Politica Antiriciclaggio (AML)

1. Introduction

This AML Policy applies to all users accessing or using the services of Elite Consulting Club (Elite Consulting FZC-LLC), including company setup and offshore company services.

By using our Services, you agree to comply with this AML Policy and all applicable laws and regulations. If you do not agree with any part of this policy, please refrain from using our Services.

2. Key Definitions

• User (You): Any individual or entity accessing or using the website, web application or Services.
• Services: Products and services offered by Elite Consulting Club, including offshore company setup and related services.
• AML: Anti-Money Laundering laws and regulations designed to prevent money laundering and terrorism financing.
• KYC: Know Your Customer processes aimed at verifying the identity and legitimacy of clients.
• PEP: A Politically Exposed Person, being an individual entrusted with a prominent public function, together with their family members and close associates.
• Source of Funds / Source of Wealth: The origin of the specific funds used in an engagement and the origin of a client's overall wealth, respectively.
• FIU: The UAE Financial Intelligence Unit, to which suspicious activity is reported via the goAML platform.

3. Compliance with Laws

The company operates in full compliance with local, national and international AML and Counter-Terrorism Financing (CTF) regulations, including the laws of the United Arab Emirates and the standards of the Financial Action Task Force (FATF).

4. Prohibited Activities

Users shall not use the Services for any unlawful activity, including money laundering, financing terrorism, fraud, circumventing sanctions or any other activity that violates applicable law.

5. AML Controls

5.1 Due Diligence

The company uses industry-leading systems such as AidKYC, Onfido and SumSub to conduct due diligence, including identity document verification, proof of address collection, and information gathering on business activities and ultimate beneficial owners (UBOs).

5.2 Ongoing Monitoring

The company continuously monitors transactions and client activities to identify and mitigate suspicious or unusual patterns.

5.3 Record Keeping

The company securely retains records of transactions, due diligence documentation and monitoring data for the periods required by law.

6. User Responsibilities

6.1 Compliance with Laws

Users agree to comply with all applicable local, national and international laws and regulations when using the Services.

6.2 Prohibited Activities

Users shall not use the platform for unlawful purposes, including money laundering, financing terrorism, fraud or any law-violating activity.

6.3 Account Security

Users are responsible for maintaining the confidentiality of their account credentials and for all activities conducted under their account.

6.4 Accurate Information

Users agree to provide truthful and accurate information and to promptly update any changes to ensure compliance with legal obligations.

7. Eligibility

To use the Services, users must be at least 18 years old and have the legal capacity to enter into binding agreements, providing accurate and complete information during registration with prompt updates for any changes.

8. Unsupported Countries and Industries

8.1 Unsupported Industries

The company does not provide services to businesses involved in:

• Weapons dealing
• Pornography or adult entertainment
• Marijuana-related businesses
• Money service businesses
• Gambling-related businesses
• Money remittance and payment services
• Tobacco businesses
• Alcohol businesses
• Debt loan collection businesses
• Precious metal or stone trading businesses
• Sensitive virtual asset businesses
• Oil and gas businesses
• Government services
• Lending and credit services
• Investment and brokerage services
• Bank account funding
• Buy Now Pay Later services
• Debt collection agencies
• ATMs
• Insurance services
• Money transmitters, remittances and currency exchange services
• Peer-to-peer money transmission
• Escrow services
• Neobanks or challenger banks
• Check cashing
• Payable-through accounts
• Funded prop trading
• Shell banks
• Selling bearer shares
• Other financial services
• Prop firms
• Prop firms with demo accounts
• Online pharmacies
• Prescription-only products and pharmaceuticals
• Prescription delivery services
• Age-restricted goods or services
• Payment facilitation and aggregation
• Multi-level marketing
• Telemedicine and telehealth services
• Tobacco products (including e-cigarettes, cigars, e-liquid)
• Herbal cigarettes
• Production equipment marketed for tobacco product production

8.2 Unsupported Countries

The company does not offer services to nationals from the following countries:

• Afghanistan
• Algeria
• Belarus
• Bhutan
• Brunei
• China
• Cuba
• Iran
• Iraq
• Libya
• Myanmar
• North Korea
• Pakistan
• Russia
• Somalia
• South Sudan
• Syria
• Venezuela
• Vietnam
• Yemen
• Zimbabwe

9. Anti-Money Laundering Compliance

9.1 AML Controls

The company reserves the right to implement strict AML controls in accordance with UAE laws and international standards.

