AML & CFT COMPLIANCE POLICY

OVERVIEW

This Compliance Manual has been prepared aiming to update the branches of Habib Qatar International Exchange Ltd. Doha – Qatar, its officers and staffs to enable them to: Prevent and detect money laundering; Identify suspicious activities; Comply with the provisions of Law No. (20) of 2019 on ML/TF & CPF and the provisions of this Manual; and Adhere to the requirements of QCB and its QFIU, and other institutions regulating financial transactions in Qatar

Scope of Policy:

This Policy guide and the procedures mentioned herein shall be applicable at Habib Qatar International Exchange Ltd entirely including the company’s branches and its Head Office.

Services and Products:

Habib Qatar Exchange is classified as financial service institution, which renders the following services and products according to the license issued by the Qatar Central Bank. Thereupon all transactions, services and products of the company are subject to Law of Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) and the regulation thereof.

1. Selling and purchasing the foreign currencies.
2. Transferring and receiving wire transfers.

Money Laundering:

Money laundering is the illegal process of concealing the origins of money obtained illegally by passing it through a complex sequence of banking transfers or commercial transactions. The overall scheme of this process returns the "clean" money to the launderer in an obscure and indirect way.

Terrorist Financing:

The importance of combating terrorist financing Terrorists needs money and other assets, for weapons but also training, travel and accommodation to plan and execute their attacks and develop as an organization. Countering terrorism financing is therefore an essential part of the global fight against terror threat.

Proliferation: (PWMD)

Rapid increase in the number or amount of something. Proliferation of Nuclear proliferation is the spread of nuclear weapons, fissionable material, and weapons-applicable nuclear technology and information to nations not recognized as "Nuclear Weapon States" by the Treaty on the Non-Proliferation of Nuclear Weapons, commonly known as the Non-Proliferation Treaty or NPT. Proliferation, or the spread of weapons of mass destruction, does not only involve the development or purchase of these weapons and their means of delivery as such, but also buying or otherwise obtaining (procuring) the goods and knowledge required for WMD development.

Objectives and Purpose

Ensuring the commitment of Habib Qatar Exchange with the provisions of Law No. (20) of 2019 on Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) and the instructions issued by Qatar Central Bank. Detecting, preventing, and reporting the activities of money laundering and terrorist financing and proliferation financing at Habib Qatar Exchange and the branches thereof. Protecting Habib Qatar Exchange and preventing the utilization thereof as channel to perform illegal transactions created by the money laundering or terrorist financing or any other illegal activities.

Know Your Customer – KYC

The most important measure in combating money laundering which originates from the counter. We should have a reasonable knowledge of the customer (KYC) particularly when the transaction takes place for a larger amount of money.  It is like categorizing customers in order to know, relatively, whether he has the capability to remit huge value of money.

CDD (Customer Due Diligence)

Customer Due Diligence information comprises the facts about a customer that should enable an organisation to assess the extent to which the customer exposes it to a range of risks. These risks include money laundering and terrorist financing. 

Enhanced Due Diligence 

We conduct enhanced CDD measures and enhanced on-going monitoring in cases where it is required under the provisions of Law or regulations, or when there is perception of high risk or money laundering or terrorist financing.

Beneficial Ownership:

Beneficial ownership is a term in domestic and international commercial law which refers to the natural person or persons "who ultimately own or control a legal entity or arrangement, such as a company, a trust, or a foundation".

Politically Exposed Persons (PEP)     

Persons who are or have been entrusted with prominent public functions in a foreign country or territory, as well as members of such person’s family or those closely associated with those persons. The prominent public functions may in this regard include: Heads of State, Heads of Government, Ministers, Deputy or Assistant Ministers, Members of Parliament, Senior politicians or important political party officials, Judicial official, Members of boards of Central Banks, Ambassadors & Charges d’ affaires, High ranking officers of armed forces, Senior executives of state-owned corporations.

Risk-based Approach

Consistent with our Company’s adoption of a rigorous compliance regime, senior management has performed an assessment and documented the risk of Money laundering, terrorist financing. Using the risk-based approach, we have identified potential high risks of Money laundering, terrorist financing as it pertains to our Company and we have developed strategies to mitigate them. We have included these strategies as part of our policies and procedures.

Non-Profit Organisation:

Includes an entity, other than an individual, that primarily engages in raising or distributing funds for charitable, religious, cultural, educational, social, fraternal or similar purposes or carries out other types of charitable or similar acts. As part of Habib Qatar policy, we do not make transactions to charitable or non- profitable organizations or offer any financial services to humanitarian, cooperative and vocational associations, and societies. Habib Qatar will not establish any business relationship with Trust, Clubs and NPOs.

Staff Training

Training of employees and managers are essential in this changing environment. It is an important activity which helps in improving the competency of employees. Training gives a lot of benefits to the employees such as improvement in efficiency and effectiveness, development of self-confidence and assists everyone in self-management. Therefore, training is important due to, Environmental changes, Organizational Complexity, Human relations, to match employee specifications with the job requirements and organizational needs. Habib Qatar Exchange takes responsibility to train our staff on ML/TF and CPF regulations, policies, and procedures. 

Record Keeping

Habib Qatar Exchange should update these data periodically and ensure that the judicial authorities and competent authorities entrusted with the enforcement of ML/TF Law have timely access to these documents and records, as and when necessary. The documents, data and record keeping will be for a minimum of 10 years.