Anti-Terrorism Policy
Purpose and Scope
This Anti-Terrorism and Counter-Terrorist Financing Policy ("the Policy") establishes Tahweel's obligation to prevent its platform, products, and services from being misused in any manner that could support terrorism, terrorist entities, or persons involved in terrorist acts.
This Policy applies to:
- All employees, contractors, and representatives of Tahweel
- All agents and partners operating under the Tahweel brand or using Tahweel systems
- All users, merchants, and business clients using Tahweel services
Policy Statement
Tahweel adopts an uncompromising approach toward any activity connected to terrorism or the financing of terrorism. The company pledges full adherence to all applicable legal, regulatory, and sanctions requirements, as well as international best practices, and will actively support competent authorities when required.
Legal and Regulatory Framework
Tahweel adheres to:
- National laws and regulations on combating terrorism and terrorist financing in the jurisdictions where it operates
- International standards issued by bodies such as the Financial Action Task Force (FATF)
- UN, local, and international sanctions and watch lists
Roles and Responsibilities
| Role | Responsibility |
|---|---|
| Senior Management | Approve and oversee the implementation of this Policy. Promote a strong compliance and "zero tolerance" culture. |
| Compliance Officer | Implement and maintain procedures for detecting and reporting suspected terrorist financing. Monitor regulatory updates and ensure the Policy is updated accordingly. |
| Employees and Agents | Follow all procedures related to onboarding, KYC, monitoring, and reporting. Immediately escalate any suspicious activity or customer behavior that may be related to terrorism or terrorist financing. Participate in regular training and awareness sessions. |
Customer Due Diligence (CDD) and Know Your Customer (KYC)
Tahweel implements robust KYC and CDD procedures to prevent terrorist organizations or individuals from accessing its services, including:
- Verifying identity of all customers (individuals and entities) using reliable, independent documents and data
- Identifying and verifying beneficial owners of legal entities where applicable
- Screening all customers, agents, merchants, and partners against relevant sanctions, terrorist, and watch lists at onboarding and on a regular basis
Sanctions and Watch List Screening
Tahweel will:
- Screen customers, agents, merchants, and transactions against applicable sanctions and terrorist lists
- Block, freeze, or restrict accounts or transactions where required by law or sanctions rules
- Immediately escalate potential matches to the Compliance Officer for review and, where necessary, reporting to authorities
Suspicious Activity Reporting
Where Tahweel identifies activity that may be linked to terrorism or terrorist financing, it will:
- File a Suspicious Transaction/Activity Report with the competent authority, in line with local legal requirements
- Cooperate with law enforcement and regulatory bodies as required
- Refrain from "tipping off" the customer or third parties about any investigation or report
Record Keeping
Tahweel will maintain records of:
- Customer identification and verification documents
- Transactions and account activity
- Screening results and decisions
- Suspicious activity reviews and reports
These records will be kept for the period required by applicable laws and regulations.
Training and Awareness
Tahweel provides regular training to all relevant staff and agents on:
- Anti-terrorism and counter-terrorist financing obligations
- Red flags and indicators of terrorist financing
- Procedures for escalation and reporting
- Sanctions compliance and customer screening
Training is mandatory and may be refreshed periodically or when regulations change.
Risk Assessment
Tahweel conducts periodic risk assessments to identify and assess the risks of its products, services, delivery channels, customer types, and geographic exposure being used for terrorist financing. Controls and procedures will be adjusted based on the risk assessment outcomes.
Breaches and Disciplinary Measures
Any employee, agent, or partner who violates this Policy may face:
- Disciplinary action, up to and including termination of employment or agency
- Reporting to regulatory or law enforcement authorities, if required
- Civil or criminal consequences under applicable laws
Policy Review
This Policy will be reviewed regularly, or whenever there are significant changes in applicable laws, regulations, or the risk environment. Updates will be approved by senior management and communicated to all relevant parties.
