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AURNÉ PRIVATE ADVISORY – KNOW YOUR CUSTOMER (KYC) & CLIENT ONBOARDING POLICY

Last updated: January 2025

1. Introduction

This KYC & Onboarding Policy outlines the due diligence standards and onboarding procedures followed by AURNÉ Private Advisory ("AURNÉ", "we", "our", "us") in compliance with UAE laws and international best practices.

As a Designated Non-Financial Business or Profession (DNFBP) under UAE AML laws, AURNÉ must verify the identity, legitimacy, and risk profile of clients before establishing a business relationship or providing any services.

This Policy applies to all:

  • Clients and prospective clients
  • Beneficial owners
  • Shareholders and directors
  • Authorized representatives
  • Third parties acting on behalf of clients
  • All jurisdictions and service types

2. Regulatory Framework

This Policy is governed by the following. For comprehensive details on our AML/CTF framework, see our AML & CTF Statement.

2.1 UAE Legislation

  • Federal Decree-Law No. 20 of 2018 (AML Law)
  • Cabinet Decision No. 10 of 2019 (Executive Regulations)
  • Cabinet Decision No. 58 of 2020 (UBO Regulations)
  • Cabinet Resolution No. 57 of 2020 (ESR Regulations)
  • Ministry of Economy DNFBP guidelines
  • Federal Decree-Law No. 45 of 2021 (PDPL – Personal Data Protection Law)

2.2 International Frameworks

Where applicable:

  • FATF Recommendations
  • OECD transparency standards
  • EU/UK AML expectations

3. Objectives of KYC & Onboarding

The KYC & Onboarding framework ensures:

  • Verification of client identity and beneficial ownership
  • Understanding of client structure, business purpose, and risk profile
  • Prevention of money laundering, terrorist financing, and sanctions violations
  • Integrity of AURNÉ's client portfolio
  • Compliance with regulatory obligations
  • Protection of AURNÉ and its clients from illegal activities

No service begins without completing KYC.

4. Scope of KYC Requirements

AURNÉ's KYC applies to:

  • Individuals
  • Corporations
  • Partnerships
  • Foundations / Trusts
  • Offshore/onshore entities
  • Free zone and mainland companies
  • Nominee arrangements (with strict justification)
  • Complex and cross-border structures

5. Onboarding Process Overview

The onboarding process includes:

5.1 Initial Inquiry Screening

  • Preliminary analysis of client request
  • High-level assessment of activity, jurisdiction, and risk
  • Identification of potential red flags

5.2 Document Collection

AURNÉ sends a formal KYC requirement checklist tailored to the client's structure and jurisdiction.

5.3 Verification & Screening

  • ID verification
  • Sanctions and PEP screening
  • Adverse media review
  • Document authenticity checks

5.4 Risk Assessment

Each client is classified as:

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

5.5 Approval or Rejection

  • Low/Medium risk: standard onboarding
  • High risk: requires Enhanced Due Diligence (EDD) and senior management approval
  • Prohibited: declined immediately

5.6 Engagement Letter & Payment

On successful approval:

  • Engagement Agreement is issued
  • Payment terms outlined
  • Work commences

6. Mandatory KYC Documentation

6.1 For Individual Clients

  • Passport copy (valid)
  • Emirates ID (if applicable)
  • Residential address proof
  • CV or professional background
  • Source of Funds (SOF) declaration
  • Source of Wealth (SOW) declaration (if required)
  • Bank reference letter (if required)

6.2 For Corporate Clients (UAE or Foreign)

  • Certificate of incorporation / formation
  • Memorandum and Articles of Association
  • Share register
  • Board resolution authorizing engagement
  • UBO declaration
  • Corporate chart
  • Trade license (for UAE entities)
  • Proof of physical address

6.3 For Beneficial Owners & Key Individuals

  • Passport
  • Address proof
  • KYC form
  • Source of funds/wealth evidence
  • KYC for directors/shareholders

6.4 Additional Documents (Risk-Dependent)

  • Bank statements (3–12 months)
  • Audited/unaudited accounts
  • Tax declarations
  • Proof of business activity
  • Contracts or invoices
  • Legal opinions
  • Regulatory licenses

7. Enhanced Due Diligence (EDD)

AURNÉ applies EDD when risk factors include (see AML & CTF Statement for comprehensive EDD framework):

