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OFZA AML Compliance Statement
AML Policy Declaration
OFZA Fintech Virtual Asset Exchange Services L.L.C (hereinafter referred to as the “Company,” “OFZA,” or the “Exchange”) has established this Anti-Money Laundering (AML) Policy (the “Policy”) to ensure compliance with all applicable laws and regulations for preventing money laundering (ML), terrorism financing (TF), and proliferation financing. This policy outlines the necessary guidelines and procedures to protect the Company from being used for illicit financial activities, maintaining the integrity and stability of the financial system.
The Policy highlights the Company's commitment to preventing the misuse of its systems, products, and services for money laundering, financing terrorism, or any other criminal activities. It further provides guidance for detecting and reporting potential suspicious activities to the authorities promptly.
The AML Policy is subject to annual review, or review on an ad hoc basis when there are changes in applicable UAE Federal Laws, Cabinet Decisions, revisions or updates to VARA Rulebooks, applicable global AML laws & regulations, and when OFZA introduces new products, services, or delivery channels.
Compliance with AML Laws and Regulations
OFZA is fully committed to preventing the use of its platform for illicit activities. This commitment involves strict adherence to the Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) laws, regulations, and guidelines provided by local authorities such as the UAE Federal Government, VARA, and international bodies such as the Financial Action Task Force (FATF).
This includes complying with the relevant provisions in:
UAE Federal Decree-Law No 10 of 2025 on AML, Combatting the Financing of Terrorism and Financing of Illegal Organizations (the Decree-Law).
Federal Law No 9 of 2014 “Combating Money Laundering and Terrorism Financing Crimes”,
VARA Laws and Regulations, mandatory rulebooks and guidances.
the Financial Action Task Force’s [FATF] 12-Month Review of the Revised FATF Standards on Virtual Assets and Virtual Asset Service Providers [June 2020]
FATF’s Second 12-Month Review of the Revised FATF Standards on Virtual Assets and Virtual Asset Service Providers [July 2021]
FATF’s Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers [October 2021]
the International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation, The FATF Recommendations [March 2022]
Cabinet Resolution No. [74] of 2020 regarding the Terrorist List System and The Implementation of Security Council Resolutions Related to Preventing and Suppressing Terrorism and its Financing, Counter of Proliferation and its Financing, and the Relevant Resolutions
Cabinet Resolution No. 20 of 2019 regarding the UAE Local Terrorist List and implementation of UN Security Council decisions relating to preventing and countering financing terrorism, and leveraging non-proliferation of weapons of mass destruction, and the relevant resolutions,
the UAE Executive Office for Control & Non-Proliferation [EOCN] Guidance on Counter Proliferation Financing for FI’s, DNFPBs, and VASPs [March 2022]; and the EOCN’s Local Terrorist List, as may be amended from time to time.
Federal Decree Law 34/2021 on Combating Cyber Crimes
Resolutions and sanctions issued by the UN Security Council and other bodies,
Any other relevant laws, regulations and guidance which OFZA must comply for ensuring effective compliance
OFZA AML Compliance Program
OFZA is committed to combatting and preventing money laundering and terrorist financing and has implemented an AML/CFT (Counter Financing of Terrorism) compliance program. The Company will adopt a Risk-Based Approach (RBA) that is proportionate to the risks to which it is exposed due to the nature of its business, Customers, geographical location, products, services, delivery channel, risky exposure to virtual asset transactions and any other matters which are relevant in the context of money laundering.
The key elements of OFZA risk-based AML/CFT program include the following:
Appointment of a qualified, experienced and senior-level Compliance Officer and MLRO.
Establishing and maintaining risk-based Customer Due Diligence (CDD), Identification, Verification and Know Your Customer (KYC) Procedures periodically and ad hoc basis at any trigger event, including Enhanced Due Diligence (EDD) for those Customers presenting higher risk, such as Politically Exposed Persons.
Performing ongoing name screening of Customers against relevant international and local sanctions, PEP, and adverse media lists.
Conducting risk-based transaction monitoring on Customers' fiat and virtual asset transactions, fraud monitoring, and market abuse through trade surveillance monitoring.
Performing ongoing review on system controls and establishing a mechanism to re-calibrate the alert thresholds based on the customer transaction behavioral pattern, regulatory requirements and industry best practices.
Establishing clear procedures for Reporting Internal Suspicious Activity Reports (SAR) by OFZA employees to MLRO and filing external SAR to UAE- FIU via the goAML platform without delay and notifying VARA.
Establishing systems and controls to ensure compliance with FATF Travel Rule Recommendation 16 and EOCN Targeted Financial Sanctions in accordance with Cabinet Resolution 74 of 2020.
Implementing an ongoing Employee AML/CFT Training Program.
Maintaining record-keeping in compliance with VARA regulations and ensuring adequate controls for safeguarding personal data protection and adherence to applicable data protection laws.
Performing ongoing and periodic Compliance Monitoring Programme.
Conducting an independent audit to test the effectiveness of the AML program by an internal auditor, external audit, or compliance professional in compliance with VARA regulations.
Know Your Customer (KYC) and Customer Due Diligence (CDD):
OFZA will conduct KYC checks before the establishment of any business relationship, including the verification of customers’ identities. This includes obtaining, verifying, and maintaining up-to-date customer information to mitigate risks related to money laundering and terrorism financing. Customer Due Diligence will be conducted on both new and existing customers.
In addition, due diligence measures will be performed on an ongoing basis, periodically at the time of customer review and ad hoc basis upon the occurrence of any trigger event. OFZA will apply more stringent and enhanced measures to High-Risk clients along with normal CDD measures at the time of onboarding and during ongoing and periodic reviews for existing clients.
Sanction Compliance
OFZA will perform ongoing name screening of its customers against local and international sanctions lists, and adverse media lists, including but not limited to those published by the United Nations, the U.S. Office of Foreign Assets Control (OFAC), and UAE Local Terrorist Lists. Any customer identified as being linked to sanctioned individuals or entities appropriate actions will be taken including but not limited to freezing the funds, restricting them from certain activities, deplatforming the customer, reporting to UAE-FIU through goAML platform and notifying VARA.
FATCA and CRS Compliance
OFZA complies with the Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standard (CRS) requirements, ensuring that necessary information regarding customers is collected, verified, and reported to relevant tax authorities.
Implementation of the FATF Travel Rule
OFZA is committed to complying with FATF’s Travel Rule Recommendation 16, which mandates the collection and transmission of specific customer information during wire transfers equivalent to the value exceeding AED 3,500. The Company will ensure that the required information is included in all transactions in accordance with the applicable regulatory standards.
Record Keeping
OFZA will maintain comprehensive records of all customer information, transactions, and related documentation for a minimum of eight years after the closure of a customer’s account. This is in line with VARA regulations and ensures compliance with legal and regulatory requirements for record retention.
