ANTI MONEY LAUNDERING(AML) 
POLICY

POLICY STATEMENT

VG Immigration Services LLC is committed to preventing money laundering and terrorist financing in accordance with the Central Bank of the United Arab Emirate’s regulations and international best practices in Anti-Money Laundering (AML) & Counter Terrorist Financing (CTF).

 

Strict adherence to the laws and regulations will protect VG Immigration Services LLC’s reputation and preserve public confidence in VG Immigration Services LLC. To this effect, we are fully geared to detect suspicious activities associated with money laundering, fraud, terrorist financing & financing of illicit organizations, and report them to the Central Bank of the UAE, as per the regulations. We are dedicated to conducting business securely with integrity and in compliance with all applicable laws and regulations.

 

Article 2 of the AML Law defines the offense of money laundering as any of the following acts done in the knowledge that the funds are derived from a crime:

 

• Transferring, moving, or conducting any transaction with proceeds with the aim of concealing or disguising their illegal source;

• Concealing or disguising the true nature, source, or location of the proceeds as well as the method involved in their disposition, movement, ownership, or rights;

• Acquiring, possessing, or using proceeds upon receipt; or

• Assisting the perpetrator of the predicate offense to escape punishment.

 

VG IMMIGRATION SERVICES LLC’S OBLIGATION

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• Identify risks to criminal acts within its business;

• Maintain a continual review of any such risks;

• Develop internal controls and policies to manage the relevant risks;

• Adopt appropriate due diligence requirements as further highlighted below; and

• Apply any United Nations (UN) directives that relate to the suppression of the financing of terrorism and proliferation of weapons of mass destruction.

 

ANTI MONEY LAUNDERING (AML) POLICY DECLARATION.

 

VG Immigration Services LLC is fully committed to adhering to the laws and regulations which reflect the relevant recommendations issued by the Financial Action Task Force (FATF) and the Basel Statement of Principles on preventing the utilization of the banking system for criminal purposes, issued by the Basel Committee. VG Immigration Services is also determined to constantly evaluate and uphold its AML policies, procedures, and controls on an ongoing basis by ensuring a befitting internal and external audit program.

 

CUSTOMER AND BUSINESS PARTNER DUE DILIGENCE

 

Foreign and local politically exposed persons (PEP), complex legal entities and third-party individual investors are examples of high-risk counterparties, which therefore require enhanced due diligence procedures.

 

CUSTOMER DUE DILIGENCE (CDD)

 

At VG Immigration Services LLC’s CDD process, we obtain relevant details of every counterparty(s) to ensure that the transactions they perform are in line with their profile or business activities. Our focus has always been to ensure the legitimacy of the source of funds and the purpose of the transaction.

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ENHANCED DUE DILIGENCE (EDD)

 

At VG Immigration Services LLC’s, we perform additional measures besides the usual CDD, to know more about the counterparty(s), and their source of funds and to confirm that the transactions are within their means. To verify that funds are legitimate and not related to any criminal proceeds by obtaining authentic and genuine documents which must support both the underlying and stated purpose. VG Immigration Services LLC adopts a risk-based approach to identify and eliminate potential risks. Hence EDD is compulsorily performed on all high-risk accounts.

 

KNOW YOUR CUSTOMERS (KYC)

 

We follow a strong identity verification process for all our counterpartie(s), as per local and international AML/CTF regulations irrespective of the amount of the transaction.

 

The purpose of the KYC procedures is to provide a mechanism through which potential counterparties can be identified and resolved in a simple, streamlined fashion, but at the same time provide a mechanism that ensures that all interested parties have been consulted *.

 

It is important for VG Immigration Services LLC to obtain such information because this process effectively mitigates the risk of being exploited for the purpose of money laundering and terrorism financing, which can be reduced to a minimum. The process would also enable suspicious transactions to be detected because they are incompatible with the information received.

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VG Immigration Services LLC is required to undertake KYC measures for all proposed transactions and business relationships. Under general KYC measures, VG Immigration Services should:

 

   (a) Verify the identity of the counterparty on the basis of original or properly certified documents, data, or information issued by or obtained from a reliable and independent source;

 

   (b) Identifying the ultimate beneficial owner, and taking reasonable measures to verify the identity of the ultimate beneficial owner such that VG Immigration Services LLC is satisfied that it knows who the ultimate beneficial owner is. For legal persons ** and arrangements, this should include VG Immigration Services LLC taking reasonable measures to understand the ownership and control structure of the counterparty. In the event of a counterparty claiming to be acting on behalf of another, it must be verified that this person has the proper legal authority to do so;

 

   (c) Seek to understand the source of wealth and source of funds; and

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VG Immigration Services LLC should apply each of the KYC measures under Items (a) to (c) above but may determine the extent of such measures on a risk sensitive basis depending on the type of counterparty, business relationship or transaction. It is recommended that measures taken should be consistent with any guidelines issued by competent authorities. For higher risk categories, VG Immigration Services LLC should perform enhanced due diligence. Records should be kept for a minimum of five years.

