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AML/CFT Policy

Anti-Money Laundering & Counter Financing of Terrorism (AML/CFT)

Summary of Policy


Lulu International Exchange LLC. (Lulu Exchange) and its branches in the United Arab Emirates (UAE), are committed to highest standards of AML/CFT and Targeted Financial Sanctions (TFS) requirements, ensuring transparency in all its business activities. The company is regulated by the Central Bank of the United Arab Emirates and has zero tolerance for actions and activities that knowingly and/or intentionally breach AML/CFT and TFS laws, regulations, standards, and guidelines.

As a licensed financial services provider, fully committed in the prevention of money laundering and combating the financing of terrorism, and to protect its reputation, its customers, its employees, and to meet its legal and regulatory obligations, Lulu Exchange employs a Money Laundering Reporting Officer (MLRO), and an Alternate Compliance Officer (ACO), who have the responsibility to oversight compliance with relevant laws, regulations, standards, guidelines, and best practices in the UAE related to AML/CFT and TFS, and assist the company to conduct business in compliance with the following principles:


  • Comply with all the relevant UAE AML/CFT laws, regulations, standards, and guidelines and maintain written policies, procedures and systems of internal control designed to facilitate ongoing compliance with the same.
  • Establish roles and responsibilities of the Board of Directors, Senior Management, and all employees regarding AML/CFT and TFS to denote clear accountability at all levels.
  • Apply risk-based customer due diligence and strict KYC requirements, considering the risk areas associated with the type of customer, the business relationship, the products offered, the type of transactions executed, the origin of the funds, and the real or the purpose of their transactions.
  • Apply enhanced due diligence measures to customers and transactions that present a higher risk of money laundering, sanctions violation, and financing of terrorism or illegal organizations.
  • Report appropriate management information on AML/CFT matters to the Board and Senior Management of the organization.
  • Keep records related to customers and transactions as required by the local regulation.
  • Monitor continuously the customer activity to identify possible involvement in money laundering or terrorist financing, or sanctions violation using advanced analytics in automated systems.
  • Screen customers and transactions against sanctions lists issued by the United Nations Security Council (UNSC), UAE Terrorist List, the European Union (EU), the United Kingdom (HMT) and the United States (OFAC), as well as lists related to adverse media publications.
  • Require from all employees to report suspicions on any customer or his/her transactions immediately to the MLRO or ACO. The MLRO, or ACO, are responsible to investigate the suspicion and where appropriate, report the transactions to the Financial Intelligence Unit (FIU).
  • Arrange for ongoing training of employees regarding AML/CFT and their related responsibilities.
  • Co-operate with any competent authority, or law enforcement agency in the UAE, for any lawful request for information made by them.
  • Ensure that the AML/CFT function is subject to periodical review by Internal Audit and an independent external audit firm, and continuously testing the effectiveness, efficiency, and adequacy of internal policies, procedures, systems, and controls associated with combating ML/FT and TFS.


Lulu Exchange continues to work with its regulators and law enforcement agencies in UAE to develop adequate controls to combat money laundering, terrorist financing, and financing of illegal organizations in accordance with appropriate laws, regulations, guidelines, and industry standards.