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Anti-Money Laundering (AML) Policy

Last Updated: 4 February 2026

1. Introduction

CalibraMoney ("Company", "we", "us", or "our") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering Policy outlines our approach to adhering to applicable laws and policies.

2. Policy Framework

CalibraMoney operates as a trusted Money Services Business (MSB) and complies with:

  1. Applicable international anti-money laundering standards;
  2. International AML/CTF best practices and guidelines;
  3. Industry-standard financial crime prevention measures;
  4. Applicable local requirements in our operating jurisdictions.

3. Know Your Customer (KYC)

3.1 Customer Identification

Before establishing a business relationship, we verify the identity of all clients through:

  1. Collection of identity documents (government-issued photo ID);
  2. Verification of address through proof of address documents;
  3. Verification against official databases and sanction lists;
  4. Risk assessment based on customer profile and activities.

3.2 Customer Due Diligence (CDD)

Our due diligence procedures include:

  1. Standard Due Diligence: Applied to all clients during onboarding;
  2. Enhanced Due Diligence (EDD): Applied to higher-risk clients, including politically exposed persons (PEPs) and clients from higher-risk jurisdictions;
  3. Ongoing Due Diligence: Continuous monitoring of client transactions and periodic reviews.

3.3 Business Clients

For business clients, we additionally verify:

  1. Legal existence and registration;
  2. Ownership structure and beneficial owners;
  3. Nature of business activities;
  4. Source of funds.

4. Transaction Monitoring

We maintain systems and procedures to monitor transactions for suspicious activity, including:

  1. Automated monitoring for unusual transaction patterns;
  2. Monitoring for transactions inconsistent with customer profile;
  3. Review of large or frequent transactions;
  4. Identification of structuring or layering activities.

5. Suspicious Activity Reporting

When we identify suspicious activity, we:

  1. Document the activity and our analysis;
  2. File Suspicious Transaction Reports (STRs) with relevant authorities as required;
  3. Do not inform the client that a report has been or may be filed (tipping off prohibition);
  4. Cooperate with law enforcement requests and investigations.

6. Record Keeping

We maintain comprehensive records including:

  1. Customer identification and verification documents;
  2. Transaction records and supporting documentation;
  3. Risk assessments and due diligence records;
  4. Suspicious activity reports and related documentation.

Records are retained for a minimum of five years from the end of the business relationship or completion of the transaction, or longer if required by applicable law.

7. Risk Assessment

We conduct ongoing risk assessments to identify and mitigate money laundering and terrorist financing risks, considering:

  1. Customer risk factors (geographic location, industry, PEP status);
  2. Product and service risk factors;
  3. Delivery channel risk factors;
  4. Geographic risk factors.

8. Sanctions Screening

We screen all clients and transactions against applicable sanctions lists, including:

  1. United Nations sanctions lists;
  2. Office of Foreign Assets Control (OFAC) lists;
  3. EU and UK sanctions lists;
  4. Other applicable national and international sanctions.

We do not provide services to individuals or entities on sanctions lists or in comprehensively sanctioned jurisdictions.

9. Staff Training

All CalibraMoney staff receive:

  1. Initial AML/CTF training upon joining;
  2. Regular refresher training;
  3. Updates on policy changes and emerging risks;
  4. Role-specific training for policy and operations staff.

10. Policy Officer

We have designated a Policy Officer responsible for:

  1. Overseeing the AML programme;
  2. Ensuring adherence to applicable laws and policies;
  3. Reviewing and updating policies and procedures;
  4. Reporting to senior management and relevant authorities;
  5. Serving as the point of contact for policy enquiries.

11. Independent Review

Our AML programme is subject to periodic independent review to assess its effectiveness and identify areas for improvement.

12. Cooperation with Authorities

We cooperate fully with law enforcement and regulatory authorities in the investigation of potential money laundering, terrorist financing, or other financial crimes.

13. Policy Review

This policy is reviewed and updated at least annually, or more frequently as needed to reflect changes in regulations, business activities, or identified risks.

14. Contact

For questions about this policy, please contact:

Email: info@calibramoney.com
Address: Dubai