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AML Compliance Policy

HJ Real Estates LLC (“Company,” “we,” “us,” or “our”) is fully committed to complying with all applicable Anti-Money Laundering (AML) laws and regulations in the jurisdictions where we operate, including the United Arab Emirates (UAE). This AML Compliance Policy outlines our internal controls and procedures to prevent money laundering, terrorist financing, and related illicit activities.


1. Purpose of the AML Policy

The purpose of this Policy is to establish effective procedures and controls that detect, prevent, and report suspicious financial activity, in accordance with applicable AML/CFT (Combating the Financing of Terrorism) regulations in the UAE.


2. Scope of Applicability

This Policy applies to:

All users and investors interacting with the Company, including through the DU MORE mobile application

All Company employees, officers, agents, and third-party service providers


3. AML Compliance Officer

The Company has designated an AML Compliance Officer (AMLCO) to oversee implementation and enforcement of this Policy. Responsibilities include:

Monitoring user onboarding and transaction activities

Conducting ongoing risk assessmentss

Implementing KYC, CDD, and EDD protocols

Reporting suspicious activities to the relevant authorities


4. Customer Due Diligence (CDD)

4.1 Identification and Verification

Before onboarding an investor, the Company requires:

Full legal name

Date of birth

Residential address

Valid government-issued ID (e.g., Emirates ID, passport)

Proof of address (e.g., utility bill or bank statement)

4.2 Enhanced Due Diligence (EDD)

For higher-risk cases, additional checks may include:

Source of funds or wealth

Nature and purpose of the investment

Sanctions screening or adverse media checks


5. Transaction Monitoring

Although DU MORE does not facilitate direct in-app transactions, the Company monitors all offline investment activities to detect:

Large, irregular, or rapid transactions

Structured transactions to avoid reporting thresholds

Funds originating from or routed through high-risk jurisdictions

Suspicious patterns are flagged and may be escalated to the relevant financial intelligence units


6. Record Keeping

To comply with regulatory requirements, the Company retains: • Customer onboarding and verification records • Transaction records and payment history • Communications related to compliance or suspicious activities These records are retained for at least 5 years from the date of completion of the transaction or closure of the account.


7. Prohibited Activities

The Company strictly prohibits: • Accepting anonymous or unverified funds • Engaging with individuals or entities on sanctions or watchlists • Facilitating transactions linked to illegal activities


8. Reporting Suspicious Activity

Any suspicious activity will be reported to the UAE Financial Intelligence Unit (FIU) or other competent authorities through appropriate channels, including Suspicious Transaction Reports (STRs) as mandated under UAE law


9. Employee Training

We provide regular AML and compliance training to all relevant staff and partners to ensure awareness of: • Legal obligations • Risk identification • Proper procedures for due diligence and escalation


10. Consequences of Non-Compliance

Violations of this Policy may result in: • Termination of client relationship • Internal disciplinary action for staff or agents • Legal consequences, including regulatory penalties or criminal liability under UAE law


10. Governing Law

This AML Compliance Policy is governed by the laws of the United Arab Emirates (UAE). Any disputes will be subject to the exclusive jurisdiction of the Dubai Courts.


12. Contact Us

If you have any questions about this Privacy Policy, reach out to us:

📞 Phone: +971 54 378 1770

🏢 Address: 1104, Silver Tower, Business Bay, Dubai, UAE

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