Anti-Money Laundering (AML) Policy

Last updated: May 14, 2026

Bevona Trade Ltd is committed to full compliance with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) laws and regulations in the United Arab Emirates, including the UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism.

1. Purpose

This policy establishes the framework by which Bevona Trade detects, prevents, and reports activities that may involve money laundering, terrorism financing, or other financial crimes. All clients, employees, and partners of Bevona Trade are required to comply with this policy.

2. Know Your Customer (KYC)

We apply a risk-based KYC process to all clients before allowing them to deposit or withdraw funds. This includes:

• Identity verification: Government-issued photo ID (passport, Emirates ID, or national ID)
• Proof of address: Utility bill or bank statement dated within 3 months
• Source of funds: Documentation may be requested for large deposits or high-risk profiles
• Enhanced Due Diligence (EDD): Applied to Politically Exposed Persons (PEPs) and high-risk jurisdictions

3. Customer Risk Assessment

Each client is assigned a risk rating (Low, Medium, or High) based on factors including:

• Country of residence and nationality
• Nature of employment and source of income
• Deposit amounts and transaction frequency
• PEP status
• Adverse media or sanctions screening results

High-risk clients are subject to Enhanced Due Diligence and more frequent monitoring.

4. Sanctions Screening

All clients are screened against UAE Central Bank, UN Security Council, OFAC, EU, and UK HM Treasury sanctions lists upon registration and on an ongoing basis. Any match will result in immediate account suspension and reporting to the UAE Financial Intelligence Unit (UAEFIU).

5. Transaction Monitoring

We monitor all transactions for suspicious patterns including:

• Unusually large or rapid deposits and withdrawals
• Deposits from multiple sources followed by immediate withdrawals
• Trading activity inconsistent with the client's stated profile
• Requests to withdraw to accounts not used for deposit (structuring)
• Deposits from high-risk jurisdictions without adequate explanation

6. Suspicious Activity Reporting

Where we have reasonable grounds to suspect money laundering or terrorism financing, we are legally required to file a Suspicious Activity Report (SAR) with the UAE Financial Intelligence Unit (UAEFIU) without notifying the client ("tipping off" is a criminal offence). We maintain a designated Money Laundering Reporting Officer (MLRO) responsible for reviewing and submitting SARs.

7. Withdrawal Policy

In line with AML best practices:

• Withdrawals must be made to the same method and account used for the original deposit
• We do not process cash withdrawals or payments to third parties
• Large withdrawals may require additional documentation on source of funds
• We reserve the right to delay or refuse withdrawals pending AML investigation

8. Record Keeping

We retain all KYC documents, transaction records, and SAR filings for a minimum of 7 years in accordance with UAE regulatory requirements.

9. Staff Training

All Bevona Trade employees who interact with clients or transactions receive mandatory AML/CTF training on an annual basis and upon induction. Our MLRO maintains current knowledge of AML legislation and best practices.

10. Contact

For AML-related queries or to report concerns:
Money Laundering Reporting Officer (MLRO)
Bevona Trade Ltd, DIFC, Dubai, UAE
Email: compliance@bevonatrade.com
Phone: +971 54 168 3527