9.2 Due Diligence

The company reserves the right to conduct due diligence, including identity verification and background checks.

9.3 Reporting Obligations

The company is obligated to report suspicious activities to the relevant authorities without prior notice to users.

9.4 Client Cooperation

Users agree to provide all necessary information and documentation promptly upon request.

9.5 Refusal of Service

The company reserves the right to refuse or terminate services if users fail to comply with AML requirements or engage in suspicious activities.

10. Sanctions and PEP Screening

As part of onboarding and on an ongoing basis, the company screens users, their beneficial owners, controllers and connected parties against applicable sanctions, watchlists and adverse-media sources, including but not limited to the United Nations (UN) Security Council Consolidated List, the United States Office of Foreign Assets Control (OFAC) lists, the European Union (EU) consolidated sanctions list, the United Kingdom HM Treasury (HMT / OFSI) list, and the United Arab Emirates (UAE) Local and UN-based Targeted Financial Sanctions lists.

The company applies a risk-based approach. Where a user is identified as a Politically Exposed Person (PEP), a family member or close associate of a PEP, or is otherwise assessed as high-risk, the company will apply Enhanced Due Diligence (EDD), which may include senior-management approval to establish or continue the relationship, additional identity and background verification, and closer ongoing monitoring.

Where a positive or potential sanctions match is identified, the company may suspend, delay, freeze or decline the engagement and any associated transaction, and may be required to report the match and withhold the funds or documents concerned, in each case as required by applicable law and without liability to the user.

11. Source of Funds and Source of Wealth

For higher-risk relationships and high-value engagements, the company requires verification of both Source of Funds (the origin of the specific monies used in the engagement) and Source of Wealth (the origin of the user's overall wealth).

The user agrees to provide supporting evidence on request, which may include bank statements, audited financial statements, tax records, contracts, sale-of-asset documentation, inheritance or gift documentation, or other reasonable evidence. The company may decline, suspend or unwind an engagement where source of funds or source of wealth cannot be satisfactorily established.

12. Prohibition on Tipping-Off

Where the company files, or is considering filing, a report of suspicious activity with a competent authority, applicable law strictly prohibits "tipping-off" — that is, disclosing to the user or to any third party that a report has been or may be made, or that an investigation is being or may be carried out.

Accordingly, the user acknowledges and agrees that the company may be legally barred from informing the user of any such report, review, freeze or investigation, and that the company will not be liable for any inability to explain a delay, suspension, freeze, refusal or termination that arises from these obligations.

13. Record Retention

The company retains KYC records, due diligence documentation, transaction records, screening results and related correspondence for a minimum of five (5) years after the end of the business relationship or the completion of a transaction, or for any longer period required by applicable law or by a competent authority. Records may be retained beyond this period where an investigation, order or legal requirement so requires.

14. Suspicious Activity Reporting

Where the company knows, suspects or has reasonable grounds to suspect that funds, property or an engagement are connected with money laundering, terrorism financing, sanctions evasion or the proceeds of crime, the company is required by law to file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the UAE Financial Intelligence Unit (FIU) via the goAML platform.

Such reports are made without prior notice to the user and may include the sharing of the user's personal data, documents and transaction information with the FIU, regulators, law-enforcement agencies and other competent authorities. Subject to the prohibition on tipping-off, the user will not be notified of the fact or content of any such report.

15. Freezing, Delay and Refusal of Transactions

The company reserves the right, acting in its sole discretion or as required by law, to freeze, delay, decline, suspend or reverse any transaction, payment, onboarding or service, and to freeze, withhold or place a hold on documents, deliverables and funds pending the completion of KYC, due diligence, sanctions or source-of-funds checks, or pending the outcome of a report to a competent authority.

Where a competent authority, regulator or court issues a freezing, seizure, disclosure or asset-restraint order, the company will comply with that order, including by freezing or holding assets, funds and documents for the period the order requires. The company will not be liable to the user for any loss arising from action taken in good faith to comply with such an order or with its legal obligations.

