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How to eSign a document: eSignature legality for Notice of Promotion in UAE

introduced to attend this webinar on sanctioned compliance requirements in UAE so to introduce myself first I am Jyoti maheshwari from amluat amlua is a firm focused on assisting clients on anti-money laundering compliances in the United Arab Emirates as well as other GCC Nations we offer wide range of services around EML compliances which includes a go ml registration setting up in-house AML compliance Department assisting and documenting your AML policies and procedure and also assisting and selecting the appropriate AML screening software so while talking about this and on the popular demand of our clients and to complete our offering on AML compliance we are here presenting you the uh AML screening software castlem.ai to give you a brief about the solution so castlem.ei is one of the world's leading screening software which is uh powered on patented technology and is interest with International as well as country specific sanctions almost 1000 plus watch list and Inc global data on politically exposed person as well as shelf companies with this brief about the solution I'll also like to introduce to Mr Peter uh who is the chief executive officer and the co-founding member of the castle alum.ai solution before co-founding the software Peter was associated with United States Treasury Department serving in multiple roles and one of the role happens to be the advisory on the sanctions implementation so uh this is brief about the solution and the founder of the solution uh just one more information as Peter mentioned earlier uh before end of this webinar we will have a time to answer your questions in the meanwhile if you have any questions feel free to put it in the Q a section available at the bottom of your Zoom application so without much of Ado I'll request Mr Peter to discuss uh the AMS sanction screening requirements in the country and walk us through the software over to Uber thank you very much dirty really want to thank um AML UAE for for partnering with us I want to thank all the participants for taking time out of their busy evenings and just want to note that we are very much uh friends of the UAE we already have UAE clients we have UAE Partners we're very familiar with UAE law and requirements and our our goal here today is to help you understand how to not get fined because I mean up until pretty in the last couple of years it was possible to do a lot of things in the UAE in terms of financial transactions that were illegal in other places including Europe and the United States and the UK that has now changed how the UAE is definitely cracking down there have been fines on small organizations that we finds on banks there have been fines on International persons and so and for those of you that have not gotten a uh compliance system yet and are not doing screening that the time is definitely now and you don't don't take my word for it because we can all just Google uh UAE AML fines or sanctions fines and see what's out there so we're going to start kind of with um you know really really an overview of what are sanctions uh so what do we have to comply with because this is not like other laws sanctions are a restriction on a particular activity or party and they're intended to punish or incentivize a change in policy or behavior so somebody is for example a Iranian proliferator um or a Isis terrorist or you know Russian or Syrian government official sanctions are placed on them but sanctions can also be taken off and so these lists are Dynamic so that's very very important because the lists change and so you can't screen something once and be done now you have to screen them on a daily basis and that's really important um for the UAE you can you know on a daily basis uh in the United States I know that's this is not applied to you but just to let you know in the United States Regulators not expect people to be screening uh real time so basically continually uh but for the UAE once a day is is what will work so sanctions can Target a person uh sanctions can Target a company sanctions can Target a vessel uh an aircraft or a country or a sector of the economy so you can have sanctions against Peter piatesky you can have sanctions against let's say Emirates Air you have sanctions against a vessel or a maritime company or you can have sanctions against a country for example Iran but the sanctions that you really need to be concerned about are what's called list based so that's a name on a list and that is pretty straightforward and if you checked your customers and your transactions against a sanctions list so who um who has sanctions and where do they apply so sanctions are adopted by internet by governments and international bodies so governments like the United Arab Emirates International bodies like United Nations and the European Union all United Nations members are obligated to implement U.N sanctions uh and then some countries also add so some a lot of countries do a domestic list United Nations list and then they might add a third list or fourth list of big economies like let's say U.S sanctions or EU sanctions uh it is very very important and this is very good why we have kind of AML UAE here and that they are able to guide you in this process is understanding your legal requirements so as UAE businesses you need to be screening at a very minimum UAE sanctions and United Nations sanctions some of you may also choose to screen us and EU but you are not legally required to do that so that kind of depends on where you do business um you know some of you might say okay that's really wonderful that you came from the US and you've sanctioned people before and you're telling me what to do I don't care why should you why do you legally have to do this so UAE cabinet resolution 74 of 2020 requires all persons and legal entities including financial institutions and dnfbps to implement targeted Financial sanctions so there is a UAE law like a cabinet resolution 74 of 2020 which sets out the requirement and also sets out the fines um dnfps I remember the first time I heard the term I thought it was very strange now