AML/CTF governance framework

Anti Money Laundering

MarinaCoins is dedicated to upholding a secure and regulation-compliant environment, enforcing strict protocols to thwart money laundering, terrorist financing, and other illegal activities.

Introduction and Definitions

MarinaCoins has established a stringent policy dedicated to actively preventing and prohibiting all forms of money laundering and any activities that might support money laundering or the funding of terrorist or criminal activities.

The company is committed to fully adhering to all applicable regulations and laws related to Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) as mandated by the UAE.

Money laundering involves activities designed to disguise or conceal the origins of money gained from illegal activities. These actions aim to make such funds appear legitimate or to convert them into assets that seem to have legal origins. Typically, money laundering involves three stages:

Here, cash from criminal activities is first introduced into the financial system, often by converting it into monetary instruments like money orders or traveler’s checks, or by depositing it into financial institution accounts.

Placement Stage

The money is then moved or transferred between different accounts or institutions, distancing it further from its criminal source.

Layering Stage

Finally, the laundered money re-enters the economy, possibly used to purchase legitimate assets, fund other criminal activities, or invest in legitimate businesses.

Integration Stage

The securities industry, though not typically involving cash deposits, can be a channel for money laundering. This can happen either by laundering funds gained from other sources or by generating illegal funds through investment fraud, including insider trading, market manipulation, Ponzi schemes, cybercrime, and other deceptive practices.

Regulatory Compliance

MarinaCoins has developed and implemented thorough AML policies, procedures, and internal controls, designed to be fully compliant with all applicable AML/CFT laws and regulations. The company is dedicated to consistently reviewing and updating these measures to reflect changes in legislation or business operations. This proactive stance ensures our practices remain effective and current with the evolving standards of anti-money laundering efforts. The following laws and regulations are integral to our processes:

Adherence to regulations and guidelines set by VARA.
Cabinet Resolution No. 10 of 2019, implementing Federal Law No. 20 of 2018.
UAE Federal Law No. 7 of 2014 on Combating Terrorism Crimes.
UAE Federal Penal Law No. 3 of 1987 and its amendments.
UAE Federal Penal Procedures Law No. 35 of 1992 and its amendments.
Regulations for declarations by travelers in UAE regarding cash, monetary, or financial instruments.
UAE Federal Law No. 5 of 2012 on Combating Cyber Crimes.
UAE Central Bank Regulations for Anti-Money Laundering, especially Circular No. 24/2000 and its updates
UAE Federal Law No. 20 of 2018 regarding Anti-Money Laundering, Counter-Terrorism Financing, and Illegal Organizations Financing.

Responsibilities and Procedures

MarinaCoins is obligated to:

Identify and assess risks related to criminal activities within its operations.

Report unusual or suspicious transactions to the UAE's Financial Intelligence Unit.

Regularly train staff on AML policies and procedures.

Analyze factors like customer profiles, transaction volumes, geographic regions, and industry trends.

Define clear policies and guidelines for employees regarding risk management and compliance.

Continuously evaluate identified risks and the effectiveness of risk management strategies.

Stay informed about evolving risks and regulatory changes.

Ensure compliance with VARA regulations.

Comply with UN directives related to terrorism financing and proliferation of weapons of mass destruction.

Maintain records of customer and transaction data for at least 5 years, preserving data confidentiality.

Follow the guidelines set by the Financial Action Task Force (FATF).

Develop and implement internal controls for risk management.

Establish robust internal control frameworks specific to identified risks.

Enforce due diligence requirements.

Implement varying levels of KYC based on customer types.

Design thorough due diligence processes for customer onboarding and ongoing monitoring, including verifying customer identities, sources of funds, and beneficial ownership.

Implement systems to detect and report suspicious activities related to these risks.

Conduct enhanced due diligence for high-risk customers.

Conclusion

MarinaCoins prioritizes a secure and compliant environment, implementing strict protocols against illegal activities such as money laundering and terrorist financing. Our comprehensive AML strategy includes accepting payments only from recognized banks, reducing the risk of non-compliant funds.

Rigorous KYC processes ensure a thorough understanding of customers, minimizing transactions with parties engaged in unlawful activities. Led by an appointed AML Compliance Officer, we continuously update policies to align with regulations and industry best practices, aiming to foster a secure and trustworthy business atmosphere while preventing financial crimes.