LALIRA DMCC (hereinafter “LALIRA”) is committed to highest standards of Anti- Money Laundering (AML) and Countering of Terrorist Financing (CTF) measures. The members of the Board, Senior Management and all employees are required to adhere to these standards to protect LALIRA and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes. The UAE is a member country of the Financial Action Task Force (FATF) by virtue of being a Gulf Cooperation Council (GCC) member. The UAE is also a member state of the United Nations (UN) and Arab League and has enacted laws and regulations designed to implement the anti-money laundering and CTF policies in line with FATF, UN and Arab League regulations. The aim of these regulations is to detect and prevent money laundering and potential terrorist financing. We have therefore implemented robust AML and compliance practices.

Anti-Money Laundering Compliance Policy Declarations
LALIRA is 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.
LALIRA is also determined to constantly evaluate and uphold its AML policies, procedures and controls on an on-going basis by ensuring befitting internal and external audit program.
LALIRA adheres to the four pillars of an effective AML program:

• Development of internal policies, procedures and related controls
• Designation of a compliance officer
• A thorough and ongoing training program
• Independent review for compliance.

Know Your Counterparty (KYC)
We follow a strong identity verification process for all our counterparties as per local and international AML/CTF regulations.
Robust KYC policies are adhered to at all levels of the organization. Identifying and conducting Counterparty Due Diligence (CDD) and Enhanced Due Diligence
(EDD) wherever required is a normal process at LALIRA for identifying any sign of money laundering.

Counterparty Due Diligence (CDD)
In our CDD process, we obtain relevant details of every counterparty to ensure that the activity 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 business activities.


Enhance Due Diligence (EDD)
EDD is to perform additional measures, besides the usual CDD, to know more about the counterparty, his source of funds and to confirm that the activity are within its 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. LALIRA adopts a risk-based approach to identify and eliminate potential risks. Hence EDD is compulsorily performed on all high-risk counterparties.

Sanctions Screening
To ensure compliance with the applicable sanctions against persons and entities, LALIRA has instruments to screen the names of the customers against the sanctions lists issued by the UN Security Council (UNSC), The Office of Foreign Assets Control (OFAC), The Office of Financial Sanctions Implementation (OFSI) the list issued by European Union (EU), and the local terrorist list issued by the UAE Supreme Council for National Security. Along with the customers’ names, all the parties are also filtered through the screening system in order to ensure compliance with sanctions obligations.

Activity Monitoring
LALIRA ensures that there is an ongoing activity monitoring to detect behaviour which is unusual or potentially suspicious based on the customer profile/ behaviour. The front line employees acts as a first line of defense and are empowered to escalate any unusual behaviour through internal channels. This process is supplemented by an extensive review of the activity at the second line
of defense including increased monitoring of the customer’s activity and behaviour.

Reporting of Unusual or Suspicious Activity
All our staff are trained and equipped to report unusual or potentially suspicious activity through our internal channels to the compliance officer. The compliance officer, conducts an in-depth investigation and takes appropriate action before reporting such activity to the Financial Intelligence Unit (FIU).

Staff Training
We at LALIRA strongly believe in empowering our employees 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 at their joining LALIRA, with follow-up trainings conducted annually.

Record Keeping & Confidentiality
All records including the customer’s identification documents, related data and any other relevant document are maintained and retained for a minimum of five years. This is in line with the regulations of the Central Bank of the UAE. LALIRA shall always maintain the confidentiality of information provided by its customers and their records.

Independent Review of the Compliance & AML Department
Compliance & AML function is subject to reviews by Internal Audit, the Central Bank of the UAE examiners as well as independent external auditors. This ensures that the compliance program is always up-to-date and is meeting all the regulatory requirements.