Our position
UQT enforces a strict, zero-tolerance approach to money laundering and terrorist financing. The Company applies appropriate measures and procedures by adopting a risk-based approach, so as to focus effort in those areas where the risk of money laundering and terrorist financing is comparatively higher.
UQT does not provide regulated financial services and does not hold client funds. The regulated providers in our network operate their own KYC and AML programmes, and they make the onboarding decisions for the regulated services they deliver. UQT's AML programme governs the brokerage and matching activity UQT conducts, and supports the providers' onboarding processes.
Risk-based approach
Our approach to AML/CFT recognises that the threat varies across clients, sectors, jurisdictions and product categories. We tailor measures accordingly and continuously review them.
Indicators we weigh include:
- The scale and complexity of the services involved
- Geographical spread of clients and counterparties
- The nature and economic profile of clients
- The distribution channels and practices of providing services
- The volume and size of expected transactions
- The country of origin and destination of clients' funds
- Deviations from the anticipated profile of activity
Money Laundering Reporting Officer (MLRO)
UQT appoints an MLRO and Compliance Officer with sufficient seniority, skills, experience and knowledge in AML/CFT compliance. The MLRO is responsible for managing the AML/CFT programme, monitoring regulatory updates, training staff, reviewing this policy at least annually, and reporting suspicious activity to the relevant authority where required.
What money laundering and terrorist financing are
Money laundering is the process of concealing the true origin and ownership of illegally obtained funds, typically through three stages: placement, layering and integration.
Terrorist financing is the provision or gathering of funds, directly or indirectly, with the intention to use them, or knowing they will be used, in whole or in part for terrorist purposes. Terrorist financing may involve funds from legitimate sources but linked to terrorist activity.
Customer due diligence
UQT's matching activity does not itself open accounts or hold funds. However, UQT collects identifying information about businesses and beneficial owners as part of profile capture, and applies risk-based due diligence proportionate to that role. This may include:
- Identification and verification of the business entity and its beneficial owners
- Identification and verification of natural persons representing the business
- Capture and assessment of business activity, geography and transaction patterns
- Screening against sanctions lists and politically-exposed-person (PEP) lists
- Ongoing monitoring of changes to the captured profile
The regulated providers we route applications to perform their own customer due diligence in accordance with their licence and their jurisdiction. The provider's CDD is independent of UQT's, and the provider's onboarding decision is final.
Sanctions and PEP screening
UQT screens businesses, beneficial owners and key counterparties against relevant sanctions lists, including:
- United Nations Security Council sanctions lists
- European Union restrictive-measures lists
- UAE national sanctions lists
- OFAC and other applicable national lists
True matches are escalated. False positives are documented and dismissed. We do not knowingly route applications to providers on behalf of sanctioned persons or entities.
Record keeping
UQT maintains records of profile capture, due diligence, sanctions screening, matching outputs, introductions sent and provider responses, in line with applicable retention requirements. Records are held securely with restricted access.
Suspicious activity
UQT staff are required to escalate any concern about money laundering, terrorist financing, sanctions breaches or other illegal activity to the MLRO. Where appropriate, the MLRO will make a report to the relevant Financial Intelligence Unit. Staff are prohibited from tipping off any client or third party about a suspicion, an investigation or a report.
Training
All UQT staff receive AML/CFT training at induction and at least annually thereafter. Training covers identification of red flags, customer due diligence, sanctions screening, escalation procedures and recent regulatory updates.
Applicable law
UQT operates under the UAE legal framework applicable to its DET-licensed activity. Where UQT acts in support of providers in other jurisdictions, the providers themselves operate under their own applicable AML/CFT framework. Our internal programme draws on standards including, but not limited to:
- UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism
- FATF Recommendations
- Relevant EU directives where they apply to providers in our network
- UN Security Council Resolutions
Reviews and updates
This policy is reviewed at least annually by the MLRO and approved by senior management. Updates are also made when material changes occur in regulation, the network or UQT's business model.
Contact
AML/CFT queries: compliance@uqt.ae.
For questions, corrections or formal queries about this policy: compliance@uqt.ae.