Aurne PRIVATE ADVISORY – KNOW YOUR CUSTOMER (KYC) & CLIENT ONBOARDING POLICY

1. Introduction

This KYC & Onboarding Policy outlines the due diligence standards and onboarding procedures followed by Aurne Private Advisory ("Aurne", "we", "our", "us") in compliance with UAE laws and international best practices.

As a Designated Non-Financial Business or Profession (DNFBP) under UAE AML laws, Aurne must verify the identity, legitimacy, and risk profile of clients before establishing a business relationship or providing any services.

This Policy applies to all:

• Clients and prospective clients
• Beneficial owners
• Shareholders and directors
• Authorized representatives
• Third parties acting on behalf of clients
• All jurisdictions and service types

2. Regulatory Framework

This Policy is governed by the following. For comprehensive details on our AML/CTF framework, see our AML & CTF Statement.

2.1 UAE Legislation

• Federal Decree-Law No. 20 of 2018 (AML Law)
• Cabinet Decision No. 10 of 2019 (Executive Regulations)
• Cabinet Decision No. 58 of 2020 (UBO Regulations)
• Cabinet Resolution No. 57 of 2020 (ESR Regulations)
• Ministry of Economy DNFBP guidelines
• Federal Decree-Law No. 45 of 2021 (PDPL – Personal Data Protection Law)

2.2 International Frameworks

Where applicable:

• FATF Recommendations
• OECD transparency standards
• EU/UK AML expectations

3. Objectives of KYC & Onboarding

The KYC & Onboarding framework ensures:

• Verification of client identity and beneficial ownership
• Understanding of client structure, business purpose, and risk profile
• Prevention of money laundering, terrorist financing, and sanctions violations
• Integrity of Aurne's client portfolio
• Compliance with regulatory obligations
• Protection of Aurne and its clients from illegal activities

No service begins without completing KYC.

4. Scope of KYC Requirements

Aurne's KYC applies to:

• Individuals
• Corporations
• Partnerships
• Foundations / Trusts
• Offshore/onshore entities
• Free zone and mainland companies
• Nominee arrangements (with strict justification)
• Complex and cross-border structures

5. Onboarding Process Overview

The onboarding process includes:

5.1 Initial Inquiry Screening

• Preliminary analysis of client request
• High-level assessment of activity, jurisdiction, and risk
• Identification of potential red flags

5.2 Document Collection

Aurne sends a formal KYC requirement checklist tailored to the client's structure and jurisdiction.

5.3 Verification & Screening

• ID verification
• Sanctions and PEP screening
• Adverse media review
• Document authenticity checks

5.4 Risk Assessment

Each client is classified as:

• Low Risk
• Medium Risk
• High Risk
• Prohibited / Declined

5.5 Approval or Rejection

• Low/Medium risk: standard onboarding
• High risk: requires Enhanced Due Diligence (EDD) and senior management approval
• Prohibited: declined immediately

5.6 Engagement Letter & Payment

On successful approval:

• Engagement Agreement is issued
• Payment terms outlined
• Work commences

6. Mandatory KYC Documentation

6.1 For Individual Clients

• Passport copy (valid)
• Emirates ID (if applicable)
• Residential address proof
• CV or professional background
• Source of Funds (SOF) declaration
• Source of Wealth (SOW) declaration (if required)
• Bank reference letter (if required)

6.2 For Corporate Clients (UAE or Foreign)

• Certificate of incorporation / formation
• Memorandum and Articles of Association
• Share register
• Board resolution authorizing engagement
• UBO declaration
• Corporate chart
• Trade license (for UAE entities)
• Proof of physical address

6.3 For Beneficial Owners & Key Individuals

• Passport
• Address proof
• KYC form
• Source of funds/wealth evidence
• KYC for directors/shareholders

6.4 Additional Documents (Risk-Dependent)

• Bank statements (3–12 months)
• Audited/unaudited accounts
• Tax declarations
• Proof of business activity
• Contracts or invoices
• Legal opinions
• Regulatory licenses

7. Enhanced Due Diligence (EDD)

Aurne applies EDD when risk factors include (see AML & CTF Statement for comprehensive EDD framework):

