• GCC Exchange is committed to the fight against money laundering and terrorist financing. As an organization that operates in different countries with different legal environments and exposed to a wide variety of cultures, offering remittance products and services to thousands of customers globally, GCC Exchange recognizes its obligation to join with governments, regulators, international organizations and other financial service organizations to close off the financial channels that money launderers and terrorist organizations use for their illicit purposes.
• GCC Exchange's policy is to conduct business in compliance with all applicable laws and regulations and stop criminals from using our products and services for the purpose of money laundering or terrorist funding.
• GCC Exchange prohibits remittances to charitable and religious organizations, societies and other Non - Profit Organizations.
• GCC Exchange's cooperation to regulators is in its entirety wherein it aims to maintain the highest operating standards to safeguard the interest of its customers, shareholders, employees, and the communities where it operates. In conducting business with due diligence, care, and skill, GCC Exchange always seeks to comply with relevant laws, rules, regulation, codes, and standards of good practice both in letter and spirit.
• GCC Exchange aims to promptly address any irregularities that may arise, as it believes in transparency in its financial and regulatory reporting with swift disclosure of any breaches.
• GCC Exchange Anti-Money Laundering & Combating Terrorist Financing Policy (GCC Exchange AML & CTF Policy) is a guide for detection and prevention of money laundering and terrorist financing.

This document is part of a framework comprising the Policy for GCC Exchange globally, and Procedures for each country based on the local regulations. These together will outline the minimum standards that must be followed by GCC Exchange in combating money laundering and terrorist financing.

GCC Exchange AML & CTF Policy Framework is based on the following two layers:

The main purpose of the Policy is to establish the essential standards designed to prevent GCC Exchange from being used for money laundering and terrorist financing. In simple words, money laundering is a process of cleaning the dirty money into clean money. The rationale, therefore, would be to reflect the global resolve to prevent and fight money laundering and terrorist financing activities, by establishing principal standards to protect GCC Exchange from being used to launder money or fund terrorists.

In the light of the above, the objectives of GCC Exchange AML & CFT Policy are listed below:

• Enable GCC Exchange to conduct clean, commercial business, conforming to the standards set by the local regulatory authorities.
• To comply with applicable laws and regulations in the respective countries with reference to Anti Money Laundering and Combating Financing of Terrorism.
• To follow, without exception, the internationally accepted standards used for Anti Money Laundering and Combating Financing of Terrorism.
• To report suspicious transactions to the respective regulatory authority upon detection.

Adherence to GCC Exchange AML & CFT Policy is absolutely fundamental for ensuring that GCC Exchange across the globe, regardless of geographic location, fully comply with applicable Anti-Money Laundering legislation. GCC Exchange is always committed to examine its Anti-Money Laundering strategies and objectives on an ongoing basis and maintaining an effective AML & CFT Policy for conducting the business.

GCC Exchange follows a Risk Based Approach grading each customer and transaction into different Risk Grades based on preset criteria in the Core Software system to fight Money Laundering. Based on the Risk category of each customer and category we will conduct the adequate level of Due Diligence to mitigate any threat of Money Laundering. Higher the risk higher the Due Diligence. Identification of the money laundering and terrorism financing risks of customers and their transactions allows us to determine and implement proportionate measures and controls to mitigate these risks.

Broadly we can divide the various Risks faced into the following Headings:

• Customer Risk
• Product Risk
• Counterparty Risk
• New Technology Risk
• Jurisdictional Risk or Country Risk
• Delivery Channel Risk or Interface Risk

As a financial institution, GCC Exchange identifies and understands the potential risks of Money Laundering and Terrorism Financing within the institution and shall have appropriate processes to mitigate, and ultimately alleviate, such risks. GCC Exchange also continually evaluates the strength of the existing policies and procedures and update them, as necessary. GCC Exchange shall have processes in place to assist governments in their efforts to identify terrorist funds.

• The Board of Directors of GCC Exchange LLC has appointed a Senior CAMS Certified Designated Compliance Officer who is responsible for coordinating and overseeing the AML/CFT framework within the organization. The appointment of the designated compliance officer is approved by the Central Bank of UAE. The Designated Compliance officer reports directly to the Board of Directors and is the sole coordinator on compliance matters to Central Bank of the UAE and UAE Law Enforcement Authorities. The company has also appointed an Alternative Compliance officer and team of well-experienced and specialized Compliance Executives to support the functions of Compliance Departments.

• GCC Exchange policies against Money Laundering and Terrorism Financing are to ensure that all reasonable and practical measures are taken to identify customers.
• We have a clear identity verification procedure for customers as per local and international AML/CFT regulations.
• All identity documents are physically verified and copy of the same will be retained whenever required. The validity of the identity documents are checked before acceptance

• Customer Due Diligence (CDD) is a process of obtaining relevant details of the customer to ensure that they conduct the transactions in line with their personal profile / business activities; thus, ensuring source of fund and purpose are legitimate as well as to ensure that the transaction is in any way not related to Money Laundering and Terrorist Financing.

• Enhanced Due Diligence is to take additional measures, besides usual Customer Due Diligence, to know more about a customer and to confirm the source and purpose of the transaction along with the required documents detailing the same.