it's kind of stuck in my head but um dnfbps it's really anyone that touches money that is not a bank um it stands for designated non-financials businesses and persons so people in real estate precious metals and Stones lawyers notaries accountants corporate service providers uh so if you are if you have a very successful Kebab Restaurant where you sell food you don't have to you're not regulated but if you are lawyer notary accountant Jeweler um yes you you do especially if you're a retailer selling items over fifteen thousand dollars um sorry can you hear me okay um now you know which so Judy can you go on on mute so we don't have audio feedback thank you um so the office that implements Us in uh sorry here I am um is there the office in the UAE uh that manages is the office uh executive office for control and non-proliferation it publishes what is the UAE terrorist sanctions list and to comply with cabinet resolution 74 all businesses should check the local UAE list of sanctions and United Nations customers against so kind of what are we establishing first what are sanctions it's legal restrictions against individuals entities vessels aircraft locations that say you cannot do business with them um who has sanctioned UAE United Nations us EU what are your legal requirements in the United Arab Emirates uh it is to do UAE and un and pretend that's that's the legal requirement but then you can add additional ones what's a specific law cabinet resolution 74 and then what do you actually need to do like what does this look like in your day-to-day so you need to be screening current customers prospects and business transaction counterparties uh directors agents represented customer and ultimate beneficial owners so let's say I'm a maritime company you know I need to screen the companies I do business with I need to screen my employees and directors I need a screen my vendors so if I'm buying fuel from somebody and really it's kind of it's basically anyone you are giving money to or receiving money from uh it's very important to remember that kind of the uiee is in a pretty dangerous neighborhood it's a very safe and very prosperous business Haven but you have Iran which is one of the most ancient countries in the world you have a very large amount of uh Russian Nationals many of whom are sanctioned uh that are going there so the risk is very very large and continuous and now I'm going to I see we have some questions um so far then we'll get to those I now wanted to show a little bit with with the platform some examples all right so we have here the Costello May platform uh it says search sanctions for free so there's there's a free version the reason we have a free version is so that you don't have to take our word for anything you can test a platform out um so we encourage all of you to sign up if you never want to talk to us again you can still use it um but their paid version is kind of what you need to comply so you need to create an account and I just so everyone can see uh you you press the sign up button uh fill out this information you will be signed in as a reminder everyone there's a Code AML euae 20 which gives everyone a discount um so once you log in you're able to search Okay I want to search for sanctions politically exposed persons or I only want to do sanctions now here are um a couple of examples that are very relevant in terms of the risk that there is in the UAE so you search a name uh here you can see this is an individual on the UAE national list of terrorist individuals and entities why are they sanctioned the UA cabinet resolution number 20 their passport number where they're from and also the name in in Arabic now to kind of zoom out from this example if we do sanctions and look at United Arab Emirates there is actually a pretty significant amount of sanctioned companies and individuals uh this is a lot more than you have in I believe all of Europe combined so there's a very large amount of sanctions risk here both from the UAE as well as other countries um and you can also use a made platform to narrow the risk down so if you are a jeweler and you only do business individuals all right it's a bit smaller 109 you can see all the details here uh if it's and you want to look at entities uh here you go now you know as a business you collect information on on your customers you collect name uh IDs Etc so the screening platform allows you to search and screen by IDs as well so you can see here is the information uh you know it's not just an individual ID it's also you can search for business IDs and we're very good at only showing you uh true positives not a lot of false positive shown so you know if we have something different you see no matches uh that that's what we'll show you you can also change the threshold if you want to make sure that you're catching something now of course uh the solution would not be very useful if we couldn't search in Arabic so you can do your compliance screening in Arabic as well as a hundred other languages uh not not an issue and I want to show now kind of a workflow so this is um in the online platform what is free is doing searches in the searches and kind of the filters that I showed you but for you to do compliance and not get fined you need to keep records and so this is this is where the record keeping portion starts so we have this onboarding workflow and so I'd say okay I searched this name matched here and let's say I'll say this is a false positive um and you have three options here so really you can have a fresher be doing this or you could have a CEO be doing this and the results should be the same so it's a false positive why and I would say let's see ID is different date of birth is different and then I would say like customer document shows um that despite name match different person foreign you submit and you have an audit Trail here now let's say you um need to send a report on a daily basis someone or you want to keep records on on paper you can go and the generate a report which will show who did the screening what date and time this will have the time zone as well the score you did it what you checked what the results were so you can see an Arab the Arabic script is right here