AML & CTF Policy

We identify and verify every customer and beneficial owner before opening an account. Enhanced due diligence applies to politically exposed persons, high-risk jurisdictions and high-risk business models.

All customers, counterparties and transactions are screened in real time against UN, OFAC, EU, UK HMT and local UAE sanctions lists. Matches are blocked pending investigation by our Financial Crime team.

Automated rules and machine-learning models monitor every transaction for unusual patterns, structuring, rapid movement of funds and other red flags. Alerts are triaged by analysts and escalated to the MLRO where appropriate.

Where we know or suspect money laundering or terrorist financing, we file Suspicious Transaction Reports with the UAE Financial Intelligence Unit and cooperate with competent authorities.

KYC, transaction and investigation records are retained for a minimum of five (5) years and made available to regulators on request.

All Lexpay staff complete annual AML/CTF training. The program is owned by the Money Laundering Reporting Officer (MLRO) and reviewed annually by the Board.

Lexpay does not service shell banks, anonymous accounts, or businesses involved in human trafficking, narcotics, weapons proliferation, child exploitation, unlicensed gambling or sanctioned activity.