Updated August 2022


This Anti-Money Laundering (AML) Policy serves as a cornerstone in the commitment towards promoting a transparent, ethical, and law-abiding financial environment. The policy has been crafted to comply with all relevant laws, regulations, and global standards aimed at combating money laundering, terrorist financing, and other financial crimes. Western Sahara Worldwide Services (“WSWS,” “The Company,” “We,” “Our”) views the prevention and detection of illicit financial activities as crucial components of its operations, aligning its practices with the highest ethical standards and regulatory requirements. As such, the company firmly upholds its responsibility to maintain an AML framework that abides by the laws and regulations governing its operations across various jurisdictions. Our commitment extends to fostering a culture of compliance that involves every employee, contractor, and third party acting on behalf of WSWS or representing Willis Capital as a product. This commitment is underpinned by the understanding that a robust AML program is fundamental not only to protect the integrity of financial systems but also to safeguard the interests of stakeholders, clients, and the broader community

Scope and Objectives

This policy focuses on the operation of Willis Capital as a proprietary trading product by WSWS. However, it extends comprehensively across all the programs, subsidiaries, and affiliates of Willis Capital. This policy holds applicability across various jurisdictions and operates as the foundational framework guiding the company's operations. It is obligatory for all employees, contractors, and third parties acting on behalf of Willis Capital to adhere strictly to the principles and guidelines outlined in this policy. Where local laws differ or impose stricter requirements, compliance with the most stringent standards becomes mandatory for all entities under Willis Capital.

  • Prevention and Detection: The primary objective of this Policy is to proactively prevent and detect instances of money laundering, terrorist financing, and other financial crimes. The Company is committed to deploying robust measures and adopting best practices to prevent its services from being exploited for illicit purposes

  • Compliance with Regulations: Another pivotal objective is to ensure strict compliance with all pertinent AML laws, regulations, and industry standards 1 across jurisdictions where Willis Capital is operated. This includes but is not limited to, adherence to local AML laws, global sanctions programs, and international best practices.

  • Identification of Beneficial Owners: Western Sahara Worldwide Services aims to establish transparent procedures for identifying and verifying beneficial ownership in relation to the operation of Willis Capital, ensuring thorough due diligence in understanding and documenting ownership structures of its clients and partners.

  • Record-Keeping and Reporting: The policy emphasises meticulous record-keeping practices to document transactions, customer information, and any suspicious activities. It encourages timely and accurate reporting of suspicious activities to the relevant authorities in line with regulatory obligations.

  • Training and Awareness: The Company places importance on continuous training and awareness programs for its employees and associated parties to enhance their understanding of AML principles, recognize red flags, and comply with the policy effectively. By setting forth these objectives, Western Sahara Worldwide Services underlines its dedication to upholding the highest standards of integrity, transparency, and compliance in its business operations globally.

Definition of Money Laundering

Money laundering refers to the process through which individuals or entities conceal the illicit origin, ownership, or control of funds derived from illegal activities. It involves converting illegally obtained money into legitimate assets or making it appear as if the funds were obtained through lawful means. This illegal process generally occurs in three stages:

  • 1. Placement: At this initial stage, unlawfully acquired funds are introduced into the financial system. This often involves breaking down large amounts of illegally obtained money into smaller, less suspicious transactions to evade detection.

  • 2. Layering: Proceeds from the criminal activity are then layered or separated from their original source through a series of complex financial transactions. This may include moving funds between various accounts or entities, making it challenging to trace their origin.

  • 3. Integration: In the final stage, the laundered funds are reintroduced into the economy, making them appear legitimate. These funds might re-enter the financial system through seemingly legal transactions, thus masking their criminal origin.

Typical Procedures Involved

Money laundering can occur through various means, including but not limited to:

  • Structuring Transactions: Breaking down large sums into smaller transactions to avoid scrutiny.

  • Using Front Companies: Establishing fictitious companies or entities to disguise the origin of funds.

  • Smurfing: Employing numerous individuals to make small transactions to avoid detection.

  • Trade-Based Laundering: Over or under-invoicing goods in international trade to move money across borders.

  • Using Cryptocurrencies: Exploiting digital currencies to obscure the source of funds due to their pseudonymous nature.

