Steadfast Commercial Brokers L.L.C is committed to prevent money laundering and terrorist financing in accordance with the Central Bank of the United Arab Emirate’s regulations, Financial Action Task Force (FATF) requirements and international best practices in Anti-Money Laundering (AML) & Counter Terrorist Financing (CTF). As a result, we are prepared to identify suspicious activities related to money laundering, fraud, financing of terrorism, and financing of illegal groups and report them in accordance with the law to the Financial Intelligence Unit (FIU). Steadfast Commercial Brokers L.L.C is committed to operating legally and ethically and in accordance with all relevant laws and regulations. We have therefore implemented a robust AML and compliance system in all our branches. Our up to date information technology infrastructure and AML solutions enable us to be fully compliant at all times.
Steadfast Commercial Brokers L.L.C is fully 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.
Steadfast Commercial Brokers L.L.C 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.
Steadfast Commercial Brokers L.L.C adheres to the following robust AML / Compliance program:
We follow a strong identity verification process for all our customers as per local and international AML/CTF regulations irrespective of the amount of the transaction.
Robust KYC (Know Your Customer) and KYCC (Know your Customer’s Customer) policies are adhered to at all levels of the organization. Identifying and conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) wherever required is a normal process at Steadfast Commercial Brokers L.L.C for identifying the customer, wealth source and purpose of transaction.
In our CDD process, we obtain relevant details of every customer to ensure that the transactions 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 purpose of transaction. For all Remittances between AED 1 to AED 55,000 CDD is performed.
EDD is to perform additional measures, besides the usual CDD, to know more about the customer, his source of funds and to confirm that the transactions 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? Steadfast Commercial Brokers L.L.C adopts a risk-based approach to identify and eliminate potential risks. Hence EDD is compulsorily performed on all high-risk accounts. For all Remittances above AED 55,000 the EDD is performed.
We at Steadfast Commercial Brokers L.L.C perform both Enterprise Wide Risk Assessment (EWRA) and Customer risk assessment at three different levels like On-boarding, transaction and profile. This risk assessment helps us to identify the customers as per their risk profiling and we become more vigilant and pro-active.
To ensure compliance with the applicable sanctions against persons and entities, Steadfast Commercial Brokers L.L.C has an automated system (World Check) to screen the names of the customers against the sanctions lists issued by the Central Bank of the UAE, 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 to the transactions are also filtered through the screening system in order to ensure compliance with Sanctions Obligations.
Steadfast Commercial Brokers L.L.C ensures that an ongoing ‘Transaction Monitoring’ is conducted to detect transactions which are unusual or potentially suspicious based on the customer profile/ behavior. The front end staff acts as a first line of defense and is empowered to escalate any unusual behavior/ transactions through internal channels. This process is supplemented by an extensive review of the transactions at the second line of defense including increased monitoring of the customer’s transactions and behavior.
All our staff are trained and equipped to report unusual or potentially suspicious transactions through our internal channels to the compliance officer. The compliance officer, conducts an in-depth investigation and takes appropriate action before reporting such transactions to the Financial Intelligence Unit (FIU), at the Central Bank of the UAE.
We at Steadfast Commercial Brokers L.L.C strongly believe in empowering our employees at every level. Effective AML trainings help the company develop good AML/CTF governance at different levels within the organization.
New employees are trained on AML policy & procedures within 30 days of joining Steadfast Commercial Brokers L.L.C, with follow-up trainings conducted annually.
All records including the customer’s identification documents, related data, transaction 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. Steadfast Commercial Brokers L.L.C shall always maintain the confidentiality of information provided by its customers and their transaction records.
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.
We also perform KYE on all our staff before on-boarding them which mainly includes Police Verification, Screening and Previous Employer reference check etc.