Anti-Money Laundering (AML) Policy
Effective Date: August 21st, 2025
Company: Real Labs FZCO
Jurisdiction: Dubai Multi Commodities Centre (DMCC), United Arab Emirates
1. Introduction
Real Labs FZCO (“Real Labs,” “we,” “our,” or “us”) is committed to full compliance with the United Arab Emirates Federal AML/CFT framework, including Cabinet Decision No. (10) of 2019 concerning the Regulation of Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations, and the Dubai Multi Commodities Centre (DMCC) regulations.
As a blockchain software development company, we recognize the potential for blockchain technologies to be misused for illicit activities. This policy establishes our approach to preventing money laundering, terrorist financing, and related financial crimes.
2. Purpose
The purpose of this AML Policy is to:
Ensure compliance with applicable UAE AML/CFT laws and regulations.
Establish robust internal procedures to detect and prevent financial crimes.
Protect the integrity and reputation of Real Labs.
Promote transparency, accountability, and responsible innovation in blockchain technology.
3. Scope
This policy applies to:
All employees, contractors, and directors of Real Labs.
Business partners, clients, and vendors interact with Real Labs in various ways that may involve financial transactions.
Any activities conducted through our blockchain software, products, or related services that could fall under AML/CFT regulations.
4. Risk-Based Approach
Real Labs follows a risk-based approach (RBA) to AML compliance, which includes:
Identifying and assessing potential risks of money laundering and terrorist financing.
Implementing proportional controls based on risk level.
Prioritizing higher-risk activities, clients, or jurisdictions for enhanced due diligence.
5. Know Your Customer (KYC) and Due Diligence
Where applicable, Real Labs will:
Collect and verify the identity information of clients and business partners.
Screen parties against international sanctions and watchlists (e.g., UN, OFAC, EU).
Apply Enhanced Due Diligence (EDD) for high-risk clients, politically exposed persons (PEPs), and transactions involving high-risk jurisdictions.
6. Monitoring and Reporting
Transaction Monitoring: Where relevant, we will monitor transactions processed through our systems to detect unusual or suspicious patterns.
Suspicious Activity Reporting: Any identified suspicious activity will be promptly escalated and reported to the UAE Financial Intelligence Unit (FIU) in accordance with applicable law.
Record-Keeping: Records of customer identification, transaction monitoring, and suspicious activity reports will be retained for a minimum of five (5) years.
7. Training and Awareness
Real Labs provides ongoing training to relevant staff and contractors to ensure awareness of:
AML/CFT obligations under UAE law.
Methods and Typologies of Money Laundering and Terrorist Financing.
Internal escalation and reporting procedures.
8. Internal Controls
To ensure effective compliance, Real Labs will maintain:
An appointed AML Compliance Officer responsible for oversight and reporting.
Internal policies, procedures, and manuals to guide compliance practices.
Regular audits and reviews of AML procedures to ensure effectiveness and compliance.
9. Prohibited Activities
Real Labs strictly prohibits:
Engaging in business relationships with individuals or entities on UAE, UN, or other recognized sanctions lists.
Facilitating anonymous transactions that violate applicable laws.
Assisting or failing to report known or suspected money laundering or terrorist financing.
10. Cooperation with Authorities
Real Labs will cooperate fully with:
UAE regulators and law enforcement agencies.
International authorities, when required by applicable law.
DMCC regulatory oversight related to AML/CFT compliance.
11. Review and Updates
This AML Policy will be reviewed annually and updated as necessary to reflect changes in laws, regulations, or business operations.
12. Contact Information
For inquiries or reports related to AML compliance, please contact:
AML Compliance Officer
Real Labs FZCO
Dubai, United Arab Emirates
Email: [email protected]
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