Compliance Policy

AML, CFT, CPF & TFS Compliance Policy

Introduction

City Exchange (“CXP”) is committed to compliance with regulatory requirements and supporting efforts to combat Money Laundering (ML), Terrorist Financing (TF), Proliferation Financing (PF), and Targeted Financial Sanctions (TFS). This commitment is emphasized by our Shareholders and Management, who prioritize adherence to applicable laws, regulations, and international best practices.

Policy Statement

City Exchange reiterates its stance on Anti Money Laundering (AML), Combating Terrorism Financing (CTF), Combating Proliferation Financing (CPF), and Targeted Sanctions Compliance (TFS). We conduct our business operations in full compliance with all applicable laws, regulations, and international standards.

Commitment to Compliance

City Exchange considers the fight against ML, TF, PF, and TFS compliance a top priority. We recognize it as a collaborative effort and support regulatory and advisory bodies globally, such as FATF, OFAC, UN, EU, HM Treasury, and the Central Bank of the UAE (CBUAE). We also adhere to guidelines from the Executive Office for Control and Non-Proliferation (EOCN), which implements export control measures and curbs the proliferation of weapons of mass destruction.

City Exchange respects and follows international best practices and guidelines from organizations such as the Basel Committee, Wolfsberg Group, FATF, Middle East & North Africa Financial Action Task Force (MENAFATF), and Financial Crimes Enforcement Network (FINCEN).

Operational Jurisdiction

City Exchange operates solely within the UAE under a license from the CBUAE, offering financial services including remittance, foreign currency exchange, and wage payment via the Wages Protection System (WPS). We are legally and regulatorily obligated to design and implement robust AML, CFT, CPF, and TFS compliance policies and procedures as per the Law, Regulations, Guidelines, and the “Standards” V 1.20 Chapter 16 of the AML/CFT Compliance framework.

Risk-Based Approach

City Exchange assesses inherent risks associated with its business nature, size, and complexity. We have implemented additional AML, CFT, CPF, and TFS procedures, systems, controls, and measures appropriate to our risk profile. This thorough Risk-Based Approach (RBA) helps us identify, assess, and mitigate ML, TF, PF, and sanction evasion risks.

Compliance Management

The Owners/Board of Directors have appointed a Compliance Officer (CO) and an Alternative Compliance Officer (ACO), both approved by the CBUAE, to direct and manage our AML, CFT, CPF, and Sanctions Compliance Program. Additionally, a Manager in Charge/General Manager (GM), also approved by the CBUAE, oversees day-to-day operations. Together with the Compliance Officer, they ensure the effective implementation of our compliance and sanctions program.