Anti-Money Laundering

Halli Jewelry and AML

Halli Jewelry Company for gold and jewelry is fully committed to remaining vigilant to prevent any use of its products and services for illegal purposes.

The company believes that no customer relationship is worth compromising its commitment to combating money laundering and financing of terrorist activities.

The compliance policy is in line with international standards and as per law on AML and CFT (Law 106).

The Company has prepared a comprehensive Compliance Policy which serves as a guideline to all employees of Halli Jewelry Company for gold and jewelry.

The policy covers all aspects of the Law 106 and follows a risk-based approach.

At Halli Jewelry Company, we are dedicated to fulfilling our mission of safely conducting business in compliance with all the applicable laws and the regulations.

We have implemented concrete Anti-Money Laundering (AML) and compliance practices in all our branches.

Our technological infrastructure and AML solutions ensures that we are completely compliant throughout.

Halli Jewelry Company ensures that it remains committed in its efforts to prevent money laundering and terrorist financing in accordance with the Ministry of Commerce Anti-Money Laundering Department regulations and international best practices in Anti-Money Laundering (AML) & Counter Terrorist Financing (CTF). And to fulfil the same, Halli Jewelry Company is completely prepared with measures to detect suspicious activities associated with money laundering, fraud and terrorist financing and to report them to the competent authorities, as per the regulations.

Know Your Customer (KYC)

Halli Jewelry Company follows a solid identity verification process for all customers as per local and international AML/CTF regulations, irrespective of the amount of the transaction.

Definitive KYC (Know Your Customer) and KYCC (Know your Customer’s Customer) policies are adhered to at all levels of the organization.

Identifying and conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) wherever required is a standard operation so as to identify signs of money laundering.

Monitoring all transactions

Halli Jewelry Company constantly monitors all transactions in order to detect transactions which are potentially suspicious based on the customer’s profile and behavior.

Our very own staff act as a first line of defense and are empowered with the knowledge and the skills to detect any unusual behavior/ transactions through the internal channels.

This process is further backed up by a comprehensive review of the transactions at the second line of defense including effective monitoring of the customer’s transactions and their behavior.

Reporting of Unusual or Suspicious Transactions to compliance

All of the staff at Halli Jewelry Company are equipped with the training and knowledge necessary to report unusual or suspicious transactions through our internal channels to the compliance officer.

Compliance Team and Technology

Halli Jewelry Company has a Compliance Department, headed by a Compliance Officer who is responsible to oversee the compliance activities of the company who report directly to the Board of Directors. The role of the compliance team is as follows:

1- Updating the Compliance Policy on a regular basis as per changes in the Law.

2- Payment monitoring.

3- Sanction list screening.

4- Investigations.

5- Conducting Enhanced Due Diligence (EDD), as required.

6- Reporting suspicious activities to the FIU.

Independent Review of the Compliance & AML Department

The AML function & Compliance is subject to reviews by Internal Audit as well as independent external auditors. This ensures that the compliance program is always up-to-date and is meeting all the regulatory requirements.

Staff Training

Halli Jewelry Company strongly believes in empowering and equipping its employees with relevant knowledge at every level. Regular and thorough AML trainings help the company adhere to the various rules and regulations in place to tackle AML/CTF.

New employees are trained on AML policy & procedures within 30 days of joining Halli Jewelry Company, with mandatory follow-up trainings conducted annually.

Record Keeping & Confidentiality

All records including the customer’s identification documents, transaction data and any other relevant document are maintained for a minimum of five years. This is in line with the regulations of the laws of the Ministry of Commerce Money Laundering Department.

Halli Jewelry Company maintains the confidentiality of all the information provided by its customers and their transaction records and keeps all related data private.

First: Appointing a Kuwaiti compliance observer to be responsible for implementing the law and all legislation and instructions issued by the competent authorities:

Second: Applying due diligence measures with the client according to the degree of risk:

Identify and verify the identity of the customer and the actual beneficiary using reliable and independent documents or data, and that we provide the necessary care with customers through:-

​1- Writing and recording all customer data.

​2- Keep copies of customer papers and civil ID.

​3- Not accepting cash amounts of more than 3000 Kuwaiti dinars.

​4- Payment is via bank debit cards (K-Net).

​5- Ensure that the bank card is in the name of the customer.

​6- Giving the customer complete freedom to conduct and complete the transaction.

