AML & CFT Policy

1. Applicable law

We are subject to:

• UAE Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, as amended;
• Cabinet Decision No. (10) of 2019 (Executive Regulations);
• Cabinet Decision No. (109) of 2023 (Beneficial Ownership);
• UAE Targeted Financial Sanctions regime under Cabinet Decision No. (74) of 2020;
• Guidance issued from time to time by the UAE Ministry of Economy, the UAE Financial Intelligence Unit ("FIU") and other competent authorities.

Where we deliver services in coordination with affiliated law firms (Neo Legal, Cornwalls), FTA-registered tax-agent partners, audit partners or licensed registered agents in other jurisdictions, those firms are separately responsible for their own AML/CFT compliance under the regimes applicable to them.

2. Governance and Money Laundering Reporting Officer

We have appointed a Money Laundering Reporting Officer ("MLRO") who is independent of the day-to-day client-facing function and reports directly to the General Manager. The MLRO is responsible for: receiving internal suspicion reports; deciding whether to file a Suspicious Transaction Report ("STR") or Suspicious Activity Report ("SAR") with the UAE FIU via the goAML portal; maintaining the firm's risk assessment; and ensuring annual AML training across the firm. The MLRO can be reached at mlro@arxsetup.ae.

3. Firm-wide risk assessment

We maintain a written firm-wide AML/CFT risk assessment covering: client risk (geography, activity, ownership structure, public-profile factors); jurisdictional risk (FATF, EU and UAE country-classification lists); product / service risk (e.g. virtual-asset structuring, complex multi-jurisdictional layering); and delivery-channel risk (remote onboarding vs in-person). The assessment is reviewed and approved annually by the General Manager.

4. Customer due diligence (CDD)

We perform Customer Due Diligence at the outset of every engagement, comprising:

• Identification of the client and verification of their identity via reliable independent documents — certified passport copy and an address proof dated within the last 90 days (utility bill, bank statement, government correspondence).
• Identification of the ultimate beneficial owners — every natural person who ultimately owns or controls 25% or more of the client, or who otherwise exercises effective control. For trusts, foundations and similar structures we identify settlors, trustees, protectors, beneficiaries and persons of equivalent function.
• Verification of the source of wealth of the beneficial owners — narrative supported by documentary evidence (tax returns, employment contracts, sale agreements, inheritance documentation).
• Verification of the source of funds for the specific funds expected to flow through the structure we are advising on.
• Understanding the purpose and intended nature of the business relationship and of the structure being advised on.
• Sanctions screening at onboarding against UAE Cabinet, UN Security Council, EU and OFAC consolidated lists, and screening for Politically Exposed Person ("PEP") status.

5. Enhanced Due Diligence (EDD)

EDD is applied where: the client or a beneficial owner is a PEP, family member or close associate of a PEP; the structure involves a country listed by FATF as high-risk or subject to a call for action; the activity is in a higher-risk category (virtual assets, precious metals and stones, regulated gambling, certain real-estate transactions); the beneficial-ownership structure involves nominee or trust layers reducing transparency; or the firm's risk assessment otherwise indicates. EDD measures include additional documentation, senior-management approval before engagement, and enhanced ongoing monitoring.

6. Ongoing monitoring

We monitor client relationships throughout their lifecycle:

• Annual KYC refresh, with the documentation cycle dictated by the client risk rating.
• Re-screening against sanctions and PEP databases on each material change (UBO change, change of activity, change of nominee, new shareholder).
• Transaction monitoring for clients to whom we provide accounting or bookkeeping services, with thresholds calibrated to the client's business profile.
• Adverse-media monitoring for higher-risk clients.

7. Suspicious Transaction and Suspicious Activity Reporting

Every member of the firm is required to escalate any concern or suspicion to the MLRO at the earliest opportunity. The MLRO assesses each internal report and, where the legal threshold is met, files an STR or SAR with the UAE FIU via the goAML portal without delay. We are prohibited from informing the client (or any third party) that a report has been or is being considered — this is the so-called "tipping-off" prohibition under Article 25 of Federal Decree-Law No. 20 of 2018. Tipping off is a criminal offence.

8. Refusal and termination

We will refuse to engage, or terminate an existing engagement, in any of the following situations:

• we cannot satisfactorily complete CDD or obtain adequate beneficial-ownership information;
• the proposed activity would be illegal under UAE law or under the law of any jurisdiction in which the structure will be incorporated;
• sanctions screening returns a positive match in respect of the client, any beneficial owner, any director or any counterparty involved in the proposed structure;
• we form a suspicion of money-laundering, terrorist financing, proliferation financing, tax evasion, fraud or other predicate offence;
• information provided to us is materially false, misleading or incomplete; or
• continued provision of the Services would create a conflict with our regulatory or professional obligations.

Refusal or termination on AML/CFT grounds does not entitle the client to a refund of fees already incurred and may itself give rise to a reporting obligation on the firm.

9. Targeted Financial Sanctions

We comply with the UAE Targeted Financial Sanctions regime under Cabinet Decision No. (74) of 2020. We screen all clients and beneficial owners against the UAE Local Terrorist List, the UN Consolidated List, and other sanctions lists we are obliged to apply. Where a positive match is identified we will: freeze, without delay, any funds or other assets we hold; refrain from making them available; and notify the Executive Office of the Committee for Goods and Material Subject to Import and Export Control (the "Executive Office") in the prescribed form.

10. Record-keeping

We retain CDD records, transaction records, internal suspicion reports, MLRO decisions, STR / SAR submissions and supporting documentation for the minimum period required by UAE AML law (currently five years from the end of the business relationship or from the date of the relevant transaction, whichever is later). Records are stored securely and made available to the UAE FIU and other competent authorities on lawful request.

11. Training

All partners and staff complete annual AML/CFT training. Training covers current typologies, sanctions developments, the UAE regime, the firm's internal procedures, the duty to report internally, and the tipping-off prohibition. Specialist training is provided to client-facing staff, to the MLRO, and to staff in roles with elevated AML responsibility. New joiners complete induction AML training within thirty (30) days of joining.

12. Whistleblowing

The firm maintains a whistleblowing channel that allows partners, staff and clients to report — without retaliation — any concern about compliance with this Policy or with the underlying law. Reports may be made to the MLRO or, where the MLRO is the subject of the concern, directly to the General Manager.

13. Independent review

The firm's AML/CFT compliance is subject to periodic independent review (commensurate with the size and risk profile of the firm), the findings of which are reported to the General Manager. The risk assessment, this Policy and the underlying procedures are reviewed and re-approved at least annually.

14. Cooperation with authorities

We cooperate fully with the UAE FIU, the UAE Ministry of Economy, the Dubai Development Authority, the UAE Federal Tax Authority and any other competent UAE authority in connection with their supervisory and investigative functions. Where lawful, we also cooperate with foreign competent authorities under mutual legal-assistance arrangements.

15. Status of this Policy

This Policy is a summary of our internal procedures and is published for transparency. It is not legal advice and does not create contractual rights for clients beyond those set out in our Terms of Engagement and the matter-specific Engagement Letter. Our full internal AML/CFT manual is made available to competent authorities on request.

16. Contact

Questions about this Policy may be directed to the MLRO at mlro@arxsetup.ae.

Issued by Neo International Consultancy FZ-LLC, DDA licence 107229, Unit L1-206, Floor 02, Loft Offices 1, Dubai Media City, Dubai, UAE. Last updated 18 May 2026.