AML POLICY

1. Policy Statement & Purpose

NWI Investment Holding is committed to the highest standards of integrity and the prevention of money laundering (ML) and terrorist financing (TF). This policy aims to ensure the company is not used as a vehicle for illicit financial activities and complies with the regulations of the state of Qatar

2.The Five Pillars of AML Compliance

I. Internal Controls and Procedures

Establish clear, written protocols for:
Risk Assessment: identifying high-risk jurisdictions, sectors, or complex corporate structures.
Sanctions Screening: Screening all partners, investors, and transactions against global lists (UN, OFAC) and the Qatar National Sanctions List.

II. Designated Compliance Officer (MLRO)
Appoint a Money Laundering Reporting Officer (MLRO) who has:
Direct access to senior management and the Board.
The authority to investigate and report suspicious transactions.
Responsibility for updating this policy annually to reflect new laws (like the 2025 updates).

III. Customer Due Diligence (CDD) & KYC
For every investment or partnership, you must perform:
Identification & Verification: Obtaining passports, trade licenses, and certificates of incorporation.
Ultimate Beneficial Ownership (UBO): Identifying the natural persons who own or control more than 20-25% of a legal entity.
Enhanced Due Diligence (EDD): Required for Politically Exposed Persons (PEPs) or high-risk jurisdictions.

IV. Employee Training
Onboarding: All new hires must receive AML/CFT training.
Annual Refreshers: Mandatory yearly training on “red flags” (e.g., unexplained wealth, structured payments, or reluctance to provide UBO info).

V. Independent Audit
Conduct an independent testing of the AML program every 12–24 months by a third party or an internal department not involved in the compliance function to ensure effectiveness.

3. Specific Red Flags for Holding Companies

Complex Structures: Layers of shell companies with no apparent commercial purpose..
Third-Party Payments: Funds arriving from or being sent to accounts not in the name of the contracted party.
Sudden Capital Influx: Large, one-off investments from private individuals without a clear source of wealth.