AML Policy

Effective date: 1 January 2026
Last updated: 2 October 2026

  1. Purpose and scope:
    This Anti-Money Laundering and Counter-Terrorist Financing Policy (the "Policy") is adopted by the company operating this website (the "Company"), registered in the United Arab Emirates. Its purpose is to prevent the Company's business from being used for money laundering, terrorist financing or sanctions evasion.

    The Policy applies to all settlements the Company receives from payment aggregators, whether by bank transfer or in virtual assets (USDT), and to the conversion of virtual assets into fiat currency. It binds the Director and all employees and contractors involved in handling these funds.

    The Policy is based on applicable UAE AML/CFT legislation, including Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and its implementing regulations (as amended or replaced from time to time), as well as relevant international standards, including the FATF Recommendations.
  2. Business model and flow of funds:
    The Company receives payment for its services through third-party payment aggregators. Settlements are normally made by bank transfer to the Company's corporate bank account. Where an aggregator's bank transfer channels are unavailable, it may settle in USDT instead.

    The Company does not hold or transfer virtual assets on behalf of customers and does not provide virtual asset services to third parties.

    USDT settlements move through the following steps:
    1. A payment aggregator sends a USDT settlement to a Company-controlled wallet.
    2. The Company screens the incoming transaction and its source wallet with AMLBot before using the funds.
    3. Cleared funds are exchanged into fiat currency through a licensed broker.
    4. The broker transfers the fiat amount to the Company's corporate bank account.
    The Company receives USDT only to wallets it controls and has registered with the relevant aggregator.
  3. Roles and responsibilities:
    The Director of the Company approves this Policy, is responsible for the Company's AML/CFT compliance and performs the compliance function. In this role, the Director:
    • runs and documents AMLBot screening of every incoming USDT settlement;
    • decides on the handling of medium- and high-risk transactions;
    • performs due diligence on payment aggregators and brokers;
    • keeps AML records and screening reports;
    • reports suspicious activity to the competent authorities where required;
    • reviews this Policy at least once a year.
    All staff who handle settlements must follow this Policy and inform the Director of any concern without delay.
  4. Risk-based approach:
    The Company applies a risk-based approach: controls are stronger where the risk is higher. The main risks in the Company's model are:
    • Source of funds risk: USDT received from an aggregator may originate from illicit sources (fraud, darknet markets, ransomware, mixers, sanctioned entities).
    • Counterparty risk: an aggregator or broker may have weak AML controls or be subject to sanctions.
    • Jurisdiction risk: counterparties may be linked to high-risk jurisdictions listed by FATF or subject to UN, UAE, OFAC, EU or UK sanctions.
    • Banking risk: tainted funds may lead to frozen assets, rejected transfers or loss of banking relationships.
    The Director reviews this risk assessment at least annually and whenever the Company adds a new aggregator, broker, network or currency.
  5. Counterparty due diligence:
    The Company works only with payment aggregators and brokers that have passed due diligence (KYB). Before onboarding, and again at least once a year, the Director collects and reviews:
    • certificate of incorporation, trade or operating license and registered address;
    • licenses or registrations relevant to payment or virtual asset activity, where applicable;
    • names of directors and ultimate beneficial owners holding 25% or more;
    • the counterparty's own AML/CFT policy or a confirmation of its AML controls;
    • the wallet addresses it will use to send settlements to the Company.
    Directors, beneficial owners and the entity itself are screened against sanctions lists (Section 7). The Company does not start or continue a relationship with a counterparty that refuses to provide this information, appears on a sanctions list, or presents a risk the Company cannot mitigate.
  6. Transaction screening with AMLBot:
    Every incoming USDT settlement is screened with AMLBot before the funds are exchanged, transferred or otherwise used. Screening covers both the transaction hash and the sending wallet, and checks exposure to risky sources such as sanctioned entities, mixers, darknet markets, scams, ransomware and stolen funds.

    The Director acts on the risk level assigned by AMLBot as follows:
    Risk level Action
    Low Funds cleared for exchange. Report saved.
    Medium Funds held. The Director reviews counterparty connections and requests an explanation from the aggregator. Funds are cleared only with a documented decision.
    High Funds frozen and not exchanged. Aggregator is notified and asked to explain. Return of funds or a report to the authorities is considered (Section 8).
    Direct sanctions exposure (any level) Funds frozen. No further action without legal advice. Report filed where required.
    The Director sets internal thresholds for each risk level and may adjust them based on experience, with the change recorded. A screening report is saved for every transaction and provided to the broker or bank on request as evidence of the source of funds.

    If the same aggregator repeatedly sends medium- or high-risk funds, the Company reviews and may end the relationship.
  7. Sanctions screening:
    The Company does not deal with persons, entities or wallets subject to sanctions. Counterparties, their directors and beneficial owners, and all sending wallets are screened against:
    • the UN Security Council Consolidated List;
    • the UAE Local Terrorist List;
    • OFAC (US), EU and UK sanctions lists.
    Screening takes place at onboarding, at every incoming transaction (wallet level, via AMLBot) and whenever the lists are updated for existing counterparties. A confirmed match leads to an immediate freeze of the related funds and the steps set out in Section 8.
  8. Suspicious activity reporting:
    Any employee who suspects that funds are linked to money laundering, terrorist financing or sanctions evasion reports it to the Director immediately. The Director investigates and documents the decision.

    Where the suspicion is confirmed and reporting is required, the Director files a report with the UAE Financial Intelligence Unit through the goAML platform without delay. Related funds are frozen until the matter is resolved.

    Staff must not inform the counterparty or any third party that a report has been or may be filed (no tipping-off).
  9. Record keeping, training and review:
    The Company keeps the following records for at least five years after the transaction or the end of the business relationship: counterparty due diligence files, AMLBot screening reports, decisions on medium- and high-risk transactions, exchange and bank transfer confirmations, and internal or external reports. Records are stored securely and made available to competent authorities, banks and brokers on lawful request.

    Staff handling settlements receive AML/CFT training at onboarding and at least once a year, including how to use AMLBot and how to recognise suspicious activity.

    The Director reviews this Policy at least once a year and whenever the business model, regulations or risk profile change. Changes take effect on the date they are published on this website.
"Skyline FZE" LLC
  • BLA-127, AMC - BOULEVARD-A BUILDING, Ajman Media City
    United Arab Emirates
  • contact@5sim.co
Access
Company