• Politically Exposed Persons (PEPs)
• High-risk jurisdictions (FATF list)
• Complex offshore structures
• Cryptocurrency involvement
• Cash-intensive activities
• Legal/litigation exposure
• Unclear source of wealth

EDD measures include:

• Senior management approval
• Additional SOF/SOW documentation
• Independent verification
• Third-party background reports
• More frequent monitoring

8. Prohibited Clients

Aurne will decline clients involving:

• Illegal or suspicious activities
• Sanctions list matches
• Anonymous or shell companies without verifiable activity
• Uncooperative individuals/entities
• Unverifiable SOF/SOW
• Terrorism, arms trade, or narcotics-linked sectors
• Corruption, fraud, or financial crime indicators

This is non-negotiable, regardless of commercial opportunity.

9. Ongoing Monitoring

KYC is not a one-time process.

Aurne conducts:

9.1 Periodic Reviews

• Low Risk: every 36 months
• Medium Risk: every 24 months
• High Risk: every 12 months

9.2 Trigger-Based Reviews

When:

• Ownership changes
• New jurisdictions involved
• Large or unusual transactions occur
• Adverse media appears
• Suspicious indicators arise

9.3 Continuous Screening

Automated or manual screening of:

• Sanctions lists
• PEP lists
• Watchlists
• Adverse media

10. Source of Funds & Source of Wealth Requirements

10.1 Source of Funds (SOF)

We verify the origin of funds used in a specific transaction or service.

Evidence may include:

• Bank statements
• Salary slips
• Sale contracts
• Loan agreements

10.2 Source of Wealth (SOW)

We verify how the individual accumulated their overall wealth.

Evidence may include:

• Business ownership records
• Investments or inherited wealth proofs
• Financial statements
• Tax documents

EDD clients require stricter SOF/SOW verification.

11. Sanctions Compliance

Aurne screens all clients against sanctions lists. For detailed screening procedures, see our AML & CTF Statement.

We screen against:

• UN Security Council sanctions
• UAE Local Terrorist List (Cabinet Decision 74/2020)
• OFAC, EU, UK sanctions (if applicable)
• Other global high-risk lists

Sanctioned or partially matched clients are escalated immediately.

12. Record Keeping

Aurne maintains comprehensive KYC records. For full record-keeping requirements, see our AML & CTF Statement.

We maintain:

• All collected KYC documentation
• Client risk assessments
• Verification logs
• Sanction screening reports
• Correspondence and approvals

Retention: minimum of 5 years as required under UAE AML law.

All data is stored securely and encrypted.

13. Confidentiality & Data Protection

Aurne ensures:

• All KYC data is protected under UAE PDPL
• GDPR protections apply for EU/EEA clients
• Strict confidentiality obligations
• Controlled access permissions
• Secure digital and physical storage

KYC data is used only for lawful compliance purposes.

14. Refusal, Suspension & Termination

Aurne may refuse or terminate services if:

• KYC documents are not provided
• Client refuses SOF/SOW evidence
• Risk is too high
• Suspicion of illegal activity
• Regulatory instructions require it

Services will not proceed under any circumstances until KYC is fully satisfied.

15. Internal Responsibilities

For comprehensive information on our AML/CTF governance structure, see our AML & CTF Statement.

15.1 AML/KYC Compliance Officer

Responsible for:

• Reviewing high-risk cases
• Approving complex structures
• Filing STR/SAR reports (see AML & CTF Statement for reporting procedures)
• Ensuring policy compliance

15.2 Senior Management

Responsible for approving:

• High-risk clients
• Clients from high-risk jurisdictions
• PEP clients
• Unusual activities

15.3 All Employees

Every employee is responsible for:

• Identifying red flags
• Reporting suspicious activity
• Maintaining integrity and compliance

16. Client Obligations

Clients must:

• Provide accurate and complete information
• Submit KYC documents promptly
• Disclose changes in structure or ownership
• Cooperate with verification requests

Failure to do so may delay or halt services.

17. Updates to This Policy

Aurne will update this policy to reflect:

• Legal changes
• FATF updates
• MOE instructions
• Internal compliance improvements

18. Contact Information

For onboarding or KYC-related matters:

Aurne Private Advisory – Compliance Division
Email: contact@aurne.org
Phone: +971 56 615 8490 (WhatsApp)
Address: Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E.