• In GCC Exchange, an automated real-time screening of all parties involved in transactions is performed against the lists, to check and ensure that customer's name does not appear in any list of known Specially Designated Nationals (SDN) or suspected terrorists or terrorist organizations or even PEP's or their close relatives and associates.
• GCC Exchange always rely and maintain awareness on the official website of UNSC Consolidated list and UAE National List. Both lists are updated periodically by adding, deleting, and amending. The Exchange has already subscribed to the official website of the Committee of UAE for Goods and Material Subjected to Import and Export Control (IEC) to receive updates of these two lists. Additionally, we have also contracted with “Dow-Jones” and connected via API with their core software system. The internal watchlist is also maintained by GCC Exchange based on notices issued from various departments of the Government which are updated manually on the information being received.

GCC Exchange has implemented the comprehensive AML - CFT Training program to all employees including to the Senior Management and Board of Directors. The top management of the company strongly believes that effective AML Training will help the company to develop a good corporate governance within the Organization.

GCC Exchange AML-CFT Training materials includes:

• Overview of Money Laundering and Combating Financing of Terrorism.
• Definition of Money Laundering, Terrorism Financing, and typologies as well as recent trends.
• AML / CFT Requirements of The Central Bank of UAE.
• Risk associated with the products and services offered by the company.
• KYC / KYCC policies, EDD and RBA.
• How to identify suspicious activities and transactions.
• Record-keeping and reporting requirements.
• Familiarity with Anti-Money Laundering forms.
• Employees legal obligation and responsibilities.
• Anti-Money Laundering and Combating Financing of Terrorism training is part of the compliance program and training is provided to all new staff and existing staff regarding updates in AML/CFT Policies & Procedures.

• GCC Exchange outlines the procedures to help employees to detect and report suspicious transactions. In the case of a suspected transaction, the staff members should be vigilant and provide information to the Branch Compliance Officer, Branch Manager or Compliance Department for further action without jeopardizing the reputation of customers or the company.

• Record-Keeping ensures that the company is able to provide basic information about its customers at the request of relevant authorities. GCC Exchange shall immediately make available any or all their books and records upon request by Central Bank or any other regulatory agencies.
• All the records / documents of transfers should be kept for a minimum period of 5 years from the date of transaction.
• GCC Exchange shall always maintain the confidentiality of information indicated in the transaction records.

• It is extremely important that employees of GCC Exchange thoroughly understand the requirements of AML - CTF requirements. GCC Exchange can be successful only if its employees ensure that the organization complies with all laws and regulations. The employees should understand that GCC Exchange AML & CTF Policy and country specific AML - CTF Procedures are of paramount importance and takes precedence over other commercial aspects of managing business and customer relationships.
• It is important to remember that security and legal compliance are everyone's responsibility. The penalties for non-compliance are severe, and ignorance or confusion about the regulations and laws is not a defense.
• It is a legal and the company requirement that continuous monitoring and analysis takes place to identify unusual and suspicious transactions.
• The penalties for violations of the government regulations and AML - CTF laws, are severe, and under certain circumstances, may be assessed against the location and/or its individual employees. The violations may cause loss of customer goodwill and unfavorable publicity, as well as civil and criminal penalties.
• All Employees are made aware that liability may be imposed on them if the employee is willfully blind to suspicious activity or knew information that he / she “should have known” was suspicious.

• Every employee of GCC Exchange has compliance and operational risk related obligations that vary according to their job. Non-compliance with the obligations set out in this policy may be considered as a breach. A breach of this policy may result in disciplinary action and could include dismissal if the breach is serious.
• If an employee is aware of or believes another employee is not complying with this policy, the employee should inform it to the Reporting Official/Compliance Officer. It is the responsibility of each employee of GCC Exchange to understand how this policy applies to them. If an employee is uncertain about any clause in this policy or situations in which it shall apply, the employee shall seek guidance/clarification from the reporting official/Compliance Officer.
• Any employee that violates this policy, either unknowingly or intentionally may be subject to disciplinary action, including but not limited to, termination of employment. GCC Exchange will support its employees to achieve the highest standards of compliance integrity. Employees must be aware of GCC Exchange's commitment to preventing money laundering and terrorist financing and their own obligations under the policies set down.

• Money laundering and terrorist financing pose a serious threat to the society and to the soundness of the international financial system. Combating these threats requires a coordinated and co-operative approach. Remaining diligent and combining our efforts are the two pre-requisite conditions to successfully meet the challenges ahead.
• Financial institutions around the world are increasingly recognizing the importance of implementing and maintaining adequate controls and procedures to ensure that on a reasonable and practicable basis they know with whom they are conducting business. The consequences of any lack of vigilance in this area can be severe. Facilitating a financial transaction while willfully or recklessly disregarding the source of a customer's funds or the nature of a customer's transaction can result in criminal and/or civil liability for the employee and/or GCC Exchange.
• Money laundering and Terrorist Financing pose a great threat to the international economy and therefore, the demand for regulatory compliance is growing rapidly day by day. Managing reputation risk and legal risk are of topmost priority in the financial industry. Money laundering not only harms the public as a whole, but it taints the financial services industry. It clearly is in the best interests of the financial industry to take all feasible action to prevent money laundering. Therefore, GCC Exchange recognizes the need to work together and cooperate to fight against the challenges posed by this social evil.