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Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Standards

 

Last updated: November 2025

1. Purpose

This Policy outlines how Arkstone FZCO (“Arkstone”, “we”, “our”, or “us”) prevents, detects, and reports activities related to money laundering, terrorist financing, and other financial crimes.

Arkstone is fully committed to conducting business in compliance with applicable laws and regulations governing anti-money laundering (AML) and counter-terrorist financing (CTF), including but not limited to:

  • UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism;

  • Cabinet Decision No. 10 of 2019 on AML/CTF implementing regulations;

  • Dubai Virtual Assets Regulatory Authority (VARA) Rulebooks and related circulars; and

  • Financial Action Task Force (FATF) international standards.

2. Objective

Arkstone’s AML/CTF framework aims to:

  • Prevent its platform from being used for illicit purposes;

  • Ensure transparency in financial transactions;

  • Protect investors and issuers through rigorous compliance standards; and

  • Maintain the trust and integrity of Arkstone’s ecosystem.

3. Scope

This Policy applies to:

  • All employees, officers, and directors of Arkstone;

  • All issuers, investors, and users of the Arkstone platform; and

  • All third-party partners providing financial, custodial, or compliance-related services.

4. AML/CTF Principles

Arkstone’s AML framework is based on the following principles:

  • Risk-Based Approach (RBA): applying enhanced due diligence (EDD) for higher-risk clients, industries, or jurisdictions.

  • Know Your Customer (KYC): verifying the identity of every investor, issuer, and partner before onboarding.

  • Customer Due Diligence (CDD): assessing ownership, source of funds, and business purpose.

  • Ongoing Monitoring: reviewing transactions and activities to detect suspicious patterns.

  • Reporting Obligations: promptly escalating and reporting suspicious activity to the competent authorities.

  • Record Retention: maintaining all KYC, transactional, and compliance records for the legally required period.

5. Customer Identification and Verification (KYC/CDD)

Before granting access to the Arkstone platform, all users (both issuers and investors) must undergo identity verification.

a) For Individuals:

  • Full legal name

  • Government-issued identification (passport, national ID, or equivalent)

  • Proof of address (utility bill, bank statement, etc.)

  • Source of funds and wealth declaration

b) For Corporate Entities:

  • Certificate of incorporation / trade license

  • Memorandum and Articles of Association

  • Beneficial Ownership declaration

  • Details of directors, shareholders, and authorized signatories

  • Source of funds documentation

Arkstone partners with regulated identity verification providers to ensure that all data is securely processed and compliant with international standards.

6. Enhanced Due Diligence (EDD)

Arkstone applies enhanced due diligence when dealing with:

  • Politically Exposed Persons (PEPs) or their close associates;

  • Clients from jurisdictions identified as high-risk by FATF;

  • Complex or unusually large transactions; or

  • Entities operating in industries with elevated AML risk.

EDD may include deeper verification of source of wealth, background checks, and senior management approval prior to onboarding.

7. Transaction Monitoring

All user transactions and funding activities on the Arkstone platform are continuously monitored using both automated and manual review processes.

Monitoring includes:

  • Flagging transactions inconsistent with a customer’s profile;

  • Detecting rapid inflows/outflows, circular trading, or layering patterns;

  • Generating internal alerts for review by the Compliance Officer.

Suspicious activity is documented and escalated for potential reporting.

8. Reporting Suspicious Activities

Arkstone’s Money Laundering Reporting Officer (MLRO) is responsible for assessing and, where necessary, reporting suspicious activity to the UAE Financial Intelligence Unit (FIU) or other competent authorities.

All employees are required to immediately report any suspicions or knowledge of money laundering or terrorist financing activity to the MLRO.

Confidentiality is maintained at all times, and employees or partners who report concerns in good faith are protected from retaliation.

9. Record Retention

Arkstone retains all relevant customer identification, transactional, and compliance data for at least five (5) yearsfollowing the end of the business relationship or completion of a transaction, unless a longer period is required by law.

All records are stored securely and accessible only to authorized personnel.

10. Training and Awareness

All employees and relevant contractors must complete AML/CTF training:

  • Upon hiring, as part of onboarding; and

  • Annually, as part of ongoing compliance awareness.

Training covers red-flag indicators, reporting obligations, and procedures for handling suspicious transactions.

11. Responsibilities

  • The Board of Directors ensures that Arkstone maintains an effective AML/CTF framework.

  • The Compliance Officer / MLRO oversees implementation, monitoring, and reporting obligations.

  • All employees and agents are responsible for understanding and applying this Policy.

12. Cooperation with Authorities

Arkstone fully cooperates with regulatory and law enforcement bodies, both domestically and internationally, in the investigation and prevention of financial crime.

13. Consequences of Non-Compliance

Failure to comply with this Policy may result in disciplinary action, suspension, or termination of access to the Arkstone platform.
Arkstone reserves the right to terminate business relationships with any individual or entity that fails to meet AML/CTF standards.

14. Review and Updates

This Policy is reviewed at least annually or whenever regulatory changes occur.
Updates are approved by senior management and communicated to all relevant stakeholders.

15. Contact Information

For questions regarding these AML/CTF, please contact: compliance@arkstoneproject.com

Summary (plain language)

  • Arkstone follows strict AML/CTF standards under UAE and global laws.

  • All users (issuers and investors) undergo KYC verification.

  • Suspicious activity is monitored, documented, and reported.

  • Non-compliance leads to suspension or termination of access.