AML & KYC Policy

1. POLICY STATEMENT

Sell Card For Cash FZ-LLC is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy is designed in accordance with the UAE Federal Decree-Law No. (20) of 2018 on AML and Combating the Financing of Terrorism and Illegal Organizations, and the regulations set forth by the Ras Al Khaimah Economic Zone (RAKEZ) authorities.

2. INTERNAL COMPLIANCE RESPONSIBILITY

The Company has appointed a designated Compliance Officer responsible for the implementation, administration, and ongoing oversight of this AML/KYC Policy, including the training of staff and coordination with UAE regulatory bodies.

3. RISK-BASED APPROACH

We apply a Risk-Based Approach (RBA) to accurately identify, mitigate, and manage money laundering and terrorist financing risks. Transactions, user profiles, and operational regions are continuously assessed for potential risks.

4. CUSTOMER DUE DILIGENCE (CDD)

While the site allows for streamlined guest checkouts to enhance user experience, the Company mandates Customer Due Diligence procedures triggered by algorithmic risk factors, high transaction volumes, or suspicious behavioral patterns. CDD requires the collection and verification of user identity prior to the completion of identified transactions.

5. ENHANCED DUE DILIGENCE (EDD)

For transactions or users categorized as high-risk, we apply Enhanced Due Diligence. EDD necessitates further investigative measures, including but not limited to establishing the source of funds, requiring formalized proof of purchase for submitted gift cards, and obtaining senior management approval for the transaction.

6. SANCTIONS SCREENING

Sell Card For Cash FZ-LLC actively screens all users, digital wallet addresses, and associated IP addresses against international and UAE-specific sanctions lists, including those issued by the UAE Executive Office for Control and Non-Proliferation, the United Nations Security Council, OFAC, and the European Union. We will immediately freeze transactions and reject users found on these lists.

7. ONGOING TRANSACTION MONITORING

Our systems employ continuous, automated logic to monitor transactions in real-time. This monitoring flags anomalous behaviors, structured transactions (smurfing), wallet address risk scoring, and geographic inconsistencies. All flagged transactions enter a mandatory 72-hour manual review period.

8. SUSPICIOUS ACTIVITY REPORTING

When a transaction or user activity is deemed actively suspicious and indicative of money laundering, fraud, or terrorist financing following investigation, the Compliance Officer is mandated to file a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR) with the UAE Financial Intelligence Unit (FIU) without notifying the user (tipping off).

9. RECORD RETENTION

In strict legal adherence to UAE AML legislation, Sell Card For Cash FZ-LLC retains all records regarding user identification, transaction data, correspondence, and findings of internal investigations for a minimum period of five (5) years following the completion of the transaction.