Epiidosis Global Finance LLC-FZ (“Epiidosis,” “the Company,” “we,” or “our”) is committed to the highest standards of integrity, regulatory compliance, and the prevention of financial crimes. This AML & Compliance Policy provides a comprehensive framework for detecting, preventing, and reporting money laundering, terrorist financing, and other financial crimes.

This policy is applicable to all employees, management, contractors, agents, and third parties engaged by Epiidosis Global Finance in any capacity.

1. Purpose and Scope

The purpose of this Policy is to:

• Establish robust procedures for the detection and prevention of money laundering and terrorist financing.
• Ensure compliance with UAE Federal Laws, including Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations (AML Law).
• Adhere to guidelines and circulars issued by the UAE Central Bank and the Meydan Free Zone Authority.
• Align with international standards, including the Financial Action Task Force (FATF) Recommendations.

This Policy covers:

• Customer onboarding and verification procedures.
• Risk-based monitoring and reporting of transactions.
• Employee responsibilities and training requirements.
• Internal governance, oversight, and audit processes.

2. Regulatory Framework

2.1 UAE AML Law

Establishes legal obligations for financial institutions and designated non-financial businesses and professions (DNFBPs) regarding:

• Customer due diligence (CDD) and enhanced due diligence (EDD)
• Record-keeping and reporting of suspicious transactions
• Implementation of internal AML controls

2.2 FATF Recommendations

Require adoption of a risk-based approach to AML/CFT compliance, continuous monitoring, and reporting.

2.3 Meydan Free Zone Authority Requirements

Enforce additional operational mandates and reporting procedures within the free zone jurisdiction.

3. AML Compliance Governance

3.1 AML Compliance Officer (AMLCO)

The Company appoints a qualified AML Compliance Officer (AMLCO) responsible for:

• Overseeing compliance with all AML/CFT policies and procedures.
• Monitoring and analyzing transactions to detect suspicious activities.
• Filing Suspicious Transaction Reports (STRs) with the UAE Financial Intelligence Unit (FIU) in a timely and confidential manner.
• Conducting mandatory AML training for all employees.
• Serving as liaison with regulatory authorities for audits, inspections, and inquiries.

3.2 Board and Senior Management Responsibilities

• Approve, review, and update the AML & Compliance Policy periodically.
• Allocate adequate resources, including staffing and technology, for effective AML compliance.
• Foster a culture of compliance and ethical conduct throughout the organization.
• Ensure all employees understand their role in AML and CFT compliance.

4. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

4.1 Customer Identification Program (CIP)

Prior to establishing any business relationship, the Company performs thorough due diligence, including:

• Verification of client identity using government-issued ID, passport, or corporate documentation.
• Identification and verification of Ultimate Beneficial Owners (UBOs) for corporate clients.
• Verification of the client’s source of funds and wealth using financial statements, bank records, or other relevant documentation.
• Assessment of the purpose and nature of the business relationship.

4.2 Risk-Based Approach

Clients and transactions are risk-assessed as Low, Medium, or High based on:

• Jurisdiction risk (e.g., high-risk countries or sanctioned regions).
• Client type (individual, corporate, or politically exposed persons (PEPs)).
• Nature, purpose, and expected volume of transactions.
• Historical behavior and patterns of financial activity.

4.3 Enhanced Due Diligence (EDD)

Applied to high-risk clients or situations, including:

• Politically Exposed Persons (PEPs), their family members, and close associates.
• Clients from high-risk or sanctioned jurisdictions.
• Complex corporate structures, trusts, or layered ownerships.
• Transactions with unusual patterns or suspicious characteristics.

EDD measures include:

• Additional verification of identity, source of wealth, and business rationale.
• Senior management review and approval before onboarding.
• Ongoing enhanced monitoring of transactions and relationship activities.

5. Ongoing Monitoring and Record-Keeping

• Continuous monitoring of transactions against customer profiles to detect suspicious or unusual activity.
• Use of automated and manual monitoring systems for threshold alerts.
• Immediate investigation and documentation of flagged transactions.
• Retention of all AML-related records for a minimum of 5 years after termination of the relationship, in compliance with UAE regulations and FATF guidelines.

6. Suspicious Transaction Reporting

• Employees must report any suspicious activity immediately to the AMLCO.
• AMLCO evaluates and determines whether a Suspicious Transaction Report (STR) should be submitted to the UAE FIU.
• Strict confidentiality is maintained for both the reporting individual and the details of the report.
• Reports are made in compliance with legal and regulatory obligations to prevent tipping-off or interference with investigations.

7. Training and Awareness

• Mandatory AML/CFT training for all employees during onboarding and at regular intervals.

Training modules include:

• Regulatory requirements (UAE AML Law, FATF, free zone directives).
• Identification of red flags for money laundering and terrorist financing.
• Reporting obligations and internal escalation procedures.
• Annual reviews of training effectiveness and maintenance of training records.

8. Sanctions and Watchlist Screening

• All clients, counterparties, and transactions are screened against updated sanctions and watchlists:

  • United Nations (UN) Security Council sanctions
  • US Office of Foreign Assets Control (OFAC)
  • European Union (EU) sanctions lists
  • UAE Central Bank and relevant local authorities

• Immediate escalation, refusal, or termination of business relationships is implemented for confirmed matches.

9. Risk Assessment and Independent Audit

• Conduct annual AML risk assessments to evaluate internal controls and identify emerging threats.
• Engage independent auditors or compliance consultants to review AML programs and adherence to UAE and international laws.
• Implement corrective actions and process improvements based on audit findings.

10. Confidentiality and Data Protection

• All AML-related information is handled with strict confidentiality and shared strictly on a “need-to-know” basis.
• Data protection measures comply with UAE PDPL, GDPR (if applicable), and international best practices.
• Information may be shared with regulatory authorities only as legally mandated.

11. Consequences of Non-Compliance

• Violation of AML policies may result in disciplinary actions, including termination of employment or contractual relationships.
• Legal actions under UAE law may apply for breaches or facilitating money laundering or terrorist financing.
• The Company reserves the right to refuse or terminate client relationships for failure to comply with AML requirements.

12. Contact Information

For any questions, reports, or inquiries related to AML compliance, you may contact:

• AML Compliance Officer (AMLCO)
  • Email: aml@epiidosisglobalfin.com
  • Phone: +971 52398 1350

Postal Correspondence:

AML Compliance Officer Epiidosis Global Finance LLC-FZ Meydan Grandstand, 6th Floor Meydan Road, Nad Al Sheba Dubai, U.A.E.

For submission of formal letters, verification documents, or identity confirmation in relation to AML matters.

13. Policy Review and Updates

This AML & Compliance Policy is reviewed at least annually or whenever there are changes in regulations, FATF recommendations, or internal risk assessments.

Updates are communicated to staff, management, and relevant stakeholders to ensure continuous compliance and effectiveness.