FundedSquad accessible from https://fundedsquad.com which owned and operated by DEVIONICS TECHNOLOGY – FZCO is dedicated to preventing money laundering, terrorist financing, and the evasion of sanctions. Adherence to relevant laws and regulations is crucial for maintaining our reputation and public trust. This AML policy outlines the measures we will implement to achieve our organizational goals while ensuring compliance with the regulatory framework for designated non-financial businesses and professions (DNFBP) in the United Arab Emirates (UAE).

Policy Objectives

1. Establish Clear Policies: Define precise policies for addressing money laundering, terrorist financing, and sanctions evasion.
2. Define Compliance Responsibilities: Provide clear instructions on the compliance duties of all employees.
3. Guide Daily Operations: Offer guidance on integrating legal requirements into daily business activities.
4. Promote Legal Adherence: Foster a culture of legal compliance in all employee actions.

Definition of Money Laundering

Under Article 2 of the Anti-Money Laundering (AML) Law, money laundering is defined as engaging in activities with the knowledge that the funds involved are from criminal acts, including:

• Transferring or disposing of funds to conceal their origin.
• Concealing the true nature, source, or location of funds.
• Using or possessing funds obtained from criminal activities.
• Assisting others in evading punishment for criminal activities.

Money laundering is an intentional act. Gross negligence, such as failing to report suspected criminal activities to the Financial Intelligence Unit (FIU), may also result in criminal liability.

Laws and Regulations

FUNDEDSQUAD complies with the following laws and regulations:

• UAE Federal Law No. 20 of 2018: Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organizations (AML Law).
• Cabinet Resolution No. 10 of 2019: Implementing Regulations of Federal Law No. 20 of 2018 (AML Regulations).
• UAE Federal Law No. 7 of 2014: Combating Terrorism Crimes.
• UAE Federal Penal Law No. 3 of 1987: Penal Code.
• UAE Federal Penal Procedures Law No. 35 of 1992: Penal Procedures Law.
• UAE Federal Law No. 5 of 2012: Combating Cyber Crimes.
• SCA Decision (17/R) of 2010: Anti-Money Laundering and Terrorism Finance Combating Procedures.
• UAE Central Bank Regulations: Procedures for Anti-Money Laundering, including Circular No. 24/2000 and amendments.
• United Nations Sanctions: Applicable through UAE ratification.

Investigatory Powers and Criminal Enforcement

The Financial Intelligence Unit (FIU) under the UAE Central Bank oversees reporting and investigating suspected illicit financial conduct. The Public Prosecution has the authority to initiate legal proceedings for such offenses.

Defenses

The Regulations do not specify defenses unique to money laundering charges. General criminal defense strategies apply. Criminal proceedings for money laundering cannot be resolved through settlements or plea agreements; cases must be adjudicated in criminal courts.

Transaction Monitoring System

FUNDEDSQUAD employs a transaction monitoring system to detect unusual or suspicious transactions. Currently, transactions are manually reviewed using ‘Veriff’ Identity Verification Service. By 2025, an automated transaction monitoring system will be implemented.

Detection of Unusual/Suspicious Transactions

We perform thorough manual reviews of each transaction, which range from $9 to $1,999. This process is designed to identify any transactions that appear abnormal or suspicious, ensuring compliance with legal standards.

Reporting Suspicious Transactions

Suspicious transactions are reported to the Central Bank of the UAE through Bank Mashreq Bank PSC. Records are maintained for at least five years to ensure compliance with legal requirements and facilitate future audits or legal proceedings.

Risk Rating

Our dedicated risk management unit conducts manual risk assessments of client profiles, ensuring comprehensive due diligence and risk mitigation in compliance with legal and regulatory frameworks.

Resolutions and Sanctions

Non-compliance with AML standards may result in administrative sanctions, including warnings, fines, business activity restrictions, and actions against board members and senior management. Convictions for money laundering can result in fines from AED 100,000 to AED 10 million and imprisonment for up to 10 years.

FUNDEDSQUAD’s Obligations

1. Risk Identification: Identify potential criminal activity risks.
2. Ongoing Risk Assessments: Regularly assess identified risks.
3. Internal Controls: Implement controls and policies to manage risks.
4. Due Diligence: Apply due diligence procedures.
5. UN Directives Compliance: Adhere to UN directives on terrorism financing and weapons proliferation.
6. Avoid Shell Banks/Organizations: Prevent business relationships with shell entities.

Employee Training

Annual AML/CFT training includes:

• Identifying and reporting reportable transactions.
• Recognizing different money laundering and terrorist financing schemes.
• Understanding internal AML/CFT policies and procedures.

Documentation of training sessions, including attendance records and instructional materials, is maintained. New or amended AML/CFT laws and policies are communicated to relevant staff.

Designated Compliance Team

A Designated Compliance Officer oversees the AML/CFT program, ensuring compliance and coordinating day-to-day operations. The Risk Management team performs regular compliance testing.