Effective as of 26 September 2023
As a registered proprietary gold trader in the DMCC, Lexim Trading is dedicated to upholding strict compliance with all relevant regulations. We prioritize the integration of compliance management into our business activities and corporate culture.
POLICY STATEMENT
Lexim Trading’s Anti-Money Laundering & Counter-Terrorism Financing Policy (“AML/CTF Policy”) sets out the processes and controls to help us prevent, identify, manage and mitigate risks of us being involved in any kind of illegal activity, in particular money laundering.
Money laundering involves concealing or altering the origins of unlawfully acquired funds (referred to as "dirty" funds) to make them appear legitimate (referred to as "clean" funds). Criminals often target financial service providers, like our company, for these activities.
In response to the scale and effect of money laundering, local and international laws, including UAE FIU directives, have been designed to combat money laundering and terrorism financing.
Our AML/CTF Policy covers:
1. Customer Identification & Verification
Lexim have established controls and procedures to ensure a thorough understanding of our business partners and customers, commonly referred to as Know Your Customer (KYC). This includes the implementation of Enhanced Due Diligence (EDD) measures where our customers are identified as higher risk, such as Politically Exposed Persons (PEPs) or following a Country Risk Perception Index high risk country assessment.
2. Transaction & Ongoing Monitoring
We regularly undertake data analysis and transaction pattern examination as essential tools for risk assessment and the detection of suspicious activities.
3. Money Laundering Reporting Officer (MLRO)
Lexim appointed a MLRO who is of significant seniority, responsible for overseeing compliance with relevant legislations, regulations, rules, and industry guidance. The MLRO is supported by the Compliance Officer, both of whom report directly to the Board.
4. Risk Assessment and Mitigation
Lexim have adopted a risk-based approach to combatting money laundering and terrorist financing. This involves an accurate assessment of our business risk appetite, implementing processes and controls proportionate with identified risks and regularly reviewing these risks and the controls.
5. Record Keeping
We maintain and retain appropriate records in accordance with the UAE legally mandated timeframes.
6. Reporting of Suspicious Transactions
Lexim promptly report any suspicious activities to the Executive Office for Control and Non-Proliferation via the goAML portal.
7. Sanctions Compliance
We conduct regular screenings against sanctions lists including; United Nations, the UAE Executive Office for Control and Non-Proliferation, and Financial Action Task Force (FATF) sanctions lists.
8. Employee Awareness Training
We provide training to all employees to enhance their awareness of potential risks and compliance obligations and regularly update the team when new updates or legislation is issued.
This policy shall be reviewed annually.
