ANTI-MONEY LAUNDERING (AML) POLICY

Our AML program is built on four fundamental pillars:

1. Development of Internal Policies and Procedures:
2. Designation of a Compliance Officer:
3. Ongoing Training Programs: Independent Review for Compliance:

Know Your Customer (KYC)

We implement a identity verification process for all customers, irrespective of transaction amount, in compliance with local and international AML/CTF regulations. Our KYC and Know Your Customer’s Customer (KYCC) policies are integral to our operations, ensuring thorough Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) where necessary.

Customer Due Diligence (CDD)

In our CDD process, we obtain pertinent details about each customer to ensure transactions align with their profile and business activities. Our goal is to verify the legitimacy of the source of funds and the purpose of each transaction.

Enhanced Due Diligence (EDD)

For higher-risk accounts, we conduct EDD, which involves additional scrutiny to confirm the source of funds and ensure that transactions are legitimate. This includes obtaining authentic documentation that supports both the underlying and stated purposes of the funds.

Sanctions Screening

To comply with applicable sanctions, Almas Jahan employs screen customer names against lists issued by relevant authorities, including the Central Bank of Afghanistan, the UN Security Council, and other international sanctions bodies. This screening extends to all parties involved in transactions.

Reporting Suspicious Transactions

All employees are trained to recognize and report unusual or potentially suspicious transactions to the compliance officer. The compliance officer will conduct a thorough investigation and, if necessary, report findings to the Financial Transaction Reporting Analysis Center of Afghanistan (FinTRACA).

Staff Training

We believe in empowering our employees through effective AML training. New staff receive training on our AML policies and procedures within 30 days of joining, with annual refresher courses to ensure ongoing compliance and awareness.

Record Keeping and Confidentiality

All records, including customer identification documents and transaction data, are maintained for a minimum of five years in line with regulatory requirements. Almas Jahan is committed to maintaining the confidentiality of all customer information and transaction records.

Independent Review of Compliance

Our AML and compliance functions are subject to regular reviews by Internal Audit, regulatory authorities, and independent external auditors. This ensures that our compliance program remains up-to-date and meets all regulatory requirements.