Klein Edu LTD is firmly committed to the prevention of money laundering, terrorist financing, and the evasion of sanctions. Unwavering compliance with applicable laws and regulations shall serve to safeguard Klein Edu LTD’s reputation and uphold public trust in Klein Edu LTD.

Therefore, it is advisable for Klein Edu LTD to establish an anti-money laundering (AML) policy that delineates the prescribed measures to be observed, aiming to ensure the efficient execution of guidelines that support the attainment of overarching organizational goals, while guaranteeing conformity with the regulatory structure governing designated non-financial businesses and professions (DNFBP) in the United Arab Emirates (UAE). The scope of the AML policy shall encompass all entities in which Klein Edu LTD holds ownership interests.

Policy Objectives

• To establish precise and unambiguous policies for Klein Edu LTD concerning the matters of money laundering, terrorist financing, and the avoidance of sanctions.
• To provide clear and concise explanations of the compliance responsibilities that all employees are obligated to fulfill.
• To offer guidance to employees regarding their daily business activities in alignment with legal requirements.
• To foster a work environment that upholds a culture of adherence to legal regulations in the manner in which employees execute their duties.

Definition of Money Laundering

As per the provisions outlined in Article 2 of the Anti-Money Laundering (AML) Law, the offense of money laundering is defined as the engagement in any of the following activities with the knowledge that the funds involved are derived from a criminal act:

• Transfers or moves the proceeds, or disposes of the funds/proceeds intending to conceal or disguise their source.
• Conceals or disguises the true nature, source, or location of the proceeds including the manner of disposal.
• Acquires, possesses, or uses the proceeds upon receiving them.
• Assists the person who committed the felony/misdemeanor to escape punishment.

It is essential to note that money laundering is always an intentional act and cannot be committed through mere negligence. However, Klein Edu LTD acknowledges that acts exhibiting gross negligence, particularly those involving the failure to report suspicions of criminality to the Financial Intelligence Unit (FIU), may incur criminal liability.

Laws and Regulations

Klein Edu LTD is subject to and 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 as amended (Penal Code).
• UAE Federal Penal Procedures Law No. 35 of 1992 as amended (Penal Procedures Law).
• UAE Federal Law No. 5 of 2012: Combating Cyber Crimes.
• SCA Decision (17/R) of 2010 Concerning Anti-Money Laundering and Terrorism Finance Combating Procedures.
• UAE Central Bank Regulations Concerning Procedures for Anti-Money Laundering, in particular Circular No. 24/2000 and its amendments by Notices No. 1045/2004 and 2922/2008.
• Any United Nations sanctions applicable through ratification by the UAE.
• In accordance with the Regulations, it is mandated for financial institutions in the UAE to adopt a risk-based approach to fulfill their legal obligations. This requirement applies to activities such as customer onboarding and conducting periodic AML assessments. Klein Edu LTD is fully committed to implementing a robust risk-based compliance program in strict alignment with both legal mandates and industry-leading best practices.

Investigatory Powers and Criminal Enforcement

The oversight of reporting and probing suspected illicit financial conduct in the UAE falls under the Financial Intelligence Unit (FIU) operating under the UAE Central Bank. The Public Prosecution retains the authority to initiate legal proceedings, which are adjudicated in the criminal courts.

Defenses

The Regulations do not provide specific defenses to money laundering charges. Defenses under UAE law for money laundering charges are not distinct from those available for other criminal offenses.

It is important to note that criminal proceedings related to money laundering cannot be resolved through settlement or plea agreements. Once the Public Prosecutor determines that actions amount to a money laundering offense, the case must be referred to the criminal courts.

Detection of Unusual/Suspicious Transactions

As an entity operating within the retail business-to-consumer (B2C) model, Klein Edu LTD’s transactions predominantly involve individual transactions ranging from $9 to $999. In adherence to legal obligations, each transaction is subjected to a meticulous manual approval process applying principles of due diligence.

This rigorous approach ensures the detection of transactions that may appear abnormal, irregular, or suspicious. Klein Edu LTD is also committed to retaining all relevant records and documents for a minimum of five years, in compliance with legal and regulatory requirements.

Risk Rating

Klein Edu LTD maintains a dedicated risk management unit, responsible for manually examining client profiles and conducting comprehensive risk assessments. Due diligence is performed thoroughly following an evaluation of customer risk ratings, ensuring compliance with applicable frameworks.

Resolutions and Sanctions

Non-compliance with established standards may result in administrative sanctions, including warnings, monetary fines, suspension of business activities, liability of senior management, and the appointment of observers.

In the event of a conviction for money laundering, the AML Law prescribes financial penalties ranging from AED 100,000 to AED 10 million, in addition to potential imprisonment of up to 10 years.

Klein Edu LTD’s Obligations

Identify potential risks associated with criminal activities.

Conduct ongoing risk assessments.

Establish internal controls and policies to manage risks.

Implement appropriate due diligence procedures.

Comply with United Nations directives regarding terrorism financing and weapons proliferation.

Prevent relationships with shell banks or organizations.

Training and Awareness

Employees of Klein Edu LTD shall receive annual AML/CFT training, which includes:

Identification and reporting of suspicious transactions.

Examples of money laundering/terrorist financing related to company products and services.

Internal policies to prevent money laundering and escalation of suspicious activity.

Training records, attendance logs, and instructional materials shall be maintained. Updates to AML/CFT laws and policies shall be communicated to relevant staff.

Designated Compliance Team

The Risk Management team shall perform regular compliance testing. A designated Compliance Officer shall oversee the AML/CFT program and coordinate day-to-day operations to ensure adherence to legal and regulatory requirements.