  • Shell Companies: Creating shell corporations with no substantial business operations to facilitate money movement without scrutiny.

Understanding the intricacies of these stages and procedures is essential for WSWS to proactively identify and prevent potential money laundering activities, thereby safeguarding its operations and maintaining compliance with AML regulations.

AML Compliance Officer

The Company acknowledges the critical role of an Anti-Money Laundering (AML) Compliance Officer in overseeing the effective implementation and adherence to AML policies and procedures. Accordingly, the company shall designate an AML Compliance Officer who will be vested with the following key responsibilities:

  • Policy Oversight: Overseeing the development, maintenance, and periodic review of the AML policy to ensure alignment with regulatory requirements and industry best practices.

  • Implementation: Ensuring the effective implementation of AML policies and procedures across all entities and jurisdictions where Willis Capital operates.

  • Risk Assessment: Conducting periodic risk assessments to identify potential vulnerabilities and evolving risks related to money laundering and terrorist financing.

  • Audit and Review: Coordinating internal audits and reviews to assess the effectiveness of AML controls and recommending improvements when necessary.

Reporting Structure

The AML Compliance Officer shall report directly to the Board of Directors or the highest level of senior management within Willis Capital. This direct reporting line ensures the independence and effectiveness of the compliance function, fostering an environment that prioritises AML compliance throughout the organisation.

AML Procedures

Client Identification Procedures (KYC/AML)

  • Verification of Client Identity: Our KYC/AML procedures mandate the verification of client identity before establishing any business relationship or entering into transactions. This includes obtaining and verifying relevant identification documents such as passports, national IDs, proof of address, and other documentation as required by local regulations.

  • Know Your Customer (KYC) Process: The company conducts a thorough KYC process, which involves understanding the client's identity, assessing their risk profile, and verifying the legitimacy of their funds and sources.

  • Documentation and Record-Keeping: We maintain accurate records of client identification, transactions, and related documentation in compliance with regulatory requirements. These records are regularly updated and securely stored for the mandated period.

Enhanced Due Diligence (EDD) for High-Risk Clients or Jurisdictions

Identification of High-Risk Clients: The company employs risk-based assessments to identify high-risk clients, politically exposed persons (PEPs), or transactions involving high-risk jurisdictions.

Enhanced Due Diligence Procedures: For high-risk clients or transactions, enhanced due diligence measures are applied, which may include additional verification procedures, obtaining more extensive information about the client's background, source of funds, and beneficial ownership.

Procedures for Monitoring and Adherence to Sanctions Lists

Continuous Monitoring: The company implements robust systems to monitor and cross-check clients and transactions against the latest sanctions lists issued by relevant authorities.

Adherence to Sanctions Lists: We adhere strictly to sanctions imposed by regulatory bodies. Clients or transactions associated with sanctioned countries, entities, or individuals undergo stringent due diligence and may be declined if necessary.

Reporting Suspicious Activities

Internal Reporting Protocols

Employee Training and Awareness: Western Sahara Worldwide Services conducts regular training sessions to educate employees on identifying and reporting suspicious activities or transactions. Employees are informed about red flags indicating potential money laundering, terrorist financing, or any other illicit activities.

Structured Reporting Mechanisms: The company has established clear internal reporting channels for employees to promptly report any suspicious activities or transactions to the designated AML Compliance Officer.

Documentation and Record-Keeping: Reports of suspicious activities or transactions are thoroughly documented, including details of the reported incident, the individuals involved, and any supporting evidence. These records are securely maintained and accessible for compliance purposes and potential investigations.

Whistleblower Protection Measures

Anonymity and Confidentiality: As a company, we ensure confidentiality and protect the identity of all our employees reporting suspicious activities. Whistleblowers are encouraged to report concerns anonymously, and their identity is safeguarded throughout the process.

Protection from Retaliation: The company strictly prohibits any form of retaliation against individuals reporting suspicious activities. Employees are assured that they will not face adverse actions or discrimination for raising genuine concerns in good faith.

Record Keeping

Requirements for Maintaining Accurate Records

Customer Identification Records: Western Sahara Worldwide Services maintains detailed records of customer identification information obtained during the Know Your Customer (KYC) process. This includes documents verifying customer identity, such as passports, national IDs, or other government-issued identification documents.

