Anti-Money Laundering (AML) Policy for Flash Real Estate

Introduction

Flash Real Estate is committed to maintaining the highest standards of integrity and compliance

with anti-money laundering (AML) regulations. This policy outlines our procedures and controls

to prevent money laundering and the illegal flow of funds through our operations.

1. Customer Due Diligence (CDD)

1.1 Know Your Customer (KYC): Flash Real Estate will conduct thorough customer due diligence

for all clients, including international clients. This includes collecting and verifying the following

information:

- Full legal name and date of birth for individuals, or company name and registration details for

corporate clients.

- Contact details, including a physical address, email, and phone number.

- Proof of identity (e.g., passport, national ID, or company registration documents).

- Proof of address (e.g., utility bill or bank statement).

- Information about the source of funds and the purpose of the transaction.

1.2 Enhanced Due Diligence (EDD): For high-risk clients or transactions, Flash Real Estate will

conduct enhanced due diligence to gain a deeper understanding of the client's background and

financial activities. This may include additional documentation, background checks, or third-

party verifications.

2. Cash Transactions:

2.1 Cash Limit: Flash Real Estate will not accept cash payments exceeding 50,000 AED from any

client, except when the client provides satisfactory proof of the legitimate source of the funds.

Such proof may include bank statements, tax documents, or other relevant financial records.

2.2 Recording Cash Transactions: All cash transactions, regardless of amount, will be

meticulously recorded, including the date, amount, client details, and the purpose of the

transaction. These records will be retained for a minimum of five years.

3. Ongoing Monitoring:

3.1 Continuous Monitoring: Flash Real Estate will monitor client accounts and transactions on

an ongoing basis to identify any unusual or suspicious activity. This includes reviewing

transactions for patterns inconsistent with the client's known business or financial profile.

3.2 Suspicious Activity Reporting: If any suspicious activity is detected, Flash Real Estate will

report it to the relevant authorities as required by law. We will cooperate fully with law

enforcement agencies in investigations related to money laundering or other illegal activities.

4. Employee Training:

4. 1 AML Training: All employees of Flash Real Estate will receive regular training on AML

policies and procedures to ensure a high level of awareness and compliance.

5. Compliance Officer:

5.1 Appointment Flash Real Estate will appoint a designated Compliance Officer responsible

for overseeing AML compliance and reporting to senior management.

6. Record Keeping:

6.1 Document Retention Flash Real Estate will maintain records of customer due diligence,

transaction records, and suspicious activity reports for a minimum of five years.

Conclusion:

Flash Real Estate is fully committed to preventing money laundering and complying with all

applicable AML regulations. We will continue to adapt and update our AML policies and

procedures to meet evolving regulatory requirements and to maintain the highest standards of

integrity in our operations.

This AML policy is an integral part of our commitment to conducting ethical and lawful business

practices. All employees and clients are expected to cooperate fully with the policy and to report

any concerns or suspicions of money laundering promptly.

Date of Policy: 02/02/2021

Effective Date: 2023/07 / 25