Goldman Whites Group

  • info@gwgroup.ae
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Anti-Money Laundering (AML) Policy

Last Updated: 01 January 2026

Policy Statement

Goldman Whites Group (“GW Group”, “we”, “our”, or “the Company”) is fully committed to preventing money laundering, terrorist financing, fraud, bribery, corruption, and other financial crimes.

We conduct our business in compliance with all applicable United Arab Emirates (UAE) laws and regulations, including:

  • UAE Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT)

  • Cabinet Decision No. (10) of 2019 and its amendments

  • Applicable guidelines issued by relevant UAE regulatory authorities

The Company adopts a zero-tolerance approach to financial crime.

Purpose

The purpose of this AML Policy is to:

  • Prevent the use of GW Group’s services for money laundering or terrorist financing

  • Establish internal controls to detect and report suspicious activities

  • Ensure full compliance with UAE AML/CFT regulations

  • Protect the Company’s reputation and integrity

Scope

This policy applies to:

  • All directors, managers, employees, and contractors

  • All subsidiaries and affiliated entities

  • All clients, partners, and third parties engaging with the Company

Customer Due Diligence (CDD)

GW Group implements risk-based Customer Due Diligence (CDD) procedures, including:

  • Verifying client identity using official documentation

  • Identifying Ultimate Beneficial Owners (UBOs)

  • Understanding the nature and purpose of business relationships

  • Conducting enhanced due diligence (EDD) for high-risk clients

  • Ongoing monitoring of transactions and client activities

We reserve the right to decline or terminate relationships where AML risks cannot be adequately mitigated.

Risk Assessment

The Company conducts periodic AML risk assessments considering:

  • Client risk profile

  • Geographic risk

  • Nature of services provided

  • Transaction risk

  • Delivery channels

Controls are implemented proportionate to the identified level of risk.

Suspicious Transaction Monitoring & Reporting

Employees are required to promptly report any suspicious activity to the designated Compliance Officer.

Where required under UAE law, the Company will file Suspicious Transaction Reports (STRs) or Suspicious Activity Reports (SARs) with the appropriate regulatory authority without notifying the client (no “tipping off”).

Record Keeping

GW Group maintains records of:

  • Client identification documents

  • Transaction records

  • Risk assessments

  • Suspicious activity reports

Records are retained in accordance with UAE regulatory requirements.

Employee Training

The Company provides AML/CFT awareness and training to relevant employees to ensure they:

  • Understand money laundering risks

  • Recognize suspicious behavior

  • Know reporting procedures

  • Comply with legal obligations

Sanctions Compliance

GW Group screens clients and transactions against applicable:

  • UAE sanctions lists

  • United Nations sanctions lists

  • Other relevant international sanctions lists

We do not engage in business with sanctioned individuals or entities.

Governance & Responsibility

Senior management is responsible for overseeing AML compliance. A designated Compliance Officer is appointed to:

  • Monitor AML implementation

  • Maintain internal controls

  • Liaise with regulatory authorities

  • Ensure policy updates as required

Non-Compliance

Failure to comply with this policy may result in:

  • Disciplinary action

  • Termination of employment or contract

  • Reporting to regulatory authorities

  • Legal action where applicable

Policy Review

This AML Policy is reviewed periodically to ensure continued compliance with UAE laws and evolving regulatory requirements.

Contact Information

For AML-related inquiries, please contact:

Goldman Whites Group
📧 Email: info@gwgroup.ae
📞 Phone: +971-47-700-871
🌐 Website: www.gwgroup.ae

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