1. Policy Statement and Commitment
MAVEN EDU is dedicated to preventing the misuse of its platform for money laundering, terrorist financing, or other illegal activities. The company operates under the DIEZ Freezone in the United Arab Emirates and is focused on maintaining ethical business practices while meeting all DIEZ Freezone requirements. This policy outlines the steps MAVEN EDU will take to protect its reputation and build public trust.
2. Purpose and Objectives
This policy provides a clear framework for MAVEN EDU’s employees and partners. It helps ensure the effective execution of guidelines that support company goals while ensuring compliance with regulations for Designated Non-Financial Businesses and Professions (DNFBP) in the UAE.
The key objectives include:
- Establishing clear policies regarding money laundering, terrorist financing, and the avoidance of sanctions.
- Clearly outlining compliance responsibilities for all employees.
- Offering guidance to employees in their daily business tasks in line with legal requirements.
- Promoting a workplace culture that values legal compliance.
3. Know Your Client (KYC) Procedures
MAVEN EDU will adopt strong KYC procedures, collecting and verifying identification documents and other information before onboarding any client.
For Individuals: MAVEN EDU will request personal details such as gender, date of birth, nationality, and home address. A valid and clear government-issued ID (passport, ID card, or driving license) is required and must be valid for at least six months. A valid proof of address, such as a utility bill or bank statement, no older than six months, is also necessary.
Due Diligence: All documents must be valid, not expired, in colour, with all details clearly visible and not blurry. Failing to provide the required data and information without a good explanation may raise suspicions of money laundering or terrorist financing, in which case the company may not proceed with the business relationship.
4. Internal Controls and Monitoring
MAVEN EDU will set up internal procedures to monitor client activity and identify suspicious behaviours.
- Risk-Based Approach: A dedicated risk management unit will manually review client profiles and conduct due diligence based on their risk rating. MAVEN EDU will implement a risk-based compliance program to meet its legal obligations.
- Suspicious Activity: Staff will be trained to recognize unusual patterns and escalate concerns to the compliance officer. This includes a thorough examination of complex or suspicious transactions. Any identified suspicious activity will be reported to the relevant DIEZ Freezone authority. The company does not allow informing clients about investigations.
- Record Keeping: All client records and transaction data will be kept for at least five years.
5. Enhanced Customer Due Diligence (CDD) Measures
MAVEN EDU will carry out enhanced CDD in specific high-risk situations, including:
- When a higher risk of money laundering or terrorist financing is identified.
- When a customer is a Politically Exposed Person (PEP).
- When a customer is from a country with significant shortcomings in its AML/CFT regime.
- In the case of any unusual or suspicious activity.
An essential step is to determine the source of clients' funds and wealth and verify this information with supporting evidence. Depending on the client's responses, the company may request documents such as recent pay slips, tax returns, audited accounts, bank statements, or property/business sale documents. If a client cannot provide the necessary evidence, the company might suspend their trading account or end the business relationship.
6. Employee Training and Compliance Team
MAVEN EDU will provide annual AML/CFT training for its employees. This training will cover:
- How to identify and report transactions that must be reported to government authorities.
- Examples of various forms of money laundering and terrorist financing involving the company's products and services.
- Information on internal policies for preventing money laundering and reporting suspicious activity.
A designated Compliance Officer is responsible for overseeing the AML/CFT program and its daily operations. The Risk Management team will regularly conduct compliance testing to ensure adherence to legal requirements.
7. Policy Review
This policy will be reviewed annually to ensure it remains in line with DIEZ Freezone requirements and internal business practices.