Section 1
1. Our Commitment
Velmont Crest is committed to preventing its services from being used for money laundering, terrorist financing or the financing of illegal organisations. This commitment is anchored in Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism (as amended) and Cabinet Resolution No. 134 of 2025 issuing its Implementing Regulation.
Accounting service providers fall within the UAE AML framework's designated non-financial businesses and professions (DNFBP) perimeter. We treat that seriously: the controls on this page apply to every engagement, every client and every transaction we touch — regardless of size.
Section 2
2. Client Due Diligence
We do not begin work for a client we have not identified. Before an engagement starts — and on an ongoing basis during it — we perform client due diligence proportionate to the risk presented:
2.1 What due diligence involves
- Identification and verification. — Verifying the identity of the client and, for entities, of the natural persons who ultimately own or control it (ultimate beneficial owners), using reliable, independent documents — trade licence, passport/Emirates ID, ownership structure documents.
- Understanding the business. — Establishing the purpose and intended nature of the relationship: the client's activities, licence scope, expected transaction patterns and source of funds where the risk profile requires it.
- Risk classification. — Assigning a documented risk rating (including politically exposed person screening and geography/activity risk) that determines the depth of ongoing monitoring and the frequency of periodic review.
- Enhanced due diligence. — Applying deeper measures — senior approval, source-of-wealth evidence, closer monitoring — where the risk assessment, PEP status or geography requires it.
Section 3
3. Targeted Financial Sanctions Screening
Clients and their beneficial owners are screened against the UN Security Council Consolidated List and the UAE Local Terrorist List before onboarding and on an ongoing basis. A confirmed match results in immediate refusal or suspension of the engagement, freezing measures where the law requires them, and reporting to the competent authorities without notice to the client (tipping-off is prohibited).
Section 4
4. Ongoing Monitoring
Because we maintain clients' books month by month, we are positioned to notice what one-off advisers cannot: transactions inconsistent with the client's known profile, unexplained third-party settlements, cash intensity that does not match the licence activity, or documentation that does not withstand reconciliation. Monitoring is continuous, and engagement files are refreshed at the periodic review the client's risk rating requires.
Section 5
5. Suspicious Transaction Reporting
Where we know, suspect or have reasonable grounds to suspect that funds are the proceeds of crime or linked to terrorist financing, we file a suspicious transaction report (STR) or suspicious activity report (SAR) with the UAE Financial Intelligence Unit through the goAML platform, as the law requires. UAE law prohibits disclosing to the client — directly or indirectly — that a report has been or may be filed. Filing obligations under the AML framework override contractual confidentiality.
Section 6
6. When We Decline or Exit
We decline to onboard — or exit — where due diligence cannot be completed, where identification documents are withheld or appear unreliable, where the beneficial ownership cannot be established, or where the requested work would facilitate concealment of the origin, ownership or destination of funds. No fee justifies accepting that risk.
Section 7
7. Record Retention
Due-diligence records, transaction records and engagement files are retained for at least five (5) years from the end of the business relationship or the date of the occasional transaction, as required by the UAE AML framework — and longer where UAE tax legislation requires extended retention. Retention and data-protection handling follow the schedule in the Privacy Policy.
Section 8
8. Competence and Training
The practice maintains current knowledge of UAE AML obligations, typologies and red flags relevant to accounting work, and reviews this policy at least annually — and immediately upon any material change in the UAE AML framework, Cabinet Decisions or supervisory guidance.
Section 9
9. AML Advisory for Clients
Separately from this internal policy, Velmont Crest provides AML compliance advisory services to DNFBP clients — goAML registration support, AML policy drafting, risk assessments and screening workflows. That advisory work is delivered in the same advisory, preparation and support capacity described in the Advisory Disclaimer: the client remains the regulated person responsible for its own AML obligations.
