Legal policy on disclosure of information about administrators of exchangers

1. Introduction

This document outlines the legal disclosure policy for our exchange rate monitoring service. It details our obligations and procedures regarding the disclosure of information about exchangers' administrators in accordance with the United Arab Emirates (UAE) law.

Our company strictly complies with UAE and international anti-money laundering and counter-terrorist financing regulations. We cooperate with law enforcement agencies, including Interpol, to ensure transparency and legality of financial transactions.

2. Legal Framework

Our disclosure policy is governed by the following UAE laws and regulations:

• Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations (AML Law)
• Cabinet Decision No. 10 of 2019 Concerning the Implementing Regulation of Decree Law No. 20 of 2018
• Regulations Re Licensing and Monitoring of Exchange Business (N 1/2014) issued by the Central Bank of the UAE
• Federal Decree-Law No. 45 of 2021 on Personal Data Protection (PDPL)

3. Disclosure procedure

3.1. Receiving a request

• All requests for disclosure are received exclusively through the official channels of the UAE Ministry of Interior.
• Requests must be made in Arabic or English.

3.2. Verifying the legitimacy of the request

• Our legal department verifies the authenticity and legitimacy of each received request.
• If necessary, we request additional information or clarification from the UAE Ministry of Interior.

3.3. Scope of information disclosed about the administrators of the exchangers:

• Know Your Customer (KYC) information (including first and last name)

3.4. Terms of providing information

• The standard timeframe for processing a request is up to 10 working days.
• In the case of urgent requests related to crime prevention, the timeframe may be reduced to 3 working days.

3.5. Confidentiality

• All information provided is transmitted via secure communication channels.
• We do not disclose the fact that we receive a request or provide information to third parties, including the subjects of the request.

3.6. Refusal to provide information

• The Company reserves the right to refuse to provide information if the request does not comply with UAE law or international regulations.
• In case of refusal, we provide a reasoned explanation to the UAE Ministry of Interior.

4. Know Your Customer (KYC) Requirements

In compliance with Article 4 of the AML Law, we are obligated to:

• Identify and verify exchangers' administrators using reliable and independent sources
• Identify the beneficial owner and take reasonable measures to verify their identity
• Understand the purpose and nature of the business relationship

As per Article 16 of the AML Law, we must maintain all records obtained through KYC procedures for a minimum of five years from the date of termination of the business relationship or the closure of the account.

Under Article 9 of the AML Law, we are required to report suspicious transactions to the UAE's Financial Intelligence Unit (FIU) without delay.

7. Data Protection and Privacy

In accordance with the PDPL, we are committed to protecting the personal data of our exchangers' administrators. This includes:

• Obtaining explicit consent for data processing (Article 4, PDPL)
• Implementing appropriate technical and organizational measures to ensure data security (Article 10, PDPL)
• Respecting data subject rights, including the right to access, rectify, and erase personal data (Article 14, PDPL)

Any transfer of personal data outside the UAE will be conducted in compliance with Article 22 of the PDPL, ensuring adequate levels of protection in the recipient country.

8. Practical Implementation

• All exchangers will be required to provide necessary identification documents and information as part of our KYC process.
• Exchangers will be informed about our data collection and processing practices, and their consent will be obtained.

• Regular reviews of exchangers' information will be conducted to ensure compliance with AML regulations.
• Any significant changes in exchangers' behavior or transaction patterns will be subject to enhanced due diligence.

• Requests for information from regulatory authorities will be processed promptly, ensuring all disclosures are in line with legal requirements.
• Exchangers will be notified of any disclosure of their information, unless prohibited by law.

9. Conclusion

Our exchange rate monitoring service is committed to full compliance with UAE laws and regulations regarding information disclosure. We strive to balance our legal obligations with the protection of the exchange administrators' privacy rights. This policy is subject to regular review and may be updated to reflect changes in legislation or regulatory guidance.

For any questions or concerns regarding this policy, please contact our legal compliance department.