United Arab Emirates is a member of the Gulf Cooperation Council, who in turn is a member of the Financial Action Task Force (FATF) on Money Laundering and Terrorism Financing. UAE’s commitment in fighting Money Laundering & Terrorism Financing is evident from the fact that clear and wide-ranging laws & regulations (Federal Law No. 4 of 2002) are in place. The Central Bank of UAE which is the regulator for all Institutions and banks operating in UAE has also issued regulations on procedures for Anti Money Laundering (Notice No. 24/2000). Crette Odier’s Compliance & AML policies are designed to ensure compliance to requirements and obligations set out in local & applicable international regulations as well as FATF recommendations on AML & CTF.

Crette Odier Policies & Principles

Crette Odier’s Compliance & AML Team owns and is responsible for the following policies;

• Anti-Money Laundering/Counter-Terrorist Financing
• Sanctions Compliance
• Correspondent Banking Relationships
• FATCA Compliance
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  Anti-Money Laundering Policy

Crette Odier’s AML Policy sets out the minimum standards which must be complied with across the Companies & Bank:

• The appointment of a Money Laundering Reporting Officer (MLRO), who has responsibility for oversight of compliance with relevant regulations, rules and best
• Establishing and maintaining Risk Based Customer Due Diligence, Identification, Verification and Know Your Customer Procedures, including Enhanced Customer Due Diligence for those customers presenting higher risk, such as Politically Exposed Persons and Correspondent Banking Relationships.
• Establishing and maintaining Risk Based Systems and Procedures to monitor ongoing customer account
• Procedures for reporting Suspicious Transaction Reports internally as well as to regulatory bodies (AMLSCU at the Central Bank of UAE).
• The maintenance of appropriate records for the minimum prescribed periods as per local
• AML training and awareness for all relevant
• Appropriate management information and reporting on AML matters to the Senior Management of the
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  Sanctions Compliance Policy

Crette Odier’s Sanctions Compliance Policy is designed to ensure that it complies with applicable economic sanctions laws in every jurisdiction with which it may operate/trade.

• All transactions are screened against watch/sanctions lists like World Check, Central Bank of UAE, United Nations, European Union, UK’s HM Treasury and US’s
• It is Crette Odier’s policy not to deal with any person/entity that may result in violation of any sanctions
• All employees receive ongoing training on the Sanctions Compliance