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AURNÉ PRIVATE ADVISORY – ANTI–MONEY LAUNDERING (AML) & COUNTER–TERRORISM FINANCING (CTF) STATEMENT

Last updated: January 2025

1. Introduction

AURNÉ Private Advisory ("AURNÉ", "we", "our", "us") is committed to conducting its business in full compliance with all applicable Anti–Money Laundering (AML) and Counter–Terrorism Financing (CTF) laws and regulations of the United Arab Emirates ("UAE"), and international standards.

As a Designated Non-Financial Business or Profession (DNFBP) operating as a Corporate Service Provider, AURNÉ is legally required to implement robust AML/CTF systems, due diligence processes, reporting obligations, and internal controls to prevent misuse of our services for illicit purposes.

2. Regulatory Framework

AURNÉ complies with the following UAE federal laws, Cabinet resolutions, and regulatory guidelines:

2.1 Federal-Level Regulations

  • Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism
  • Cabinet Decision No. 10 of 2019 regarding the Executive Regulations
  • Federal Decree-Law No. 26 of 2021 amending AML/CTF laws
  • Cabinet Decision No. 24 of 2022 (amended DNFBP requirements)

2.2 Ministry of Economy (MOE) DNFBP Framework

AURNÉ adheres to:

  • DNFBP Supervision Guidelines
  • Risk-based AML/CTF approach
  • goAML registration and reporting
  • Targeted financial sanctions (TFS) requirements

2.3 International Standards

Where applicable:

  • FATF (Financial Action Task Force) Recommendations
  • Wolfsberg Principles
  • OECD global compliance standards

AURNÉ participates fully in UAE Federal and MOE-led compliance enforcement initiatives.

3. AML/CTF Compliance Objectives

AURNÉ's AML/CTF framework aims to:

  • Identify and verify the identity of clients and beneficial owners
  • Detect suspicious activities and transactions
  • Prevent misuse of AURNÉ's services for illegal purposes
  • Ensure compliance with sanctions lists
  • Maintain effective internal controls and staff training
  • Meet reporting and record-keeping obligations

4. Scope of Application

This AML/CTF Statement applies to:

  • All AURNÉ employees
  • All directors and senior management
  • All contractors or outsourced functions
  • All services offered by AURNÉ
  • All clients and associated beneficial owners

Compliance is mandatory and non-negotiable.

5. Risk-Based Approach (RBA)

AURNÉ employs a Risk-Based Approach, assessing each client, business relationship, and transaction according to:

  • Jurisdiction risk
  • Industry risk
  • Client risk
  • Ownership structure complexity
  • Source of funds/wealth
  • Transaction purpose
  • Delivery channel

Risk ratings include:

  • Low Risk
  • Medium Risk
  • High Risk
  • Prohibited / Declined

Higher-risk clients undergo Enhanced Due Diligence (EDD).

6. Customer Due Diligence (CDD)

AURNÉ conducts CDD before onboarding or providing any services. For detailed CDD procedures, documentation requirements, and onboarding processes, see our KYC & Client Onboarding Policy.

CDD includes:

  • Full identification of the client
  • Verification of identity using reliable documentation
  • Collection of corporate documents
  • Identification and verification of UBO(s)
  • Understanding of business purpose
  • Screening against sanctions and risk lists

No services commence until CDD is complete and approved.

7. Enhanced Due Diligence (EDD)

EDD is applied in higher-risk scenarios, including:

  • Politically Exposed Persons (PEPs)
  • High-risk jurisdictions (as per FATF)
  • Complex cross-border structures
  • Cash-intensive or sensitive industries
  • High-risk business activities

EDD measures include:

  • Senior management approval
  • Independent verification of source of funds & wealth
  • Additional documentation
  • Ongoing enhanced monitoring

8. Sanctions Screening & Watchlist Checks

AURNÉ performs mandatory screening against:

  • UAE Financial Intelligence Unit (FIU) lists
  • United Nations Security Council sanctions
  • UAE Cabinet Resolution 74/2020
  • OFAC, EU, UK, and other global sanctions lists (when relevant)

Matches or partial matches undergo immediate escalation.

9. Ongoing Monitoring

AURNÉ conducts ongoing monitoring of:

  • Client transactions (if applicable)
  • Changes to corporate structure
  • Changes in risk profile
  • Adverse media alerts
  • Expired documents
  • Suspicious behavior or inconsistencies

Monitoring takes place throughout the business relationship.

10. Suspicious Transaction/Activity Reporting (STR/SAR)

AURNÉ is registered with goAML and fulfills all reporting obligations.

We file:

  • Suspicious Transaction Reports (STRs)
  • Suspicious Activity Reports (SARs)
  • Priority reports (when directed by MOE or FIU)
  • Targeted Financial Sanctions (TFS) reports

Clients are not notified when such reports are made (tipping-off prohibition).

11. Record Keeping

AURNÉ retains:

  • CDD/KYC records
  • Transactional documentation
  • Risk assessments
  • AML-related internal notes
  • Audit trail of decisions

Retention period: minimum of 5 years, or longer if required by law.

All records are securely stored and encrypted.

12. Internal Controls & Governance

AURNÉ maintains:

  • A documented AML/CTF policy and procedures manual
  • A designated AML Compliance Officer
  • Escalation and reporting protocols
  • Regular internal compliance audits
  • Management oversight and review
  • Screening tools and risk systems

13. Employee Training

All staff receive:

  • Mandatory AML/CTF onboarding training
  • Annual refresher training
  • Risk-specific training (if required)
  • Targeted training for staff involved in CDD/EDD

Training tracks are recorded for compliance verification.

14. Prohibited Activities

AURNÉ will not accept clients or provide services where:

  • The activity is illegal or unethical
  • The client refuses to provide KYC information
  • There are signs of money laundering or sanctions evasion
  • The client is associated with terrorism or financial crime
  • The structure is excessively opaque or unjustifiable
  • Sources of funds cannot be verified

AURNÉ reserves the right to decline or terminate any engagement.

15. Reporting Violations

Employees must promptly report suspected AML/CTF violations to:

  • The AML Compliance Officer
  • Senior management (if appropriate)

Retaliation against whistleblowers is strictly prohibited.

16. Continuous Improvement

AURNÉ regularly updates its AML/CTF framework based on:

  • Regulatory changes
  • MOE or FIU directives
  • FATF updates
  • Internal audit findings
  • Risk changes in client portfolio

Compliance is a continuously evolving process.

17. Contact Information

For AML/CTF matters or regulatory inquiries:

AURNÉ Private Advisory – AML Compliance Division
Email: contact@aurne.org
Phone: +971 56 497 5840 (WhatsApp)
Phone: +971 56 615 8490 (WhatsApp)
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.