Our Compliance, AML & CFT

1. Our Commitment

At Zuato Financial Services, compliance is not just a regulatory obligation—it is a fundamental pillar of our business operations. We are committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in all our activities.

As a licensed payment acquirer regulated by the Central Bank of the UAE, we operate under strict guidelines designed to protect our merchants, their customers, and the broader financial ecosystem from financial crimes including money laundering, terrorist financing, fraud, and other illicit activities.

Our comprehensive compliance program is designed to:

• Prevent the use of our platform for money laundering or terrorist financing
• Ensure all merchants and transactions are legitimate and lawful
• Protect the integrity of the financial system
• Maintain trust with our partners, regulators, and stakeholders
• Meet or exceed all applicable regulatory requirements

2. Regulatory Framework

Our compliance program is built upon a robust regulatory framework that incorporates local, regional, and international standards.

We continuously monitor regulatory developments and update our policies and procedures to ensure ongoing compliance with evolving requirements.

3. KYC/KYB Verification Process

Before onboarding any merchant, we conduct thorough Know Your Customer (KYC) and Know Your Business (KYB) verification to ensure legitimacy and assess potential risks.

3.1 Merchant Onboarding Process

4. AML/CFT Program

Our Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) program is a comprehensive framework designed to prevent, detect, and report suspicious activities.

4.1 Program Components

• Policies and Procedures: Documented policies covering all aspects of AML/CFT compliance, regularly reviewed and updated
• Risk Assessment: Ongoing assessment of ML/TF risks at the institutional, customer, and transaction levels
• Customer Due Diligence: Robust KYC/KYB processes for all merchants and beneficial owners
• Transaction Monitoring: Real-time and periodic monitoring of transactions for suspicious patterns
• Sanctions Screening: Continuous screening against global sanctions and watchlists
• Reporting: Timely filing of Suspicious Transaction Reports (STRs) and other required reports
• Training: Regular AML/CFT training for all relevant staff
• Independent Audit: Periodic independent review of the AML/CFT program

4.2 Compliance Officer

Zuato has appointed a dedicated Money Laundering Reporting Officer (MLRO) responsible for:

• Overseeing the AML/CFT compliance program
• Reviewing and filing Suspicious Transaction Reports
• Liaising with regulatory authorities and the Financial Intelligence Unit
• Ensuring staff training and awareness
• Reporting to senior management and the Board

5. Identity Verification Technology

We leverage advanced identity verification technology to ensure accurate, reliable, and efficient verification of all merchants and their stakeholders.

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5.1 Verification Capabilities

6. Sanctions Screening

We maintain a robust sanctions screening program to ensure compliance with international and local sanctions requirements.

6.1 Screening Coverage

All merchants, beneficial owners, and related parties are screened against:

• OFAC: U.S. Office of Foreign Assets Control sanctions lists
• UN Security Council: United Nations consolidated sanctions list
• EU Sanctions: European Union consolidated sanctions list
• UK HMT: Her Majesty's Treasury financial sanctions
• UAE Local Lists: UAE designated persons and entities lists
• PEP Databases: Global Politically Exposed Persons databases
• Adverse Media: Negative news and media screening

6.2 Screening Frequency

• Onboarding: All parties screened before merchant activation
• Daily Batch: All active merchants rescreened against updated lists daily
• Real-time: Transaction-level screening for high-risk scenarios
• Trigger Events: Rescreening upon material changes or alerts

7. Transaction Monitoring

We employ sophisticated transaction monitoring systems to detect and investigate potentially suspicious activities in real-time and through periodic reviews.

7.1 Monitoring Approach

7.2 Key Monitoring Indicators

Our monitoring systems track various indicators including but not limited to:

• Unusual transaction volumes or values compared to merchant profile
• High velocity transactions in short time periods
• Excessive refunds or chargebacks
• Transactions from high-risk geographies
• Structuring patterns to avoid thresholds
• Mismatches between business type and transaction patterns
• Multiple failed transaction attempts
• Dormant accounts with sudden high activity

8. Risk Assessment

We employ a risk-based approach to compliance, applying enhanced measures to higher-risk merchants while maintaining efficient processes for lower-risk ones.

8.1 Risk Categories

8.2 Risk Factors Considered

• Industry Risk: Nature of business and associated ML/TF vulnerabilities
• Geographic Risk: Country of incorporation, operations, and transaction origins
• Customer Risk: Type of customers served by the merchant
• Product/Service Risk: Types of products/services offered
• Channel Risk: Sales channels and payment methods accepted
• Transaction Risk: Expected volumes, values, and patterns
• Ownership Risk: Complexity of ownership structure, presence of PEPs

9. Reporting Obligations

We fulfill all regulatory reporting obligations promptly and accurately, working closely with the UAE Financial Intelligence Unit and other relevant authorities.

9.1 Suspicious Transaction Reports (STRs)

When suspicious activity is identified, we file Suspicious Transaction Reports with the Financial Intelligence Unit (FIU) in accordance with UAE regulations. Our process includes:

• Initial detection through monitoring systems or staff reports
• Investigation and documentation by the compliance team
• Review and approval by the MLRO
• Filing with the FIU through the goAML portal
• Ongoing monitoring of the reported party

9.2 Other Regulatory Reports

• Currency Transaction Reports: Reports for cash transactions exceeding thresholds
• Sanctions Match Reports: Immediate reporting of confirmed sanctions matches
• Periodic Compliance Reports: Regular reports to the Central Bank as required
• Annual AML Return: Annual compliance certification and statistics

10. Record Keeping

We maintain comprehensive records of all customer due diligence, transactions, and compliance activities as required by regulation.

10.1 Retention Periods

Records are maintained in a secure, retrievable format and can be made available to regulatory authorities upon request.

11. Training & Awareness

We invest significantly in ensuring all staff understand their AML/CFT obligations and can effectively identify and report suspicious activities.

11.1 Training Program

• Induction Training: All new employees receive AML/CFT training within their first week
• Annual Refresher: Mandatory annual training for all staff
• Role-Specific Training: Enhanced training for compliance, onboarding, and customer-facing teams
• Regulatory Updates: Ad-hoc training when regulations or procedures change
• Case Studies: Regular review of typologies and real-world scenarios

11.2 Training Topics

• Overview of money laundering and terrorist financing
• UAE AML/CFT legal and regulatory framework
• Customer due diligence requirements
• Red flags and suspicious activity indicators
• Internal reporting procedures
• Sanctions and PEP requirements
• Record keeping obligations
• Consequences of non-compliance

12. Compliance Contact

If you have any questions about our compliance program, wish to report a concern, or need to contact our compliance team, please use the information below.

To report suspicious activity or concerns confidentially, please email mlro@zuato.com. All reports are treated with strict confidentiality.