16. Reporting Obligations

The company is required by law to report suspicious activities to the relevant authorities without prior notice, including sharing client information with government entities, regulators and law-enforcement agencies.

17. Client Cooperation and Non-Cooperation

The user agrees to cooperate fully and promptly with all KYC, due diligence, sanctions, PEP and source-of-funds requests, and to provide accurate, complete and up-to-date information and documentation on request.

Failure to cooperate — including refusing, delaying or providing false or incomplete information — will be treated as a breach of this policy and may result in the suspension or termination of the relationship and the withholding of services, documents and deliverables. Where a relationship is suspended or terminated for AML/KYC non-compliance or suspicious activity, no refund of any fees paid will be issued.

18. Cooperation with Law Enforcement and Regulators

The company cooperates fully with law-enforcement agencies, regulators, the FIU and other competent authorities, and will respond to lawful requests, orders and investigations. This may include disclosing user information, documents and transaction records, and complying with production, freezing or asset-restraint orders, in each case as required by applicable law and, where required, without notice to the user.

19. Account Suspension and Termination

19.1 Regulatory Requests

Accounts may be suspended or terminated based on orders from regulatory or law-enforcement authorities.

19.2 Non-Compliance

If users fail to meet AML/KYC requirements or engage in suspicious activities, accounts may be suspended or terminated without notice.

19.3 Cooperation with Authorities

Users are obligated to cooperate with any investigations or requests from governmental authorities.

20. Refusal and Termination of Service

The company reserves the right to refuse or terminate services if users fail to meet AML compliance requirements or engage in suspicious activities. No refunds will be issued in such cases.

21. Training and Awareness

All employees and agents undergo regular AML/CTF training to stay informed of regulatory changes and to maintain awareness of evolving threats.

22. Data Protection

All personal data collected for AML purposes is handled in accordance with our Privacy Policy and applicable data-protection laws, used solely for compliance purposes, and stored securely with access limited to authorised personnel.

23. No Liability for Compliance Measures

The user acknowledges that the compliance measures described in this policy are undertaken to satisfy legal and regulatory obligations. Accordingly, to the fullest extent permitted by applicable law, the company shall not be liable for any loss, delay, cost, expense, loss of profit, loss of opportunity or other damage of any kind, whether direct or indirect, suffered by the user or any third party arising out of or in connection with:

• Requests for KYC, Customer Due Diligence or Enhanced Due Diligence information or documentation, and any time taken to review them;
• Sanctions, PEP, adverse-media or other screening, and any resulting matches, escalations or reviews;
• Delays in verification, onboarding, service delivery or the release of documents, deliverables or funds pending compliance checks;
• The freezing, holding, delay, decline, suspension or reversal of any transaction, engagement or service;
• The refusal of onboarding, the suspension or termination of the relationship, or the withholding of services under this policy;
• Any report, disclosure or filing made in good faith to the FIU, a regulator, a law-enforcement agency or any other competent authority, whether or not the underlying suspicion is subsequently substantiated.

Compliance measures may be applied at any time and without prior notice, and, subject to the prohibition on tipping-off, without explanation. The user further acknowledges that fees remain due and payable, and amounts already paid remain non-refundable, during any compliance hold, review, freeze or investigation, and that the application of a compliance measure does not constitute a breach of contract or a failure of service by the company.

24. Client Indemnity for AML-Related Losses

The user agrees to indemnify, defend and hold harmless the company, its owners, shareholders, directors, officers, employees, agents and representatives (together, the "Indemnified Parties") from and against any and all fines, penalties, sanctions, losses, damages, liabilities, claims, demands, actions, investigations, judgments, settlements and costs (including full legal and professional costs on an indemnity basis and the costs of responding to regulatory or law-enforcement enquiries) suffered or incurred by any Indemnified Party arising out of or in connection with:

• The user's breach of any applicable AML, CTF, sanctions or anti-financial-crime law or regulation, or of this policy;
• The provision by the user, or by any person acting on the user's behalf, of false, misleading, inaccurate or incomplete information or documentation, or the failure to update such information;
• The use of any entity, structure, bank account or other arrangement formed, introduced or facilitated through the Services for money laundering, terrorism financing, sanctions evasion, fraud, tax evasion or any other illicit purpose;
• Any claim by a third party, regulator or authority attributable to the user's acts, omissions or misrepresentations.