 

Where VG Immigration Services LLC is unable to comply with Items (a) to (c) above, it must not commence business relations or perform the transaction; and it must terminate the business relationship; and must make a suspicious transactions report in relation to the counterparty.

 

These requirements must be applied to all new counterparties

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* Internal controls such as ‘KYC form’ for use by customer-facing employee to be implemented/revised. The KYC form should cover off paragraphs (a) through (c).

** E.g., companies, partnerships, associations.

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IDENTIFICATION OF COUNTERPARTY

 

VG Immigration Services LLC is committed to establish and verify the identity of any counterparty with or for whom it acts or proposes to act. Initially VG Immigration Services LLC will adopt the following approach in establishing and verifying a counterparty’s true identity. VG Immigration Services LLC may update as appropriate any counterparty identification policies, procedures, systems, and controls having considered its risk assessment in respect of the counterparty.

 

The following list should be considered as guidance regarding the type of information and evidence which must be obtained by VG Immigration Services LLC to establish and verify the identity of a counterparty before conducting any transactions or entering any business relationships:

 

Natural Persons

(a) Full name

(b) Date of birth

(c) Nationality

(d) Legal domicile

(e) Current residential address (not a PO box)

(f) Name and address of employer or a business

(g) Approval of higher management if the customer or beneficial owner is a PEP

 

Items (a) to (g) at minimum must be obtained from the “would-be” beneficial owner.

 

Items (a) to (c) above should be obtained from a current valid passport or, under exceptional circumstances where a counterparty does not possess a passport, an official Govt. identification document which includes a photograph.

 

Documentary evidence of address (any of the following):

(a) Tenancy agreement

(b) Utility bill

(c) Letter from employer or sponsor (as the case may be) confirming residential address

 

Legal Persons and Arrangements

(a) Full business name and any trading name

(b) Registered or business address

(c) Name and address of legal representative in the UAE, if person is located outside of the UAE

(d) Date of incorporation or registration

(e) Place of incorporation or registration

(f) A copy of the certificate of incorporation or registration

(g) A copy of the articles of association or any similar documents (h) A valid commercial or professional license

(i) The identity of the directors, partners, trustees or equivalent persons with executive authority of the legal person

(j) For a trust, a certified copy of the trust deed to ascertain the nature and purpose of the trust and documentary evidence to the appointment of the current trustees

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Where identification documents cannot be obtained in original form, for example, because VG Immigration Services LLC has no physical contact with the counterparty, the counterparty should be considered high-risk, and VG Immigration Services should always obtain a copy certified as a true copy by a person of good standing such as a registered lawyer or Notary Public, a chartered accountant, a bank manager, a police officer, an employee of the person’s embassy or consulate, or other similar people.

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RECORD KEEPING & CONFIDENTIALITY

 

All records including the counterparty's identification documents, related data, transaction data, and any other relevant documents are maintained and retained for a minimum of five years. This is in line with the regulations of the Central Bank of the UAE. VG Immigration Services LLC shall always maintain the confidentiality of information provided by its customers and their transaction records.

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SOURCE OF WEALTH / FUNDS As a general rule, but particularly in the case of high-risk counterparties, VG Immigration Services LLC always obtain:

 

(a) Information regarding the origin of the funds

(b) Information regarding the structure of the funds, if loans or credit finance

(c) Information regarding the source of wealth and income

 

Where VG Immigration Services LLC is unable to obtain satisfactory evidence of Items (a) - (c) above, it must not commence business relations or perform the transaction, or it must terminate the business relationship; and should consider making a suspicious transactions report in relation to the counterparty.

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VG Immigration Services LLC only accepts payment from authorized and recognized banks.

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INDICATORS OF SUSPICIOUS

 

• Non-transparent or unusually complex ownership structure

• Counterparty and/or its funds originate from high-risk countries

• Payment in cash

• Counterparty has an unusual income (eg. the counterparty has no income or there is an inconsistency in the counterparty’s income and standard of living)

• An unusual rise in counterparty’s financial means

• Transactions are anonymous

• Use of front companies, shell companies, trusts, and other corporate structures to purchase property

• Use of complex loans, credit finance, or mortgage schemes to purchase property • Manipulation of the assets valuation (eg. successive sales on the same property at higher prices)

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SANCTIONS

 

Once the identity of a counterparty has been determined, VG Immigration Services LLC must ensure sanctions compliance by screening the counterparty on all applicable sanctions lists. This should be a mandatory process that must be followed by VG Immigration Services in respect of each counterparty prior to the establishment of a business relationship. Where VG Immigration Services discovers the counterparty appears on any applicable sanctions list, it must not commence business relations or perform the transaction; it must terminate the business relationship; and must make a suspicious transactions report in relation to the counterparty.

 

REPORTING OF UNUSUAL OR SUSPICIOUS TRANSACTION

 

All our consultants/advisors are trained and equipped to report unusual or potentially suspicious transactions.

 

STAFF TRAINING

 

We at VG Immigration Services LLC strongly believe in empowering our consultants/advisors at every level. Effective AML trainings help the company develop a good AML/CTF governance at different levels within the organization. New employees are trained on AML policy & procedures within 30 days of joining, with follow-up training conducted annually.

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