements

TRAINING

All employees and traders will undergo regular AML training to ensure they understand their responsibilities and can identify and report suspicious activities.

COMPLIANCE OFFICER

A Compliance Officer will be appointed to:

• Oversee the implementation and updating of the AML policy.
• Report to senior management and regulatory bodies.
• Manage training and awareness initiatives.

REVIEW AND UPDATE

This policy will be reviewed annually or when there are significant changes in regulations or our operational structure.

PENALTIES FOR NON-COMPLIANCE

Non-compliance with this AML policy may result in disciplinary actions, including termination of trading privileges, and could lead to criminal or civil penalties.

CONCLUSION

Quick Trade Capital is committed to maintaining the highest AML standards in our trading environment. All staff and traders are required to comply with this policy and report any suspicious activities.