1. Policy Statement

    Relocate MENA and WAY HOME are committed to conducting business with integrity and in full compliance with all applicable laws and regulations designed to combat money laundering, terrorist financing and the evasion of economic sanctions. We maintain robust policies and procedures to prevent our services from being misused for illegal or unethical purposes. This policy applies to all employees, directors, contractors and third parties acting on our behalf.

    2. Purpose

    This policy sets out the principles and procedures that Relocate MENA follows to:

    • Identify and mitigate the risk of money laundering and terrorist financing.

    • Ensure the identity of our clients and beneficial owners is verified (Know Your Customer).

    • May screen clients and counterparties against sanctions lists and adverse media.

    • Report suspicious activities to relevant authorities when required by law.

    • Maintain records in compliance with regulatory obligations.

    3. Scope

    This policy covers:

    • All business units, subsidiaries and affiliates of Relocate MENA and WAY HOME.

    • All products and services offered by our organisation, including relocation, immigration, property search and related advisory services.

    • All clients and counterparties, whether individuals or corporate entities.

    4. Regulatory Framework

    Relocate MENA complies with:

    • Relevant UAE federal laws and guidance from the Central Bank and Financial Intelligence Unit.

    • International standards, including the Financial Action Task Force (FATF) Recommendations.

    • Applicable EU and US sanctions regulations, UN Security Council resolutions and local regulations of the jurisdictions in which we operate.

    5. Risk Based Approach

    We adopt a risk based approach to AML and KYC compliance. This means:

    • Assessing the risks posed by different clients, geographies and types of transactions.

    • Applying enhanced due diligence to higher risk clients and simplified measures to lower risk situations.

    • Reviewing and updating our risk assessment regularly to reflect evolving threats.

    6. Customer Due Diligence (KYC)

    We perform due diligence on all clients before establishing a business relationship:

    • Identification and Verification: Collecting and verifying the identity of clients and beneficial owners using reliable, independent documentation (for example passports, national ID, proof of address). For corporate clients, we obtain incorporation documents and verify the corporate structure and beneficial ownership.

    • Source of Funds or Wealth: Where appropriate, we request evidence of the origin of funds used in transactions or investments (for example bank statements, audited financials, sale contracts).

    • Enhanced Due Diligence: For clients deemed high risk (for example politically exposed persons or clients from high risk jurisdictions), we gather additional information and obtain senior management approval before proceeding.

    7. Sanctions, PEP and Adverse Media Screening

    We may screen all clients and relevant counterparties against:

    • Sanctions lists issued by the United Nations, the European Union, OFAC (United States) and the UAE (as applicable).

    • Politically Exposed Person (PEP) databases to identify individuals with prominent public functions.

    • Adverse media and law enforcement reports to detect negative involvement in financial crimes.

    If a match is identified, we evaluate the risk and decide whether to proceed, decline or report the relationship in accordance with legal requirements.

    8. Ongoing Monitoring

    Client relationships are monitored throughout their lifecycle:

    • We review client information periodically to ensure it remains current and accurate.

    • We monitor transactions (for example payments and fund transfers related to relocations) to identify unusual or suspicious activity.

    • We keep records of client data, due diligence information and transactions for at least the minimum period required by law.

    9. Reporting of Suspicious Activity

    If employees detect activity that may indicate money laundering, terrorist financing or a sanctions violation, they must promptly report it to the designated AML Compliance Officer. The Compliance Officer will determine whether a suspicious transaction report should be filed with the relevant authorities.

    10. Roles and Responsibilities

    • Board and Senior Management: Provide oversight, approve this policy and allocate resources for compliance.

    • AML Compliance Officer: Maintain and update AML and KYC policies, oversee screening and due diligence processes, review and file reports with authorities, and ensure staff training.

    • Employees and Contractors: Follow the procedures outlined in this policy, complete required training, and promptly report suspicious activities.

    11. Training and Awareness

    All employees and contractors receive AML, KYC and sanctions compliance training upon joining and at regular intervals. Training covers:

    • Money laundering and terrorist financing typologies.

    • How to conduct customer due diligence and identify beneficial owners.

    • The importance of sanctions screening and how to handle matches.

    • Reporting obligations and confidentiality requirements.

    12. Policy Review

    This policy is reviewed and updated annually or more frequently if required by changes in legislation or our risk assessment to ensure ongoing effectiveness.