Avanor · Legal
Anti-Money Laundering & Counter-Terrorist Financing Policy
Avanor Technologies L.L.C-FZ (“Avanor”) is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) controls. Our Board, senior management and all employees are required to uphold these standards in order to protect Avanor and its reputation from being misused for money laundering, terrorist financing or any other unlawful purpose.
01Regulatory Framework
As part of the United Arab Emirates — a member of the Financial Action Task Force (FATF) through the Gulf Cooperation Council (GCC), and a member state of the United Nations (UN) and the Arab League — Avanor operates under laws and regulations designed to give effect to AML and CTF standards consistent with FATF, UN and Arab League requirements. These measures are aimed at detecting and preventing money laundering and potential terrorist financing, and we have implemented robust AML and compliance practices accordingly.
Avanor adheres to the relevant recommendations of the FATF and to the Basel Statement of Principles on the prevention of the criminal use of the banking system, issued by the Basel Committee. We continuously evaluate and maintain our AML policies, procedures and controls through appropriate internal and external audit programmes.
02The Four Pillars of Our AML Programme
Avanor’s programme is built on the four pillars of an effective AML framework:
- The development of internal policies, procedures and related controls.
- The designation of a dedicated compliance officer.
- A thorough and ongoing training programme.
- An independent review of compliance.
03Know Your Counterparty (KYC)
We apply a rigorous identity-verification process to all counterparties, in line with local and international AML/CTF regulations. Robust KYC policies are observed at every level of the organisation, and the conduct of Counterparty Due Diligence (CDD) and, where required, Enhanced Due Diligence (EDD) is an established part of identifying any indication of money laundering.
Counterparty Due Diligence (CDD)
Through our CDD process, we obtain the relevant details of every counterparty to confirm that their activities are consistent with their stated profile and business. Our focus is to verify the legitimacy of both the source of funds and the underlying business activity.
Enhanced Due Diligence (EDD)
EDD comprises additional measures, beyond standard CDD, to obtain a deeper understanding of a counterparty and the source of their funds, and to confirm that the activity is within their means and not connected to criminal proceeds. We obtain authentic and genuine documentation supporting both the underlying and the stated purpose of the relationship. Applying a risk-based approach, Avanor performs EDD on all high-risk counterparties.
04Sanctions Screening
To ensure compliance with applicable sanctions against persons and entities, Avanor screens counterparty names against the sanctions lists issued by the UN Security Council (UNSC), the U.S. Office of Foreign Assets Control (OFAC), the UK Office of Financial Sanctions Implementation (OFSI) and the European Union (EU), as well as the local terrorist list issued by the UAE Supreme Council for National Security. All relevant parties — not only the named customer — are filtered through our screening systems to ensure our sanctions obligations are met.
05Ongoing Activity Monitoring
Avanor maintains ongoing monitoring of activity to detect behaviour that is unusual or potentially suspicious in light of a customer’s profile and conduct. Front-line employees act as the first line of defence and are empowered to escalate unusual behaviour through internal channels. This is reinforced by an extensive second line of defence, including heightened monitoring of customer activity and behaviour.
06Reporting Unusual or Suspicious Activity
All staff are trained and equipped to report unusual or potentially suspicious activity to the compliance officer through our internal channels. The compliance officer conducts an in-depth investigation and takes appropriate action before reporting such activity to the Financial Intelligence Unit (FIU).
07Staff Training
We believe in empowering employees at every level, and effective AML training is central to building sound AML/CTF governance across the organisation. New employees are trained on our AML policy and procedures upon joining Avanor, with follow-up training conducted annually.
08Record Keeping & Confidentiality
All records — including customer identification documents, related data and any other relevant documentation — are maintained and retained for a minimum of five years, in line with the regulations of the Central Bank of the UAE. Avanor maintains the confidentiality of all information and records provided by its customers.
09Independent Review
Our Compliance and AML function is subject to review by Internal Audit, by examiners of the Central Bank of the UAE and by independent external auditors. This ensures that our compliance programme remains current and continues to meet all applicable regulatory requirements.
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