Third: High standards when hiring employees:

Among our stressful recruitment conditions are:

• The employee should have experience in dealing with material transactions.
• Submits a criminal record to the company before work.
• To have the ability to deal with customers and the art of dealing with the public.
• To pass the paper tests and the personal interview of the company.

Fourth: Implementing a continuous program to train employees:

To ensure that the work team is aware of the requirements of combating money laundering and terrorist financing, new developments, methods, methods and trends in the field of money laundering and terrorist financing, the requirements related to due diligence and the dangers of any suspicious transactions, a training plan has been developed for employees by enrolling them in training courses, seminars and educational workshops with specialized training institutes and legal consultancy offices.

•  Because of the importance of developing the staff with the new developments in this regard, a subsidiary company of our company called Halli Jewelry Company Institute was established to serve the company's activities and its employees in particular in terms of specialized technical courses in the field of money laundering in agreement with lecturers from Kuwait University who specialize in this field.

Fifth: Establishing independent internal audit functions to verify compliance with internal policies, procedures, systems and controls:

To achieve the tasks of the internal audit, employees have been appointed and assigned to them with specialized tasks in this field and daily follow-up, and their tasks include:-

• Verify all invoices and payments and ensure that the cash payment amount is adhered to.
• Ensure the civil ID companions of each client.
• Register the journal stamped by the Ministry of Justice.
• Inventory book.
• Preparing all accounts of the auditor agreed with him (Ernst and Young - Al-Aiban, Al-Osaimi and Co.) so that he is ready to audit the accounts and inventory with them.

Sixth: Establishing an electronic database:

An integrated database has been prepared for each customer and a historical record of all its purchases and sales, which can be referenced at any time.

Seventh: Keeping records and information:

In implementation of what was stated in Article 11 of the law to keep for at least five years and prove that all transactions with customers are recorded in official records in accordance with an organized accounting system available to the supervisory authorities, we have implemented these laws and kept all required records and stored backup copies of all transactions.

Eighth: The obligation to notify the Kuwaiti Financial Intelligence Unit:

All employees were assured of the obligation, without delay, to notify the Kuwaiti Financial Intelligence Unit of any transaction or any attempt to conduct a transaction, regardless of its value, if it was suspected or there were sufficient evidence to suspect that such a transaction was being conducted with funds obtained from a crime or funds related to, related to it or that could be used. To carry out money laundering or terrorist financing operations.

In the event of any suspicious transaction, the following shall be done:-

• Verify customer data (civil number, name and address).
• Ensure that the customer is not among the suspicious figures.
• Communicate with the Kuwaiti Financial Intelligence Unit through their means of communication and the forms designated for reporting.
• Examining daily any update in the data of those banned on terrorism and money laundering websites approved by the Money Laundering Department and the Kuwaiti Investigation Unit.

Ninth: Dealing with those on the international and national sanctions lists related to terrorism:

All employees have been assured, in the event of suspicions about a customer, to do the following:

• Ensure that the name is included in the list of individuals and entities.
• Refrain from providing any types of services to those listed and notify the list to review the Security Council Resolutions Implementation Committee of the Ministry of Foreign Affairs.
• Informing the Special Committee for the Implementation of Security Council Resolutions Related to Terrorism at the Ministry of Foreign Affairs within three days at the e-mail account (CTC@mofa.gov.kw).

Tenth: Risk Assessment Study:

The risk assessment study was kept with a acknowledgment of risk or updated and provided to the supervisory authorities (Ministry of Commerce and Industry) upon request, taking into account the results of the assessment study and setting appropriate procedures to determine Money laundering and terrorist financing risks Taking into account the risk factors mentioned in the law, ministerial decisions and indicators of suspicion of the client published on the website of the Kuwaiti Financial Intelligence Unit when preparing the study)

Eleventh: Commercial and Electronic Contracting System:

An electronic commercial contract system specialized in the field of gold has been established for our company and is constantly being developed. This system has been dealt with since the opening of the company and all decisions issued by the Ministry of Commerce in the same have been implemented, as the program contains:-

• Listed database and fast.
• Daily recording of all accounting transactions and storing them with backup copies.
• Record a barcode system for each piece in the company with its details.
• Electronically storing all attached files (civil card or bank document) for each client.
• Details of each invoice with its payments (knet or cash) are recorded electronically.
• Daily, weekly, monthly and annual reports on all invoices and their total.
• The ability to search the database with ease.