false positive gave full appendix of everything you searched so if you search less lists then you will get less kind of this will show less um now you don't have to do that because we also have an audit trail that is electronic so you can see all the searches I've done previously and you can see this is the one I did right now uh so you have this here and then another very important feature uh here is batch search so going to show you a a file here so you can location name IDs you can see I have Arabic Korean Chinese Russian and the batch file you know the search works very similarly and again geody enable UE are excellent at training everyone on this so um they can answer all of your questions as as can we but you let's say you have a customer file and you want to check it on a daily basis so this is how easy it is to do this so you just upload your customer file this file has an actual matches in it but this is kind of what it looks like say okay I have a true positive entity ID match and we are also adding a feature later this month which will allow you to schedule these screens uh so right now kind of you have to do this manually towards the end of this month it will be a uh where you say I want this to run every morning at 9am for example so I know we're about out of time uh but just kind of as a as a quick overview um you know we'll take a Stella mad platform you create an account here click on search sections for free uh to get access to the workflow and other features all the pricing is right here so you uh click here sign up now um promotion code AML uae20 and the features you can search in any language uh you can search IDs you can select your categories you can search peps as well there's batch screening electronic records so that's that's the platform and then to kind of really go back to why you care right no nobody does compliance because it's just fun uh we do it to make sure we're not doing business with terrorists and to make sure that we comply with the law so in the UAE all dnfbps have to screen customers and counterparties against UAE and U.N sanctions lists that's at a minimum uh fines for failure to screen sanctions are up to 1 million drum so that's over 250 000 that's a lot more than I want to pay for a fine I'm assuming the same is uh is uh for yourselves and transactions involving International wires should also be screened against us and EU it may be UK sanctions depending on where it's going so a big value add of the custom AI platform is the fact that we have all of the lists so you want UAE you want un you want OPAC it's all there you can test all of it mluas our local partner they can provide all the training and if you sign up before the end of the month you can use the promo code AML UAE for 20 off so again that will expire at the end of the month so I now want to stop and turn over to Jody and also answer questions thank you Peter so I think it was very insightful to have an overview of the compliance requirement anyway and also thank you for walking us through this illusion so I think uh uh we should take up the questions let's do it um I see there's one question um so regarding U.S and UK sanctions for effort 50 threshold on ownership and control um however such a professional does not provided an EU and U.N sanctions text therefore if an entity that is sanctioned in the uneu holds 40 of a third entity does the third entity become sanctioned even if not included in the uneu list so this this is um look this webinar is kind of a very sanctions 101 this question is kind of a sanctions 405s uh class but but the answer is pretty straightforward uh lists do not combine so first you need to start with what is my legal requirements so your legal requirements are UAE and un the UAE and un do not have 50 rules so you do not have to be you are not legally required to do this now should you perhaps worry about it you know is that something that you want to make sure you're covering uh that depends on on your risk and your risk tolerance I always advise people to not do more than they are legally required um so the first question kind of is if you are are you screening us and UK sanctions then you should care about it if you're only screening UAE and you win you don't um but in short kind of if a if a company is lists do not combine if an EU you don't kind of add ownership percentages across lists and if a company combined his own let's say 40 by something that it one is not sanctioned so you can legally do business with a company that is up to 49 percent Bones by someone that is sanctioned um let's see a question um how often is sanctions data updated in our platform thank you every five minutes so if some we check all the sources so we check UAE olfac Japan mofa India mha we check all this every five minutes and you will see things in our platform before you see them in the news um and we actually we issue corrections to governments all the time uh We've issued corrections to the U.S will issued corrections to Canada we've issued corrections to UK we've progressions to EU even the U.N so the data quality is excellent um and updated every five minutes and that's across all languages I see another question how many sanctions lists are connected globally um so in the platform we have over 1 000 watch lists let me answer the question of how many sanctions lists we have for you right now and also show you how I get that answer So within the platform we have list sources and categories so I'm going to select sanctions only and we have 446 sanctions lists and something that is is relevant to the question uh is actually how many how many countries have sanctions globally uh so we recently did published the global sanctions index so this will tell you which countries have sanctions so the the yellow here means no sanctions you can see the majority of countries in the world do not have sanctions um so these are the countries that do and those are the list that we have um the question are there any policies um for sanctions I think what you uh Samir I think what you mean by that question is like do you need policies and procedures the answer is yes um I would recommend you talk to geod afterwards because that is what um amlue is