This indemnity is a continuing obligation, applies regardless of whether the relevant engagement has completed or the relationship has ended, and survives the suspension or termination of the Services and of this policy.

25. Ongoing Monitoring and Periodic Re-Verification

The user acknowledges that KYC is not a one-off exercise. The company conducts ongoing monitoring of the business relationship and may, at any time and at its sole discretion, require the user to provide updated identity documents, refreshed proof of address, current corporate and UBO information, renewed source-of-funds or source-of-wealth evidence, or to complete a full re-verification of the relationship.

Re-verification may be required periodically (in line with the user's risk rating), on the occurrence of trigger events (including changes in ownership, control, business activity, jurisdiction, transaction patterns or adverse information), or following a change in the user's risk classification.

The user agrees to comply with any such request within the deadline stated in the request. Failure to comply within the stated deadline entitles the company to suspend or terminate the relationship and any pending engagement, and to withhold services, documents and deliverables, in each case without refund of any fees paid and without liability to the user.

26. Reliance on Third-Party Screening and Data Providers

In performing its compliance obligations, the company may rely in good faith on external screening databases, sanctions and watchlist providers, public and commercial registries, credit and identity bureaus, and third-party verification providers (including the systems referred to in Section 5 of this policy), as well as on information published by governments, regulators and international bodies.

The user acknowledges that such third-party sources are outside the company's control and may contain errors, omissions, duplications or outdated information. To the fullest extent permitted by applicable law, the company shall not be liable for any inaccuracy, incompleteness or lack of currency in third-party data, nor for any action taken in good-faith reliance on such data — including delays, escalations, freezes, refusals, suspensions, terminations or reports resulting from a false positive or a mistaken match — even where the information relied upon is later shown to have been incorrect.

27. Tax Information Exchange (FATCA/CRS)

The user acknowledges that entities, structures and financial accounts formed, introduced or facilitated through the Services may be reportable under the U.S. Foreign Account Tax Compliance Act (FATCA), the OECD Common Reporting Standard (CRS) and other automatic exchange-of-information or tax-transparency frameworks applicable in the relevant jurisdictions, and that financial institutions, registries and authorities may exchange information about the user, its controlling persons and its accounts accordingly.

The user is solely responsible for its own tax residence determinations, tax reporting, filings and self-certifications (including FATCA and CRS self-certification forms) in every relevant jurisdiction, and for the accuracy and completeness of the information given in them. The company may provide information about the user to banks, financial institutions, registries and competent authorities where required to do so under these frameworks or by applicable law, without liability to the user.

Nothing provided by the company constitutes tax advice. The user should obtain independent, professional tax advice in respect of its own circumstances before entering into any engagement.

28. No Fiduciary Relationship

Nothing in this policy, and no compliance interaction, screening, review, request, communication or measure carried out under it, creates — or shall be construed as creating — any fiduciary, advisory, protective, trustee or agency duty owed by the company to the user or to any third party.

The user acknowledges that the compliance measures described in this policy are performed by the company to satisfy its own legal and regulatory obligations, and not as a service to, or for the benefit or protection of, the user or any third party. The user remains solely responsible for its own legal, regulatory, tax and commercial compliance, and no completion of KYC, screening or due diligence by the company constitutes an endorsement, clearance or assurance of the user, its structures or its activities.

29. Governing Law and Jurisdiction

This AML Policy is governed by the laws of the United Arab Emirates. Subject to any applicable mandatory law, the courts of Dubai shall have exclusive jurisdiction over any dispute arising out of or in connection with this policy. The English-language version of this policy is the governing version.

30. Policy Updates

This AML Policy may be updated at any time to reflect regulatory changes or company operations, with updates taking effect immediately upon posting.

31. Contact Information

For questions about this AML Policy, please contact us:

• Trading name: Elite Consulting Club
• Legal entity: Elite Consulting FZC-LLC
• TRN: 104062296900003
• Registered address: Sharjah Publishing City (SPC) Free Zone, Sheikh Mohammed Bin Zayed Rd, Sharjah, United Arab Emirates
• Email: [email protected]
• Phone: +971 502733997
• Website: https://eliteconsultingclub.com
• Hours: Monday to Friday, 9:00 AM – 6:00 PM GST