Why we ask, and what we check

Customer due diligence

Before an account can be funded, FBGM24 verifies the client’s identity using a valid government-issued photo document and confirms residential address with a recent utility bill, bank statement or equivalent. Electronic verification against independent databases is used where available, with manual review of any mismatch.

Enhanced due diligence — additional documentation, senior-management approval and closer monitoring — applies to politically exposed persons, clients from higher-risk jurisdictions and any relationship where the initial assessment indicates elevated risk.

Sanctions and PEP screening

All clients, beneficial owners and authorised signatories are screened against UN, EU, UK, US (OFAC) and UAE sanctions lists as well as PEP and adverse-media databases at onboarding and re-screened daily. Matches are escalated to the Money Laundering Reporting Officer (MLRO) for resolution before any account activity is permitted.

Source of funds and source of wealth

Cumulative deposits above 10,000 USD (or equivalent) in any rolling twelve-month period trigger a request for evidence of source of funds, such as payslips, bank statements, tax returns or sale contracts. For deposits above 100,000 USD, evidence of source of wealth is also required. Accounts may be restricted until satisfactory evidence is received.

Third-party payments

FBGM24 does not accept deposits from, or make withdrawals to, accounts held in a name other than the client’s. Payments received from third parties are returned to the originating account net of any bank charges.

Return-to-source withdrawals

Withdrawals are paid first to the payment method originally used to fund the account, up to the amount deposited by that method. Only once deposited funds have been returned may the remaining balance be withdrawn to a different verified method in the client’s name.

Transaction monitoring

Automated rules flag activity inconsistent with the client’s profile, including rapid deposit-withdrawal cycles with minimal trading, structuring of payments below reporting thresholds, sudden changes in funding source and trading patterns suggestive of market abuse. Flags are reviewed by compliance within one business day.

Reporting

Where FBGM24 knows or suspects that funds are the proceeds of crime or are linked to terrorist financing, a suspicious activity report is filed with the UAE Financial Intelligence Unit. The law prohibits FBGM24 from informing the client that a report has been made.

Record keeping

Identity documents, verification results, transaction records and correspondence are retained for at least six years after the end of the client relationship, in a form that can be produced to the regulator or law enforcement on request.

Staff training and governance

All staff complete AML training on joining and annually thereafter; client-facing and compliance staff complete additional role-specific modules. The MLRO reports to the board quarterly, and the programme is reviewed by an independent auditor each year.

Digital assets

Stablecoin deposits are accepted only from wallets the client has demonstrated control of. Blockchain analytics are used to screen incoming transactions for exposure to sanctioned addresses, mixers and known illicit services. Transactions with elevated risk scores are held for review and may be returned.