Purpose
Horwick is committed to preventing money laundering, terrorist financing and sanctions evasion. This policy follows the VARA rulebook and applicable UAE federal law.
Customer due diligence
Every client must be verified before trading. We collect and verify:
- A valid government-issued photo ID.
- A liveness check (selfie) matched against the ID.
- Proof of residential address issued within the last three months.
Enhanced due diligence
Additional checks, such as source-of-funds and source-of-wealth documents, apply to higher-risk clients, politically exposed persons and large or unusual activity.
Sanctions screening
Clients and transactions are screened against UN, UAE, EU, UK and US (OFAC) sanctions lists at onboarding and on an ongoing basis.
Transaction monitoring
We monitor deposits, trades and withdrawals for unusual patterns using automated rules and manual review. Blockchain analytics are applied to crypto deposits and withdrawals.
Reporting obligations
Where we suspect money laundering or terrorist financing, we file suspicious activity reports with the UAE Financial Intelligence Unit. We are legally prohibited from informing the client when a report is made.
Record keeping
Identity and transaction records are kept for at least five years after the end of the business relationship, as described in our Privacy Policy.
Restricted jurisdictions
We do not onboard residents of sanctioned or high-risk jurisdictions. The current list is available on request.
Compliance contact
Our Money Laundering Reporting Officer can be reached at [email protected]. Registered company details are on the Contact page.