Anti-Money Laundering (AML) Policy
ODAS GLOBAL UNLIMITED OIL PRODUCTS TRADING L.L.C
Effective Date: May 13, 2025
1. Introduction
ODAS GLOBAL UNLIMITED OIL PRODUCTS TRADING L.L.C (“ODAS OIL”, “the Company”, “we”, “our”, or “us”) is committed to maintaining the highest standards of compliance with applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws and regulations, including:
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Federal Decree Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations (UAE);
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Cabinet Decision No. 10 of 2019;
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Financial Action Task Force (FATF) Recommendations;
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Relevant international laws and best practices.
This policy outlines our approach to preventing and detecting any attempt to use our business or services for money laundering or terrorist financing.
2. Objectives
Our AML Policy aims to:
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Prevent the use of ODAS OIL’s services for money laundering or terrorist financing.
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Detect and report suspicious transactions in a timely manner.
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Ensure compliance with all applicable AML/CTF laws and regulations.
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Establish robust internal controls, due diligence, and staff training.
3. Definitions
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Money Laundering: The process of concealing the origins of illegally obtained money, typically by means of transfers involving foreign banks or legitimate businesses.
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Terrorist Financing: Providing or collecting funds, by any means, with the intention that they should be used to carry out terrorist acts.
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Customer Due Diligence (CDD): The process of identifying and verifying the identity of customers and beneficial owners.
4. Risk-Based Approach (RBA)
ODAS OIL applies a risk-based approach to AML, ensuring resources are allocated efficiently and proportionately. Factors considered include:
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Geographic location
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Client type and legal structure
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Transaction complexity and volume
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Method of payment
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Source of funds
High-risk customers and transactions are subject to Enhanced Due Diligence (EDD).
5. Know Your Customer (KYC) Requirements
We apply strict KYC measures to all customers, suppliers, and counterparties, including:
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Verifying legal identity (passport, national ID, or trade license);
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Determining beneficial ownership of corporate entities;
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Verifying source of funds;
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Screening against sanctions lists (e.g., UN, EU, OFAC).
We do not engage with anonymous, fictitious, or shell entities.
6. Customer Due Diligence (CDD)
ODAS OIL performs CDD in the following scenarios:
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Establishing a new client relationship;
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Conducting transactions above the regulatory threshold;
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Suspicion of money laundering or terrorist financing;
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Doubts about the veracity of previously obtained information.
CDD includes collecting, verifying, and storing customer data. Records are retained for at least five (5) years.
7. Enhanced Due Diligence (EDD)
EDD is applied in cases such as:
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Politically Exposed Persons (PEPs);
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High-risk countries or industries;
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Complex ownership structures;
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Transactions involving unusual patterns or large volumes.
EDD may include obtaining additional identification, approval from senior management, and ongoing monitoring.
8. Monitoring and Reporting
We conduct continuous transaction monitoring to detect suspicious activities. Indicators may include:
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Sudden or large cash transactions;
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Unusual payment patterns;
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Transfers to/from high-risk jurisdictions;
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Requests to structure transactions to avoid thresholds.
Suspicious activities are escalated to the Compliance Officer and, if necessary, reported to the UAE’s Financial Intelligence Unit (FIU) via the goAML platform.
9. Recordkeeping
ODAS OIL maintains accurate and complete records of:
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Customer identification and verification data;
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Transaction data and supporting documentation;
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AML training logs;
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Internal reports and risk assessments.
All records are retained for a minimum of five (5) years from the date of the last transaction or termination of the relationship.
10. Training and Awareness
All employees receive mandatory AML training at the time of hire and on an ongoing basis. Training covers:
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Laws and regulations
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Customer due diligence
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Identifying suspicious activities
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Internal reporting procedures
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Penalties for non-compliance
11. Compliance Officer
ODAS OIL has appointed a qualified AML Compliance Officer responsible for:
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Implementing and maintaining the AML Policy;
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Conducting risk assessments;
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Reviewing and filing suspicious activity reports;
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Coordinating with authorities and auditors.
The Compliance Officer operates independently and reports directly to senior management.
12. Sanctions Compliance
ODAS OIL screens all parties against:
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United Nations Sanctions Lists
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Office of Foreign Assets Control (OFAC)
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EU Consolidated Sanctions List
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UAE National Terrorist List
We do not do business with entities or individuals subject to sanctions.
13. Breach and Non-Compliance
Any employee who fails to comply with this policy or participates in money laundering activities will be subject to:
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Internal disciplinary measures;
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Immediate termination of employment or contract;
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Reporting to law enforcement or regulatory bodies.
14. Review and Updates
This AML Policy is reviewed annually and updated as needed to reflect changes in laws, regulations, or company activities.
15. Contact Information
For any questions regarding this AML Policy, please contact:
Compliance Department
ODAS GLOBAL UNLIMITED OIL PRODUCTS TRADING L.L.C
📍 S1-28 PROPERTY INVESTMENT OFFICE 4, Dubai Investment Park First, DUBAI, 111485
📞 +971 503 956 811
📧 office@odasoil.com
