(AML) & (KYC)

CAPITAL ELITE REAL ESTATE AND GENERAL CONTRACTING
Date: 1^st April 2025

Approved by: Board of Directors

Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

Purpose

CAPITAL ELITE REAL ESTATE AND GENERAL CONTRACTING is committed to upholding the highest standards of integrity and compliance in all its operations.
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines the measures taken to prevent the use of our business for money laundering, terrorist financing, or any unlawful financial activity.
We recognize our duty as a Designated Non-Financial Business and Profession (DNFBP) operating in the real estate sector of the United Arab Emirates (UAE).
Our objective is to maintain transparency, safeguard our clients and partners, and comply fully with the UAE’s legal framework.

Regulatory Framework

Our company strictly follows the UAE AML and CFT laws and regulations, including:

• Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism.

• Cabinet Decision No. (10) of 2019 concerning the implementation of this law.

• Guidelines issued by the UAE Ministry of Economy for DNFBPs.

• Requirements of the Financial Intelligence Unit (FIU) for reporting and registration in the goAML system.

We are registered with the UAE Ministry of Economy as a DNFBP.
Our internal processes and documentation are aligned with the expectations of the Central Bank of the UAE, the FIU, and the Executive Office for Control and Non-Proliferation.

Commitment to Compliance

CAPITAL ELITE REAL ESTATE AND GENERAL CONTRACTING adopts a proactive compliance culture.
We maintain written policies, employee training programs, and transaction monitoring systems designed to detect and report suspicious activities.
We cooperate with all regulatory authorities and comply with requests for information or inspection related to AML/CFT obligations.

Client Verification (KYC)

Our KYC procedures form the foundation of our AML system.
We identify and verify every client before initiating any service or transaction.

Verification steps include:

1. Collection of Identification Documents

   • Valid Emirates ID, passport, or commercial license.

   • Proof of address (utility bill, tenancy contract, or title deed).

2. Verification of Legal Capacity and Authority

   • Ensuring that the client or representative is legally authorized to conduct the transaction.

3. Source of Funds and Purpose of Transaction

   • Confirming that the funds used are derived from legitimate sources.

   • Recording the purpose of purchase, sale, or lease to identify unusual or complex transactions.

4. Sanctions and Watchlist Screening

   • Checking all clients, entities, and beneficial owners against UAE national lists and international sanctions databases (UN, EU, OFAC).

We apply enhanced due diligence (EDD) in cases involving:

• Politically Exposed Persons (PEPs).

• Cross-border or high-value transactions.

• Complex corporate structures or offshore entities.

Risk-Based Approach

We implement a structured, risk-based approach to all client relationships and real estate transactions.
Risk levels are determined through assessment of:

• Client profile and background.

• Geographic exposure.

• Nature and purpose of the transaction.

• Size and frequency of payments.

Clients are classified as low, medium, or high risk, and appropriate controls are applied accordingly.
High-risk cases undergo additional review and require management approval before proceeding.

Record Keeping

We retain all records related to client identification, transactions, and risk assessments for a minimum of five (5) years from the date of completion of the transaction or termination of the relationship.
Records are stored securely and are accessible only to authorized personnel.
Electronic records are maintained with restricted access and regular data backups.
All information is handled confidentially and shared only with regulatory authorities when legally required.

Monitoring and Reporting

We actively monitor client activity and transaction patterns to detect irregularities.
When a transaction appears suspicious or inconsistent with a client’s known profile, our compliance team conducts further investigation.
If suspicion remains, a Suspicious Transaction Report (STR) is promptly filed with the UAE Financial Intelligence Unit (FIU) through the goAML system.

Reports may include:

• Unexplained or unusually large payments.

• Structuring of transactions to avoid reporting thresholds.

• Third-party payments or transfers without clear business justification.

• Refusal to provide documentation or inconsistent information.

Under UAE law, such reports are submitted without notifying the client.

Employee Training and Awareness

All employees are trained to recognize potential signs of money laundering and to understand their obligations under UAE law.
Training covers:

• AML/CFT principles and red flags.

• KYC documentation requirements.

• Internal reporting procedures.

• Confidentiality obligations.

Refresher training is conducted annually or whenever regulatory updates occur.
Staff must immediately report any suspicious behavior or transaction to the company’s Compliance Officer.

Role of the Compliance Officer

A designated Compliance Officer oversees the implementation of AML and KYC measures.
Responsibilities include:

• Ensuring compliance with legal and regulatory requirements.

• Supervising customer due diligence and record keeping.

• Receiving and reviewing internal reports of suspicious transactions.

• Submitting STRs and other reports to the FIU through goAML.

• Coordinating employee training and audits.

The Compliance Officer reports directly to senior management and maintains independence from business operations.

Client Responsibilities

All clients of CAPITAL ELITE REAL ESTATE AND GENERAL CONTRACTING must cooperate fully with KYC and AML requirements.
Clients must:

• Provide accurate and updated identification and ownership documents.

• Disclose the source and purpose of funds.

• Update personal or business details when requested.
  Failure to comply may result in suspension or termination of services.

Confidentiality and Data Protection

All client information collected under AML/KYC procedures is kept confidential and used only for regulatory and compliance purposes.
Access to such data is limited to authorized staff.
We maintain strict data protection standards consistent with UAE privacy laws.

Continuous Review and Improvement

Our AML and KYC policies are reviewed regularly to ensure effectiveness and alignment with UAE regulations and international best practices.
We update our procedures following any change in legislation or regulatory guidance.
Independent audits and internal compliance reviews are performed to assess ongoing adherence.

Statement of Commitment

CAPITAL ELITE REAL ESTATE AND GENERAL CONTRACTING affirms its commitment to the highest standards of ethical conduct and regulatory compliance.
We strive to maintain a transparent, secure, and trusted business environment for all clients, investors, and partners.
By adhering to this policy, we support the integrity of the UAE financial system and contribute to global efforts to combat financial crime.

Approved by:

Board of Directors
Managing Director / Authorized Signatory
CAPITAL ELITE REAL ESTATE AND GENERAL CONTRACTING
Date: 1^st April 2025