HIGH-TECHS L.L.C. ("we", "the Company") is committed to preventing money laundering, terrorist financing and sanctions evasion. This Policy sets out the controls we apply to comply with applicable anti-money-laundering (AML) and counter-terrorist-financing (CTF) laws, the FATF standards and applicable UAE AML/CTF law. We do not knowingly enter into business with anyone involved in criminal activity.
This Policy applies to all directors, employees, contractors and the onboarding of all customers ("Investors") and their transactions on the Platform.
We assess and rate the money-laundering risk of each customer and product, considering geography, customer type, transaction size and channel. The level of due diligence and monitoring is proportionate to the assessed risk (low / medium / high).
Before an Investor can transact, we verify identity using reliable, independent sources. We collect and verify at minimum:
We apply additional checks for higher-risk cases, including Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, and unusually large or complex transactions. EDD may include senior-management approval, extra source-of-funds evidence and closer monitoring.
We screen customers and, where applicable, counterparties against relevant sanctions lists (including UN, OFAC (US), EU, UK (OFSI) and UAE local terrorist lists) and PEP databases at onboarding and on an ongoing basis. We do not provide services to sanctioned persons or to prohibited jurisdictions, including the United States and its territories and any country or region subject to comprehensive sanctions (such as North Korea, Iran, Syria, Cuba, and the Crimea, Donetsk and Luhansk regions).
We monitor activity for the duration of the relationship to detect transactions that are inconsistent with our knowledge of the customer. We keep customer information up to date and re-verify periodically based on risk.
Automated and manual controls flag suspicious patterns, such as: structuring to avoid thresholds, funds inconsistent with stated profile, rapid movement of funds, use of anonymising tools, or reluctance to provide information. Flagged activity is escalated for review.
Where we know or suspect money laundering or terrorist financing, our MLRO files a Suspicious Activity / Transaction Report (SAR/STR) with the UAE Financial Intelligence Unit (FIU) and complies with any "no tipping-off" rules. We cooperate with lawful requests from regulators and law enforcement.
We appoint a Money Laundering Reporting Officer (MLRO), reachable at compliance@high-techs.net, who is responsible for this Policy, reporting and liaison with authorities. Senior management is accountable for maintaining an effective AML/CTF programme.
We retain KYC records, transaction data and reports for at least 5 years after the end of the relationship or the transaction, as required by law, and make them available to authorities on lawful request.
Relevant staff receive AML/CTF training at onboarding and periodically thereafter, covering red flags, obligations and reporting procedures.
We may refuse, suspend or terminate any account, and withhold funds, where required to comply with AML/CTF or sanctions obligations. Breaches by staff are subject to disciplinary action.
AML/compliance queries: compliance@high-techs.net.