WealthAxis Advisory FZ-LLC (“WealthAxis”) has adopted and shall implement this Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy to prevent, detect, and deter the misuse of its services for money laundering, terrorist financing, fraud, or other financial crimes. This policy is consistent with UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering, Cabinet Decision No. 10 of 2019, all relevant resolutions issued by the competent UAE authorities, and recommendations of the Financial Action Task Force (FATF).
WealthAxis is aware of its obligations as an investment advisory firm to protect the integrity of the financial system and to maintain public and regulatory confidence. This policy provides a comprehensive framework of internal controls, procedures, and governance structures to identify, assess, mitigate, and manage AML and KYC risks. This policy is mandatory for the entire organization. Ethics, compliance, and a zero-tolerance policy against any illicit financial activity provide the bedrock for this framework. Improvements are an essential part of its effective implementation.
This AML & KYC Policy is universal and applies to all clients, prospective clients, transactions, advisory services, employees, directors, officers, contractors, and associated persons of WealthAxis. The policy applies to both individual and corporate clients and is applicable to both domestic and international business relationships.
This policy applies to all third-party introducers, intermediaries, and outsourcing service providers acting on behalf of WealthAxis and is subject to the same standards. The policy is continuous and risk-based, requiring a review of applicability whenever there is a change in circumstances. The policy applies to all business units, regardless of function or level, and must be adhered to. There are no exceptions to the policy and it is not applicable in any circumstances.
WealthAxis has a structured AML governance framework in place to ensure accountability, control, and effective implementation of AML and KYC measures. The ultimate responsibility for compliance with relevant AML laws and regulations rests with the company’s senior management. A Compliance Officer is appointed to supervise the implementation of AML and KYC measures on a day-to-day basis.
Responsibilities are well defined, documented, and communicated within the organization. The AML governance framework has escalation mechanisms for risks and suspicious transactions identified. The independence of the compliance function is maintained to ensure objectivity in the oversight function. The reporting structure enables effective communication to the senior management, which receives periodic updates on AML risks and compliance. Sufficient financial, technical, and human resources are dedicated to sustain the framework, and its effectiveness is reviewed periodically to mitigate risks.
Customer Due Diligence (CDD) is an integral part of the AML strategy implemented by WealthAxis and is carried out before any business relationship is established. CDD is a process of verifying the identity of the client, understanding the nature and purpose of the relationship, and evaluating the related risks of money laundering and terrorist financing.
The information gathered has to be accurate, reliable, and obtained from independent and credible sources whenever possible. Higher-risk clients are subject to Enhanced Due Diligence, while Simplified Due Diligence is carried out only if allowed by relevant laws and after documented risk assessments. CDD is proportionate to the risk level identified and is carried out on an ongoing basis to ensure that information is up to date. Unsatisfactory completion of CDD leads to refusal or termination of services.
WealthAxis performs the verification of the identity of all clients using valid, official, and reliable documentation before offering advisory services. For individual clients, they are required to provide identification and proof of residential address. For legal entity clients, they are required to provide incorporation documents, constitutional documents, ownership structures, and authorized signatory details.
Ultimate beneficial owners are identified and verified in accordance with regulatory requirements. The verification is done using independent and trustworthy sources, and the documents must be up-to-date, readable, and genuine. If permitted by law, electronic or digital verification processes can be used. The identity verification process must be done before engagement, and all documents are stored safely.
WealthAxis also ensures the identification and verification of the ultimate beneficial owners of all legal entity clients to ensure transparency and avoid the possibility of hiding ownership. The beneficial ownership thresholds and definitions are considered in accordance with the relevant UAE regulatory guidance.
The ownership and control structures, voting rights, nominee ownership, and indirect ownership chains are also analyzed. The complex and opaque ownership structures are also subject to rigorous review. The beneficial ownership information is also documented, verified through credible sources, and continuously monitored. Failure to identify the beneficial owners will result in the refusal to onboard or continue services. Transparency is required, and hiding ownership is not tolerated.
WealthAxis takes a risk-focused approach to categorize clients based on their risk of money laundering and terrorist financing. The risk assessment takes into account factors such as jurisdiction, type of business, ownership, transaction patterns, delivery channels, and political risk.
