Compliance Policy


Compliance with the regulatory requirements and supporting efforts to combat Money Laundering (ML), Terrorist Financing (TF), Proliferation Financing (PF) and Targeted Financial Sanctions (TFS) compliance is a sustained emphasis within the Organization and is directed by the Shareholder(s) and the Management.

Through this policy document, LM Exchange (“LME”) wishes to convey its position on Anti Money Laundering (AML), Combating Terrorism Financing (CTF), Combating Proliferation Financing (CPF) and Targeted Sanctions Compliance (TFS) reiterate that the Company shall conduct its business operations in total compliance with all applicable Laws, Regulations and international best practices.

LME shall consider the fight against Money Laundering, Terrorist Financing, Proliferation Financing & Sanction compliance as a high priority for our organization and recognize it as a team effort. LME shall support all the regulatory/advisory bodies globally such as FATF, OFAC, UN, EU, HM and the local regulatory authority, namely the Central Bank of the UAE  which collectively sets and enforces standards for anti-money laundering and counter terrorist financing policies and programs and The Executive Office for Control and Non-Proliferation (EOCN) which plays an active role in implementing export control besides curbing the proliferation of weapons of mass destruction with relevant associated technology, based on policies, legislations and partnerships domestically and internationally.

LME also respect and follows international best practices/guidances such as Basel Committee, Wolfsburg, FATF, Middle East & North Africa Financial Action Task Force (MENAFATF), Financial Crimes Enforcement Network (FINCEN) etc.

The Company is operating in the UAE (it has no branches outside of the UAE) under license from the CBUAE to offer financial services products such as Remittance, Foreign Currency Exchange and payment of wages using the WPS. In this respect, it is under the legal and regulatory obligation to design and implement formal and effective AML, CFT, CPF & TFS Compliance Policies and Procedures, based on the Law, Regulations, Guidelines & the “Standards” V 1.20 Chapter 16 of the AML/CFT Compliance.

The Company assessed the inherent risks associated with its business nature, size, and complexity, and has implemented additional AML, CFT, CPF & TFS procedures, systems, controls, and measures appropriate to its risk profile to identify, assess, and act on ML, FT, PF & Sanction evasion risks by applying a thorough Risk-Based Approach (RBA).

The Company’s Owners/Board of Directors has nominated and appointed a Compliance Officer (CO), supported by an Alternative Compliance Officer (ACO), both have been approved by the CBUAE – to direct and manage the AML, CFT, CPF and Sanctions Compliance Program.  The Owners/Board of Directors have also appointed a Manager in Charge/General Manager (GM) – approved by the CBUAE – to run the day-to-day operations of the Company, and together with the Compliance officer are responsible for effectively implementing the AML, CFT, CPF & TFS Compliance and Sanctions Program of the Company.