Transaction Details: Comprehensive records of all transactions, including the nature, amount, date, and parties involved, are diligently maintained. This includes both financial and non-financial transactions conducted by Willis Capital's clients.

Documentary Evidence: The company ensures the availability of adequate documentary evidence supporting the legitimacy of transactions and compliance with regulatory obligations.

Duration and Specifics of Record Keeping

Retention Period: The company adheres to the legally mandated record retention period, which typically spans a minimum of five years, from the date of the last transaction or the end of the business relationship, whichever is later.

Legal Mandates: Record-keeping practices comply with the regulations set forth by relevant authorities or jurisdictions, ensuring that records are securely stored and readily accessible for inspection purposes, audits, or investigations by regulatory bodies.

Secure Storage: All records, whether physical or electronic, are securely stored to prevent unauthorised access, tampering, or loss, in compliance with data protection and privacy laws.

Training on Anti-Money Laundering (AML)

Mandatory AML Training

Employee Requirement: The company mandates comprehensive AML training for all employees, contractors, and relevant stakeholders involved in financial services, trading activities, or client interactions.

Content of Training Sessions: The training program covers, but is not limited to:

  • Overview of AML laws, regulations, and internal policies
  • Identification of suspicious activities, red flags, and risk scenarios
  • Procedures for reporting suspicious transactions or behaviours
  • Customer due diligence (CDD) and Know Your Customer (KYC) protocols
  • Responsibilities and obligations of employees in AML compliance
  • Emerging trends and updates in AML regulations

Frequency and Refreshers: We also conduct regular AML training sessions, ensuring that employees undergo refresher courses annually or as per regulatory updates. Additionally, new employees or contractors receive AML training as part of their onboarding process.

Documentation: The company maintains records of attendance, course materials, and certifications obtained by employees upon completion of AML training sessions.

Risk Assessment and Policy Review

Periodic Risk Assessments

Frequency: Western Sahara Worldwide Services conducts periodic risk assessments to evaluate the effectiveness of its AML Policy and procedures. These assessments are conducted regularly, typically on an annual basis, or more frequently if necessitated by significant regulatory changes or emerging risks.

Comprehensive Evaluation: The assessments involve a comprehensive review of:

  • Existing AML procedures and their alignment with current regulations
  • Effectiveness of client identification measures (KYC/EDD)
  • Appropriateness of transaction monitoring and reporting mechanisms
  • Analysis of internal controls and their efficiency in mitigating AML risks
  • Responsibilities and obligations of employees in AML compliance
  • Any identified vulnerabilities or areas requiring enhancement
Policy Updates and Improvements

Adaptive Measures: The company commits to promptly implementing updates or improvements based on the findings of these assessments. Any identified deficiencies or gaps are addressed with revised or additional AML procedures.

Regulatory Compliance: Policy enhancements are aligned with evolving regulatory requirements, industry best practices, and emerging trends in money laundering or terrorist financing activities.

Communication: The updated AML policies and procedures are communicated across the organisation, ensuring all relevant stakeholders are informed of the changes and understand their responsibilities under the revised framework.

Sanctions Compliance Protocols

Adherence to National and International Sanctions

Screening Protocols: We implement stringent screening measures to ensure compliance with both national and international sanctions programs. This includes:

  • Regular screening of clients, transactions, and business relationships against relevant sanctions lists, such as those imposed by national authorities and international bodies.
  • Maintaining a comprehensive database of sanctioned countries, individuals, entities, or politically exposed persons (PEPs).

Enhanced Due Diligence (EDD): Any client or transaction identified from a sanctioned country or listed on relevant sanctions lists undergoes enhanced due diligence procedures. This involves:

  • A rigorous assessment to determine the legitimacy and potential risks associated with the client or transaction.
  • Additional verification steps to ascertain the source of funds and the purpose of the transaction.

Compliance with Sanctions Regulations: The company ensures its activities align with all applicable sanctions laws and regulations. We strictly prohibit engaging in business relations or transactions with individuals, entities, or countries subject to sanctions.

Regular Updates: The sanctions screening protocols are regularly reviewed and updated to reflect any changes in sanctions lists or modifications in national and international sanctions programs.

