1. Introduction

Purpose
This policy establishes the principles and standards for compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. It aims to mitigate risks of financial crimes and ensure Xdeel complies with all applicable legal requirements.

Scope and Application
This policy applies to all Xdeel employees, senior management, and third parties associated with Xdeel’s operations. It ensures measures are in place to prevent misuse of Xdeel’s services for money laundering, terrorism financing, or sanctions violations.

The policy is updated annually or as required based on international regulations and legislative changes.

Definitions

• Money Laundering: Concealing or disguising the origins of criminally derived funds.
• Terrorist Financing: Raising or holding funds intended for terrorism.
• Proliferation Financing: Providing funds for developing or using weapons of mass destruction.
• Sanctions: Political and economic restrictions imposed by international bodies.

2. AML Principles

Xdeel implements an AML/CTF program to ensure compliance with legal requirements and to prevent financial crimes. This program includes:

1. AML Program Components:

• Appointment of a Money Laundering Reporting Officer (MLRO).
• Risk-based customer assessments.
• Transaction monitoring and suspicious activity reporting.
• Comprehensive record-keeping and internal audits.

1. Policy Approval & Revision:

• The AML policy is approved and regularly reviewed by the Board of Directors.

1. Risk-Based Approach:

• Customer, transaction, and business risk assessments guide the implementation of preventive measures.

3. Customer Due Diligence (CDD)

Identification and Verification
Xdeel verifies the identity of its customers (individuals and businesses) to ensure their legitimacy. Steps include:

1. Confirming personal details and obtaining valid identification documents.
2. For businesses, verifying ownership, legal structure, and beneficial owners.
3. Screening customers against sanctions and watchlists.

Risk Classification
Customers are categorized as low, medium, or high risk based on:

• Geographical location.
• Nature of business.
• Transaction behavior.

Enhanced Due Diligence (EDD)
Applied to high-risk customers, EDD involves additional measures such as verifying the source of funds and enhanced transaction monitoring.

Simplified Due Diligence (SDD)
SDD is applied in low-risk cases, such as transactions involving publicly listed companies or regulated financial institutions.

4. Monitoring

Transaction Monitoring
Xdeel continuously monitors customer transactions to ensure they align with the customer’s risk profile. Key actions include:

1. Detecting unusual transaction patterns.
2. Updating customer data periodically:

• Low risk: Every two years.
• Medium risk: Annually.
• High risk: Every six months.

Internal Investigations
Suspicious transactions trigger internal investigations and, if necessary, reporting to regulatory authorities.

5. Politically Exposed Persons (PEPs)

Definition
PEPs include individuals entrusted with prominent public functions, their immediate family members, and close associates.

Measures for PEPs

1. Obtain senior management approval before establishing a business relationship.
2. Establish the source of funds.
3. Conduct enhanced and continuous monitoring of transactions.

6. Identification of Suspicious Activity

Employees must remain vigilant for activities or transactions that deviate from a customer’s normal behavior. Examples include:

• Transactions lacking business justification.
• Reluctance to provide required identification documents.
• Large or unexplained inter-account transfers.

Suspicious transactions are escalated to the MLRO for review and potential reporting.

7. Reporting Procedure

Suspicious Transaction Reports (STRs)
All employees must report suspected cases of money laundering or financial crimes to the MLRO. Reports must include:

1. Customer details.
2. Description of the suspicious transaction.
3. Supporting evidence, if applicable.

Tipping Off
Employees must not disclose to customers that their activities are being investigated or reported, as this could impede investigations.

8. Record Keeping

Xdeel maintains detailed records of customer identification, transaction history, and due diligence checks for at least five years. These records may be shared with regulatory authorities when required.

9. Staff Training

Xdeel provides regular training to all employees on:

1. AML/CTF regulations and compliance.
2. KYC procedures and identifying suspicious transactions.
3. Reporting obligations and internal procedures.

Training is conducted annually and upon onboarding for new employees.

10. Prohibited Activities and Countries

Prohibited Businesses
Xdeel does not engage with industries or activities involving:

• Drugs, arms trade, or counterfeit goods.
• Financial pyramids or shell banks.
• Businesses from prohibited industries as outlined in Xdeel’s internal policies.

Prohibited Countries
Xdeel does not process transactions involving sanctioned countries, including (but not limited to):

• North Korea, Russia, Iran, Syria, Venezuela, and Belarus.

For more detailed information, please refer to our full KYC Policy:
Download the Full KYC Policy (PDF)