The risk categorization of clients is done at the time of onboarding and also on a periodic basis. High-risk clients are subjected to Enhanced Due Diligence and intense monitoring. As soon as there is a material change in circumstances, the clients are reassessed immediately. The risk assessment approach is well-documented, consistent, and made on conservative assumptions in case of incomplete information. High-risk relationships also require approval from senior management, and the risk categorization decides the intensity of monitoring and control.
WealthAxis uses Enhanced Due Diligence on all cases involving Politically Exposed Persons (PEPs), their relatives, and close associates. PEP identification involves both local and international political connections.
Source of wealth and source of funds are evaluated to reduce the risk of corruption, reputation, and regulatory issues. Approval from the senior management is mandatory before engaging in any business with PEPs. Enhanced risk monitoring is used throughout the relationship, and periodic review of PEP status is done. PEPs are not automatically excluded from business; however, tight controls, documentation, and constant vigilance are required.
WealthAxis performs continuous monitoring of client relationships to ensure that they are consistent with the client’s known profile, risk category, and expected behavior. The monitoring process involves reviewing advisory activities, transaction behavior where appropriate, and periodic updates of client information.
Unusual or inconsistent patterns are quickly identified, investigated, and recorded. The level of monitoring is commensurate with risk and may be done through automated processes or manual reviews. Escalation procedures are relevant where concerns are raised. Continuous monitoring is critical for effective AML compliance.
WealthAxis is mandated to report suspicious transactions or behavior to the concerned authorities in the UAE as per the prevailing laws. Suspicion may arise due to unusual activity, inconsistencies, or deviations from expected behavior.
Employees are expected to report their suspicions internally to the Compliance Officer promptly. Reporting is done in a timely, accurate, and confidential manner, and the prohibition on tipping-off is strictly adhered to. The Compliance Officer uses his discretion to determine reportability based on legal thresholds. Reporting is done while maintaining confidentiality, and legal safeguards apply to good-faith reporting. Reporting supersedes client confidentiality as mandated by law.
WealthAxis holds AML and KYC records in compliance with the relevant legal and regulatory requirements for record retention. The records held include identification documents, due diligence information, risk assessments, monitoring information, and suspicious transaction reports.
The records are accurate, complete, secure, and easily accessible for audit or regulatory purposes. The records are only accessible to authorized personnel. Secure storage methods are in place, and confidentiality and integrity of the records are maintained throughout the retention period. The records are disposed of securely when they expire.
WealthAxis holds AML and KYC records in compliance with the relevant legal and regulatory requirements for record retention. The records held include identification documents, due diligence information, risk assessments, monitoring information, and suspicious transaction reports.
The records are accurate, complete, secure, and easily accessible for audit or regulatory purposes. The records are only accessible to authorized personnel. Secure storage methods are in place, and confidentiality and integrity of the records are maintained throughout the retention period. The records are disposed of securely when they expire.
WealthAxis offers all relevant employees extensive training on AML and KYC to ensure they are aware of the legal requirements, risk factors, and reporting procedures. Training includes relevant laws, policies, risk factors, procedures, and updates.
Refreshers are held from time to time based on risk exposure. New employees are trained on AML as part of their induction program. Training results are measured, and attendance is mandatory. Records are maintained for audit purposes. Senior management is actively involved in AML training programs.
WealthAxis undertakes an independent review of its AML/KYC framework on a periodic basis to evaluate its effectiveness and regulatory compliance. The review can be carried out internally or through external auditors, depending on the regulatory requirements and risk factors.
The review encompasses governance, processes, controls, and their implementation. The results are recorded and presented to the top management, and remedial measures are taken within stipulated timeframes. Independence and impartiality are maintained, and audit trails are recorded to ensure accountability and improvement.
However, failure to comply with the AML and KYC requirements will attract serious legal, regulatory, and reputational repercussions for WealthAxis and the individuals involved. The repercussions include fines, sanctions, license revocation, or criminal charges as stipulated by law.
WealthAxis adopts a zero-tolerance policy towards this matter. Employees who violate this policy will be subject to disciplinary measures, including dismissal. Business relationships will not be established or will be severed if the AML risks cannot be mitigated. Legal and regulatory requirements will take precedence over business considerations.