Duration and Specifics of Record Keeping

Retention Period: The company adheres to the legally mandated record retention period, which typically spans a minimum of five years, from the date of the last transaction or the end of the business relationship, whichever is later.

Legal Mandates: Record-keeping practices comply with the regulations set forth by relevant authorities or jurisdictions, ensuring that records are securely stored and readily accessible for inspection purposes, audits, or investigations by regulatory bodies.

Secure Storage: All records, whether physical or electronic, are securely stored to prevent unauthorised access, tampering, or loss, in compliance with data protection and privacy laws.

Non-Compliance Consequences

Consequences of AML Policy Violations

Disciplinary Actions: Any breach or violation of the AML Policy, including failure to adhere to established procedures, reporting suspicious activities, or participating in money laundering-related actions, will result in disciplinary measures.

Termination of Relationships: Non-compliance by employees, contractors, or any other relevant stakeholders may lead to immediate termination of their association or business relationship with Western Sahara Worldwide Services and the Willis Capital platform.

Legal Implications: Non-compliance with AML regulations and company policies may lead to legal consequences, including:

  • Potential civil or criminal charges against the violator(s).
  • Fines, penalties, or legal actions imposed by regulatory bodies or law enforcement agencies.

Ongoing Monitoring: The company maintains an ongoing monitoring system to ensure compliance with the AML Policy and applicable laws. Regular audits and assessments help identify and rectify any potential breaches or gaps in compliance.

Applicable Laws and Regulations

AML Laws and Regulatory Frameworks

  • UAE Federal Law No. 20 of 2018: This law outlines the Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations (AML Law) in the United Arab Emirates. Western Sahara Worldwide Services adheres strictly to the provisions and mandates set forth by this law.

  • Cabinet Resolution No. 10 of 2019: The Implementing Regulations of Federal Law No. 20 of 2018 (AML Regulations) provide detailed guidelines for the enforcement and implementation of the AML Law. Western Sahara ensures compliance with these regulations.

  • Federal Law No. 7 of 2014: Pertaining to Combating Terrorism Crimes, this law is integral to the prevention and identification of terrorism financing activities. Our practices are aligned to thwart any involvement in terrorist financing activities.

  • Federal Penal Code and Penal Procedures Law: These laws lay down the legal framework for addressing criminal offences, including money laundering, within the UAE. We ensure alignment with these codes to mitigate illicit financial activities.

  • UAE Central Bank Regulations: Circulars and directives issued by the UAE Central Bank, notably Circular No. 24/2000 and subsequent amendments, mandate specific procedures for AML compliance by financial institutions. We strictly adhere to these directives.

  • SCA Decision (17/R) of 2010: Issued by the Securities and Commodities Authority, this decision outlines Anti-Money Laundering and Terrorism Finance Combating Procedures. We follow these guidelines to prevent illicit financial activities.

  • International Sanctions: The company complies with international sanctions imposed by the United Nations and other relevant bodies. Transactions and clients are screened against sanctions lists, and due diligence is applied for entities or individuals from sanctioned countries.

  • Risk-Based Approach: As mandated by regulations, Western Sahara Worldwide Services adopts a risk-based approach for customer onboarding, ongoing due diligence, and assessments, aligning with its obligations under the AML laws and regulations. Our commitment to combating money laundering and terrorist financing extends across all operational aspects. Through comprehensive risk-based approaches, robust client identification procedures, meticulous record-keeping practices, and continual staff training, we aim to fortify our defences against illicit financial activities. As a company, we acknowledge the dynamic nature of regulatory environments and remain vigilant in reviewing and updating our AML policies and procedures. Yet, we remain committed to combating money laundering and terrorist financing across all operational aspects. Through comprehensive risk-based approaches, robust client identification procedures, meticulous record-keeping practices, and continual staff training, we aim to fortify our defences against illicit financial activities. We are dedicated to staying abreast of evolving laws, industry best practices, and emerging threats to ensure our AML framework remains robust, effective, and aligned with global standards. All of these are with a view to contributing to a transparent, secure, and trustworthy financial ecosystem that establishes confidence among stakeholders and demonstrates our commitment to ethical business practices