really excellent at is kind of structuring your policies and procedures um for the screening but the the policy and procedures would essentially look something like Samir batra LLC we screen our clients once a day against these lists when we have a match we follow the following instructions Etc so what Regulators generally look for is basically something that is so clear that you could have a junior person come in and understand exactly what to do um I see a question here from Dr Peter Wilson is a Tax Advisor a dnfbp I believe the answer is yes um it is um Russia is a software approved so governments don't approve software but if you look at our Advisory Board um one of our advisors is the head of enforcement for the UAE Central Bank um so to to me that is it says yes um and we do have uh priority UAE clients as well as um UAE government work um I think we'll let's see any any other questions yeah and I think you know the the question is is the software approved is a really good one because what you're essentially asking is is this reliable um the answer is yes you know we're we're we have former um treasury um former treasury of other U.S government Regulators uh who are running kind of this company you know we have advisors who are European and UAE government officials uh we have UAE and other government users clients and and contracts and we have uh over 1400 users globally so I think a big reason why people like the platform is because you can try it for free as you can test it out and then once you see okay I like the data I like the coverage I need the record keeping um that's when we urge you to kind of uh sign up so I know we're we're scheduled for 30 minutes and we're a little bit over um who is our divisor from the U Central Bank it is her academic here let me uh let me show you uh and for those of you interested to learn more about our company so as part of our team uh this is her family kind of enforcement at the Central Bank of the United Arab Emirates uh I'm a former treasury uh former state department and FBI as well as other former government officials so kind of we we very much know how to get people and Banks and dnfps find and so that helps us know how to not get you fine so I want to just confirm um Jody what is the correct if we can put the code in the chat yes we can do that I'll just put that go thank you um and then actually we have a question actually about uh relatives and Close Associates screening so let me get to that as well so we do have politically exposed persons here and so if I select I'm going to go here and select Global peps and then I'm going to select uh United Arab Emirates so this will show you we have 139 peps primary peps for the UAE and then you'll be able to see for example Abdullah Bin Zaid online you have his name aliases and then you have all of the people he's connected to this is a very large family so you can see his parents siblings uh and you can also go kind of up and down that tree your relationship tree and then you can also do that for uh you can do a workflow here so again I do want to be clear like you know today we're talking about sanctions sanctions are your legal requirements uh but pep screening is is encouraged and I feel like maybe we should probably do our next uh webinar for the UAE around uh peps so same same workflow here um Rockstar does that answer your question um Samir what if if someone is on a sanctions list is the family tree also part of the sanctions list uh no the answer is no so if I am sanctioned my mother and father are not sanctioned um and if let's say your wife or husband is sanctioned you are not sanctioned um but it's illegally you can still do that but then that becomes a question of of risk and you know here I'll show an interesting example so everyone of course is familiar with the Russia sanctions and Vladimir Putin most of you have probably never heard of Europe Austin Europe fossen is the son-in-law of Vladimir Putin so you can see some in love Vladimir Putin who is he connected to so this is his wife and these are the parents uh de Putin's and so if we look at the sanctions tree or sorry this relationship trade Maria veran Silva the daughter of Putin you'll now see she is sanctioned by Australia EU Switzerland Canada US UK Japan and France and she's a pet so not every pep is sanctioned not every sanctioned person is a pept but our platform does allow you to see this and again you know the looking things up is very important but what you need to then do is do your compliance and this is the most important part so moving from kind of the search to name match let's say name match ID match um customer rejected um uh business denied and then you have um UA government coming to you by the way if you see um I did maybe like 10 seconds of clicking uh and this is what I have this full standardized clean audit Trail uh and you can also export the report um I see another question from nandal is there adverse news uh there is uh I think Lindell my first question is kind of are you already doing sanctioned screening um and I I would say let's speak with uh got uh afterwards because if kind of the most important thing is to First make sure that you are doing sanctioned screening all right and then you can add you know path and negative new screening on top of that um what I will say about the pricing is sanctions perhaps export control all of that is included in the Costello mad platform um and there are unlimited searches so we do not charge you per search uh negative news is extra but we we do have it um I I want to conclude just because we have um I don't want to take up folks time but I want to very much thank everyone uh for the questions I especially want to thank Jordan ameluae and I want to thank all of our participants we'll definitely be doing another webinar um I encourage you to create an account and go to the costellomatic pricing page uh we will be sending kind of an email out afterwards with the discount code if you have any questions uh please follow up with us afterwards and again cabinet resolution 74 of 2020 it is not a joke there are fines already coming uh stay with us kind of ahead of the law and have a great evening everyone thank you everyone