# AML & KYC Policy

> How Horwick prevents money laundering and verifies client identity: the documents we ask for, checks we run and why.

Source: https://horwick.com/legal/aml-kyc · Last updated 2026-09-01

## 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](/legal/privacy-policy#data-retention).

## 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 [compliance@horwick.com](mailto:compliance@horwick.com). Registered company details are on the [Contact page](/contact#company).