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AML/CFT Policy

AML/CFT Policy

ANTI-MONEY LAUNDERING AND COMBATTING THE FINANCING OF TERRORISM POLICY

Last Revised: 11 June 2026

  1. Policy Statement and Commitment

    1.1. This Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Policy (the Policy) establishes the framework adopted by MNA Foundation (the Foundation) to identify, assess, and mitigate the risks of money laundering, terrorist financing, proliferation financing, and other financial crimes in connection with its activities.

    1.2. The Foundation is incorporated in Dubai International Financial Centre (DIFC) and is primarily involved in the oversight of its subsidiaries, structures and associated arrangements. While the Foundation is not a financial institution or Designated Non-Financial Business or Profession (DNFBP) as per the applicable laws and regulations of DIFC, this Policy is adopted on a risk-based and proportionate basis to support the Foundation’s commitment to corporate governance, ethical business conduct, and internal risk management standards, having regard to the nature, size, and complexity of its business.

    1.3. The Foundation has adopted this Policy as a matter of good governance and risk management. While the Foundation is not currently subject to the AML/CFT requirements applicable to DFSA-regulated entities, it remains committed to maintaining appropriate controls to mitigate financial crime and sanctions risks and to supporting compliance with applicable UAE laws.

  2. Effective Date

    2.1. This AML/CFT Policy is effective from 22 June 2026 and supersedes any previous internal guidance on this subject.

  3. Governance and Responsibility

    3.1. The Foundation shall maintain appropriate internal arrangements for the implementation and periodic review of this Policy, having regard to the nature, size, and risk profile of its business. The Foundation may, where necessary, designate appropriate personnel or external advisors to assist with the compliance with this Policy.

    3.2. All employees are obliged to comply with the requirements of this Policy and to escalate reasonably suspected anomalies, suspicious activity, or non-compliance to the senior management of the Foundation. Any employee identifying a potential concern regarding AML/CFT or any suspicious activity shall escalate such matter promptly to the senior management of the Foundation for assessment within one (1) business day of such occurrence.

    3.3. The Foundation may, in its sole discretion, provide appropriate AML/CFT awareness or guidance to relevant employees or representatives, having regard to their roles, responsibilities, and level of involvement in customer onboarding, finance, or other activities where AML/CFT risks may reasonably arise.

  4. Risk-Based Approach

    The Foundation shall apply a risk-based approach in all customer and transaction assessments. Pursuant to this, customers shall be classified into three categories:
      • Low Risk: based customers with transparent profiles and no adverse indicators.
     
      • Medium Risk: Foreign customers from jurisdictions not deemed high risk, where documentation and profile are consistent.
     
      • High Risk: Foreign customers from high-risk jurisdictions, UAE-recognised sanctioned jurisdictions, or jurisdictions otherwise subject to applicable sanctions or heightened AML/CFT concerns.
     
  5. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

    5.1. Customers that pose a Medium or High Risk to the Foundation may be subject to proportionate CDD. Where further review is deemed necessary, customers may also be screened against applicable sanctions lists, ‘PEP’ databases, and adverse media sources at onboarding and before acceptance of the first payment. CDD may include the following:

    a. For Natural Persons:

      • Verification of full name, nationality, and date of birth;
     
      • Review of a valid passport or national identity document (where applicable);
     
      • Proof of residential address (utility bill, tenancy contract, or equivalent); and
     
      • Details of employment or business activity.
     
    b. For Legal Persons:

      • Valid trade licence and constitutional documents;
     
      • Register of shareholders and Ultimate Beneficial Owners (UBOs);
     
      • Identification of natural persons holding 25% or more ownership or exercising control; and
     
      • Board resolution or power of attorney evidencing authority to contract.
     
    5.2. The Foundation shall conduct ongoing risk-based monitoring of customer relationships. This may include periodic reviews and re-screening of customer information, with the frequency determined by risk classification, and event-driven reviews when material changes or unusual circumstances are identified.

    5.3. EDD may be utilised where customers are classified as High Risk and may include verification of source of funds and source of wealth through appropriate supporting documentation.

  6. Sanctions Compliance

    6.1. The Foundation shall not knowingly engage with or facilitate activities involving persons, entities, organisations, or jurisdictions that are subject to applicable United Nations sanctions or UAE sanctions restrictions.

    6.2. Appropriate sanctions screening may be conducted before onboarding, prior to material transactions, and periodically on a risk-sensitive basis.

  7. Suspicious Activity

    7.1. Where the Foundation identifies activity that appears unusual, suspicious, or inconsistent with the known purpose of a relationship or transaction, the matter shall be escalated for review.

    7.2. The Foundation may seek additional information, suspend engagement, decline a transaction, or terminate a relationship where concerns cannot be satisfactorily resolved.

  8. Record Keeping

    The Foundation shall maintain records relating to due diligence, risk assessments, screening results, approvals, and relevant transactions for a minimum period of six (6) years following the end of the relationship or completion of the transaction, or such longer period as may be required by applicable law.

  9. Review of Policy

    This Policy shall be reviewed on an annual basis, or earlier where there are material changes to applicable laws, business activities, customer or risk profiles.

    This AML/CFT Policy has been approved by the senior officers of the Foundation and adopted as of the Effective Date. The Foundation commits to maintaining this Policy in accordance with applicable laws and regulations.