The website dubaimotorclub.com is owned and operated by Perk City Loyalty Card Services L.L.C the “Company”) By visiting our website, you engage in our “Service” and agree to be bound by this Anti-Money Laundering (AML) / Know Your Customer (KYC) Policy (“Policy”).

Throughout the Website and this Policy, the terms “we”, “us”, “our” and “the website” refer to the Company. The Company offers this Website, including all information, products and services available from this Website to you, the user (“You”), conditioned upon your acceptance of all terms, conditions, policies and notices stated herein.

This Policy sets forth the rules and procedures that the Company, its subsidiaries and affiliated parties follow for detecting and preventing any financial crime.

This Policy is an integral part of the Website’s Terms of Use, which are at all times available on the Company’s Website.

The Company is strongly committed to preventing the use of its Services for money laundering or any activity which facilitates money laundering, the funding of terrorist or criminal activities, or any other illicit purposes. Therefore, kindly read this Policy carefully before accessing or using our Website. By accessing or using any part of the Website, You agree to be bound by this Policy. If You do not agree to this Policy, then You may not access the website or use any Services.

Article 1: INTRODUCTION

The Company is dedicated to upholding the highest standards of compliance with Anti-Money Laundering and Counter-Terrorism Financing (CTF) regulations in the United Arab Emirates (UAE) (“AML / CTF Regulations”). This Policy outlines the Company’s commitment to detecting, preventing, and reporting any activities related to money laundering and terrorist financing.

Article 2: Purpose

2.1         The purpose of this Policy is to establish guidelines for:

2.1.1      Identifying, assessing, and managing money laundering and terrorist financing risks.

2.1.2      Conducting due diligence on customers, employees, and partners.

2.1.3      Reporting suspicious activities to the relevant authorities.

2.1.4      Maintaining proper records and implementing internal controls to ensure compliance.

Article 3: Scope

This policy applies to all employees, officers, directors, and agents of the Company, as well as any third parties acting on behalf of the Company.

Article 4: Legal and Regulatory Framework

The Company complies with all relevant AML / CTF Regulations, including but not limited to:

1. UAE Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations.

2. UAE Cabinet Decision No. 10 of 2019 on the Implementing Regulation of Federal Law No. 20 of 2018.

3. Guidelines and regulations issued by the UAE Central Bank and the Financial Intelligence Unit (FIU).

Article 5: AML/KYC Framework

5.1.     Procedures

1. The Company implements AML/KYC procedures for various services, including but not limited to the exchange of virtual currency against fiat currency and the provision of virtual currency wallet services.

2. The Compliance Department of the Company, led by the AML Compliance Officer (“AMLCO”), administers these procedures and ensures compliance with relevant laws and regulations.

5.2.     Protection Measures

1. Performing KYC procedures on all users, both natural and legal persons.
2. Conducting an enterprise-wide risk assessment to determine the Company’s risk profile.
3. Implementing internal procedures, policies, and controls aimed at mitigating money laundering and terrorist financing risks.
4. Providing regular AML/CFT training to staff.
5. Conducting periodic AML audits.
6. Maintaining and updating user information in the Company’s database.
7. Reporting suspicious transactions to the FIU.

Article 6: Enhanced Due Diligence (EDD)

For customers deemed to be higher risk, the Company will apply enhanced due diligence measures, including:

1. Obtaining additional information on the customer and their intended transactions.
2. Increased monitoring of the customer’s transactions.
3. Senior management approval for establishing or continuing business relationships.

Article 7: MONITORING REQUIREMENTS

The Company will monitor customer transactions on an ongoing basis to identify and report suspicious activities. This includes:

1. Regularly reviewing and updating customer information.
2. Analyzing transactions to detect unusual or suspicious patterns.

Article 8: Reporting Suspicious Activities

8.1         “Internal Reporting” Employees must report any suspicious activities to the AMLCO without delay. The AMLCO will review the report and determine whether to file a Suspicious Activity Report (SAR) with the relevant authorities.

8.2         “External Reporting”

The AMLCO will report suspicious activities to the FIU in accordance with UAE regulations. All SARs must be filed promptly and accurately.

Article 9: Record Keeping

The Company will maintain records of all customer identification information, transaction records, and SARs for a minimum of five years from the date of the transaction or the end of the business relationship.

Article 10: GOVERNING LAW & JURISDICTION

This Policy shall be governed by and construed in accordance with the applicable laws and regulations of the UAE, including but not limited to Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations, and any relevant laws and regulations issued by the competent authorities in UAE.

Article 11: Internal Controls and Audits

The Company will implement internal controls to ensure compliance with this policy and relevant laws. This includes regular audits and reviews of the AML program to identify and address any weaknesses or areas for improvement.

Article 12: CUSTOMER IDENTIFICATION AND VERIFICATION

The Company will implement a Customer Identification Program (CIP) to verify the identity of each customer. This includes collecting and verifying information such as name, date of birth, address, and identification numbers.

The Company may use a variety of methods to verify customer identities, including document verification, non-document verification, and third-party verification services.

The Company will continuously verify customer information to ensure its accuracy and relevance, particularly when there are significant changes in customer behaviour or when the customer engages in high-risk transactions.

Article 13: RISK ASSESSMENT AND MANAGEMENT

The Company adopts a risk-based approach to AML/CFT/KYC, focusing on customers, products, services, and geographical locations that pose higher risks. The level of due diligence, monitoring, and control measures will be proportionate to the assessed risks.

Customers and transactions will be categorized as low, medium, or high risk. High-risk customers will be subject to EDD as outlined in Article 6.

Article 14: THIRD-PARTY RELATIONSHIPS

The Company will conduct due diligence on third-party service providers, partners, and affiliates to ensure they comply with applicable AML/CFT/KYC regulations. Contracts with third parties will include clauses requiring compliance with this Policy.

If any AML/CFT/KYC responsibilities are outsourced, the Company will ensure that the service provider has adequate policies and procedures in place to meet the required standards.

Article 15: EMPLOYEE TRAINING AND AWARENESS

The Company will provide regular AML/CFT training to all employees, ensuring they understand the legal requirements and internal procedures for preventing money laundering and terrorist financing.

Employees must be vigilant and report any suspicious activities to the AMLCO. Failure to do so may result in disciplinary action.

Article 16: Policy Review

This Policy will be reviewed and updated annually or as needed to reflect changes in laws, regulations, or the Company’s business practices.

Article 17: Approval and Implementation

This Policy has been approved by the Board of Directors of the Company and is effective as of 31/08/2025. All employees are required to comply with this Policy and its procedures.

Article 18: CONTACT INFORMATION

For any questions or concerns regarding this Policy, please contact us at support@dubaimotorclub.com.

This Policy ensures that the Company adheres to the highest standards of AML compliance, protecting both the Company and its customers from the risks associated with money laundering and terrorist financing.

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