  • Politically Exposed Persons (PEPs)
  • High-risk jurisdictions (FATF list)
  • Complex offshore structures
  • Cryptocurrency involvement
  • Cash-intensive activities
  • Legal/litigation exposure
  • Unclear source of wealth

EDD measures include:

  • Senior management approval
  • Additional SOF/SOW documentation
  • Independent verification
  • Third-party background reports
  • More frequent monitoring

8. Prohibited Clients

AURNÉ will decline clients involving:

  • Illegal or suspicious activities
  • Sanctions list matches
  • Anonymous or shell companies without verifiable activity
  • Uncooperative individuals/entities
  • Unverifiable SOF/SOW
  • Terrorism, arms trade, or narcotics-linked sectors
  • Corruption, fraud, or financial crime indicators

This is non-negotiable, regardless of commercial opportunity.

9. Ongoing Monitoring

KYC is not a one-time process.

AURNÉ conducts:

9.1 Periodic Reviews

  • Low Risk: every 36 months
  • Medium Risk: every 24 months
  • High Risk: every 12 months

9.2 Trigger-Based Reviews

When:

  • Ownership changes
  • New jurisdictions involved
  • Large or unusual transactions occur
  • Adverse media appears
  • Suspicious indicators arise

9.3 Continuous Screening

Automated or manual screening of:

  • Sanctions lists
  • PEP lists
  • Watchlists
  • Adverse media

10. Source of Funds & Source of Wealth Requirements

10.1 Source of Funds (SOF)

We verify the origin of funds used in a specific transaction or service.

Evidence may include:

  • Bank statements
  • Salary slips
  • Sale contracts
  • Loan agreements

10.2 Source of Wealth (SOW)

We verify how the individual accumulated their overall wealth.

Evidence may include:

  • Business ownership records
  • Investments or inherited wealth proofs
  • Financial statements
  • Tax documents

EDD clients require stricter SOF/SOW verification.

11. Sanctions Compliance

AURNÉ screens all clients against sanctions lists. For detailed screening procedures, see our AML & CTF Statement.

We screen against:

  • UN Security Council sanctions
  • UAE Local Terrorist List (Cabinet Decision 74/2020)
  • OFAC, EU, UK sanctions (if applicable)
  • Other global high-risk lists

Sanctioned or partially matched clients are escalated immediately.

12. Record Keeping

AURNÉ maintains comprehensive KYC records. For full record-keeping requirements, see our AML & CTF Statement.

We maintain:

  • All collected KYC documentation
  • Client risk assessments
  • Verification logs
  • Sanction screening reports
  • Correspondence and approvals

Retention: minimum of 5 years as required under UAE AML law.

All data is stored securely and encrypted.

13. Confidentiality & Data Protection

AURNÉ ensures:

  • All KYC data is protected under UAE PDPL
  • GDPR protections apply for EU/EEA clients
  • Strict confidentiality obligations
  • Controlled access permissions
  • Secure digital and physical storage

KYC data is used only for lawful compliance purposes.

14. Refusal, Suspension & Termination

AURNÉ may refuse or terminate services if:

  • KYC documents are not provided
  • Client refuses SOF/SOW evidence
  • Risk is too high
  • Suspicion of illegal activity
  • Regulatory instructions require it

Services will not proceed under any circumstances until KYC is fully satisfied.

15. Internal Responsibilities

For comprehensive information on our AML/CTF governance structure, see our AML & CTF Statement.

15.1 AML/KYC Compliance Officer

Responsible for:

  • Reviewing high-risk cases
  • Approving complex structures
  • Filing STR/SAR reports (see AML & CTF Statement for reporting procedures)
  • Ensuring policy compliance

15.2 Senior Management

Responsible for approving:

  • High-risk clients
  • Clients from high-risk jurisdictions
  • PEP clients
  • Unusual activities

15.3 All Employees

Every employee is responsible for:

  • Identifying red flags
  • Reporting suspicious activity
  • Maintaining integrity and compliance

16. Client Obligations

Clients must:

  • Provide accurate and complete information
  • Submit KYC documents promptly
  • Disclose changes in structure or ownership
  • Cooperate with verification requests

Failure to do so may delay or halt services.

17. Updates to This Policy

AURNÉ will update this policy to reflect:

  • Legal changes
  • FATF updates
  • MOE instructions
  • Internal compliance improvements

18. Contact Information

For onboarding or KYC-related matters:

AURNÉ Private Advisory – 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.