AML / KYC Policy

1. Policy Statement

Global Passport Partners FZ-LLC ("GPP") is committed to preventing money laundering, terrorist financing and sanctions evasion. Investment migration is a gatekeeping industry: our files are relied upon by governments, banks and due diligence agencies, and we hold ourselves to the standard that relationship demands.

This framework is aligned with the Financial Action Task Force (FATF) Recommendations, UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and its Cabinet implementing decisions, and the AML requirements of each citizenship and residency programme we operate.

2. Know Your Customer (KYC)

Before accepting any engagement, we identify and verify every applicant and adult dependant using government-issued identity documents, proof of address, and — where an entity is involved — full beneficial ownership analysis to the natural persons ultimately owning or controlling it.

We screen all parties against international sanctions lists (UN, OFAC, EU, UK HMT, UAE Local Terrorist List), politically exposed person (PEP) databases and adverse media, at onboarding and continuously throughout the engagement.

3. Source of Funds and Source of Wealth

Every engagement requires documented evidence of both the source of the specific funds used (bank statements, sale contracts, dividend records, audited accounts, exchange statements for digital assets) and the origin of the client's overall wealth. Files that cannot be evidenced to this standard are declined, regardless of commercial value.

4. Enhanced Due Diligence

Enhanced due diligence applies to PEPs and their close associates, clients from high-risk or monitored jurisdictions as designated by FATF, complex ownership structures, digital-asset-derived wealth, and any file presenting unusual transaction patterns. Enhanced measures include senior management approval, independent verification, and additional documentary corroboration.

5. Prohibited Clients

We do not act for: persons subject to sanctions; persons with convictions for serious financial crime, trafficking, or terrorism-related offences; shell banks; clients who refuse to complete KYC; or funds that cannot be traced to a lawful origin. We reserve the right to decline or exit any engagement without stating reasons where financial crime risk is suspected.

6. Payment Controls

All payments must be made by bank transfer from accounts held in the name of the applicant (or otherwise documented to AML standard). We do not accept cash, bearer instruments, or third-party payments without verified justification. Cryptocurrency is not accepted as direct payment; crypto-origin wealth must be converted through regulated exchanges into the banking system with a complete audit trail.

7. Reporting and Record Keeping

Suspicious activity is reported to the UAE Financial Intelligence Unit through the goAML platform, and to equivalent authorities in other jurisdictions where required. Tipping-off is prohibited. Client identification and transaction records are retained for a minimum of 5 years after the end of the business relationship.

8. Training and Governance

All staff receive AML training at onboarding and annually thereafter. A designated Money Laundering Reporting Officer (MLRO) oversees this framework, which is reviewed annually and audited independently. Questions may be directed to postmaster@globalpassportpartners.com.