AML/CFT POLICY STATEMENT

The fight against Money Laundering is a priority for Orient Exchange Co. (L.L.C.). We recognize that the fight against Money Laundering and Terrorist Financing is team effort. We support the major International Organizations, which collectively set and enforce standards for Anti-Money Laundering and Counter-Terrorist financing policies and programs such as FATF, UN, The EU, The Organization of American States – The office of Foreign Assets Control (OFAC) and the Local Regulatory Authorities such as Central Bank of the UAE.

Orient Exchange Co. (L.L.C.) is committed to the highest standards of Anti Money Laundering (AML) compliance and requires management and employees to adhere to these standards to prevent use of our products and services for money laundering purposes, to safeguard the interest of our customers, our shareholders, our staff and the communities where we operate.

Adherence to the Orient Exchange Co. (L.L.C.) Anti-Money Laundering Program is the responsibility of all employees. The program is formulated and directed by the Risk & AML Compliance Unit. The program includes client screening through World Check System and monitoring requirements, “know your customer” procedures (including the requirement to establish the identity of beneficial owners), record keeping requirements, the reporting of suspicious circumstances in accordance with relevant laws, and mandatory training for all employees.

AML INITIATIVES IN UNITED ARAB EMIRATES

UAE has always recognized the importance of joining hands with International community on implementing Anti Money Laundering measures. The Central Bank of the UAE (CBUAE), as early as 1990, decided to adopt the various recommendations of FATF with the active and joint involvement of regulatory bodies including the National Anti Money Laundering Committee (NAMLC) and Subsequently the CBUAE has issued the “Money Laundering Law, “ 1) Circular No.24/2000-Regulation dated 14/11/2000 and related amendments 2) Regulation No.1815/2001dated 03/10/2001

FEDERAL LAW

Also the Regulators have implemented the Royal Decree No.72/2004 on Executive Regulations of the Law of Money Laundering issued on 28.6.2004.

AML INITIATIVES IN OEC

OEC in its endeavors recognizing the importance of combating Money Laundering activities has established effective controls and procedures in its financial operations. OEC has established its AML policies and procedures manual in compliance to the Money Laundering Law. Strict adherence to its KYC norms, with additional controls and efforts to train all staff members are done on a continuous basis. Newly recruited staffs are provided training on AML Compliance immediately after joining. All Staffs are subjected to examinations to test their knowledge on AML Policies and KYC Procedures.