Last updated: 2025-11-01
AML Policy
1. Commitment
Delta Pay maintains a comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) program aligned with UAE laws and FATF recommendations.
2. Governance
Program ownership sits with the MLRO (Money Laundering Reporting Officer). The Board reviews program effectiveness quarterly. Independent audits are conducted annually.
3. Customer Due Diligence
We conduct risk-based KYC/KYB at onboarding, including UBO identification, source of funds/wealth review, sanctions and PEP screening (OFAC, EU, UN, UK), and adverse-media checks.
4. Enhanced Due Diligence
EDD applies to high-risk categories, cross-border corridors, cash-intensive businesses and PEPs, including senior-management approval, more frequent reviews, and additional documentation.
5. Ongoing monitoring
Transactions are monitored continuously against typologies. Alerts are triaged by trained analysts; escalations reach the MLRO within defined SLAs.
6. Reporting
Suspicious activity is reported to the UAE Financial Intelligence Unit through goAML in the timeframes required by law.
7. Sanctions
We do not process transactions with sanctioned individuals, entities, or jurisdictions. Screening is performed at onboarding and continuously against updated lists.
8. Training
All employees complete AML training at onboarding and annually thereafter. Role-based advanced training is provided to compliance and operations staff.
9. Record-keeping
Records are retained for a minimum of five years or longer where required by law.
10. Contact
MLRO — Telegram @Deltapay_admin — Business Bay, Dubai, UAE.