Transparency and Reliability in Our Business

As a regulated entity incorporated in the Abu Dhabi Global Market («ADGM») ACM Limited is committed to its regulatory obligations relating to the United Arab Emirates (UAE) sanction regime that, among others implement the United Nations Security Council Resolutions (UNSCR), including those related to the United Nations (UN) resolutions on the suppression and combating of terrorism, terrorist financing, and countering the financing of proliferation of weapons of mass destruction, the so known as Targeted Financial Sanctions (TFS).

The UAE Government has taken steps to enforce these resolutions and has implemented measures to prevent the financing of terrorist activities and other prohibited activities by issuing various federal resolutions such as the:

  • Cabinet Resolution No (74) of 2020 regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combating of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its Financing and Relevant Resolutions;
  • supplementary acts such as Circular No. (2) of 2022 regarding Implementation of Targeted Financial Sanctions (TFS) on UNSCR 1718 (2006) and 2231 (2015),
  • Circular No. (5) of 2021 regarding Targeted Financial Sanctions Reporting, and various published guidelines and typologies aimed at assisting compliance with the UAE Sanctions Regime Obligations on Financial Businesses and Professions and Designated Non-financial Businesses and Professions.

ACM Limited, which is committed to its core corporate principles and prudent practices, observes not only the UAE Sanctions Regime but also observes and complies with International Sanctions Regimes including but not limited to those of the United Kingdom sanctions regimes, United States Office of Foreign Assets Controls, the European Union Sanctions, and the UNSC.

International sanctions have become a key element in contemporary international relations. They are coercive measures applied against States, non-State entities or individuals that pose a threat to international peace and security. The objectives pursued are to modify the behaviour of an agent, reduce its capacity for manoeuvre or weaken its position and publicly denounce those agents that pose a threat to international peace and security. Sanctions are fundamentally preventive and should be proportionate. They are used as an alternative to the use of armed force.

Companies and individuals that operate in jurisdictions subject to international sanctions must comply with these measures to avoid legal and financial penalties. Compliance with international sanctions typically involves monitoring and screening transactions, customers, suppliers, and partners to ensure they do not involve sanctioned entities.

Compliance with international sanctions is a complex and evolving area of law that requires specialised expertise and resources. Organisations that operate in multiple jurisdictions should have a robust sanctions compliance programme that includes policies, procedures, and controls to ensure adherence to applicable sanctions regimes. Additionally, companies should conduct regular training and awareness programmes for employees and third parties to ensure that they understand and comply with sanctions requirements.

It is important to note that sanctions regimes can change rapidly, and it is essential to stay up-to-date with the latest developments and comply with them accordingly. Non-compliance with international sanctions can result in severe legal and financial consequences, including fines, reputational damage, and even criminal liability.

ACM has developed specific procedures and controls to ensure full compliance with EU, UN, US and UK sanctions regulations, primarily based on the following five axes of sanctions regulation compliance:

  • Management Commitment
  • Risk Assessment and zero tolerance
  • Internal Controls
  • Testing and Auditing
  • Training and accountability

In order to ensure the soundness and effectiveness, compliance and alignment with the UAE Sanctions Regime and the various other sanction regimes as mentioned above, ACM’s controls and checks tools requires an annual audit, and ad-hoc checks take place as needed. In 2022, we carried out an ad-hoc sanctions audit, which concluded with non-material findings in the firm’s internal control environment.

Lastly ACM Limited adheres to all relevant Financial Action Task Force (FATF) requirements and refrains from establishing relationships with potential clients from FATF «blacklist» jurisdictions.

By upholding these high standards, we demonstrate our unwavering commitment to protecting our clients and their investments, and fostering long-lasting relationships built on trust and reliability by maintaining high compliance standards and principles.

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