Anti-Money Laundering (AML), Know Your Customer (KYC) & Due Diligence Policy
Public Summary
Last updated: January 2026
Naucom L.L.C. (“Naucom L.L.C.”, “we”, “us”, “our”) is committed to conducting its business in compliance with applicable anti-money laundering, counter-terrorist financing, sanctions, and financial crime prevention laws and regulations.
This public summary outlines our high-level approach to AML, KYC, and due diligence. It is provided for general informational purposes only and does not disclose internal controls, thresholds, or procedures.
1. Our Commitment
Naucom L.L.C. maintains a zero-tolerance approach to money laundering, terrorist financing, fraud, corruption, sanctions evasion, and other forms of financial crime.
We are committed to:
- complying with applicable laws and regulations in the United Arab Emirates and other jurisdictions in which we operate;
- aligning our practices with internationally recognised standards, including those issued by the Financial Action Task Force (FATF);
- supporting the objectives of the UAE’s national AML/CFT framework and competent authorities; and
- conducting business only with legitimate, lawful, and appropriately verified counterparties.
2. Scope
Our AML, KYC, and due diligence measures apply on a risk-based basis to:
- customers and counterparties;
- business partners, introducers, and intermediaries;
- suppliers and service providers; and
- transactions and engagements facilitated by Naucom L.L.C.
3. Know Your Customer (KYC)
Naucom L.L.C. applies proportionate, risk-based KYC measures designed to:
- identify and verify the identity of counterparties;
- confirm legal existence, ownership, and authorised signatory authority; and
- understand the nature, purpose, and expected activity of the business relationship.
Depending on the engagement, we may request corporate, ownership, and authority documentation consistent with applicable laws and industry standards.
4. Due Diligence & Risk Assessment
We apply due diligence measures proportionate to assessed risk, which may take into account factors including:
- jurisdictional and geographic risk;
- sector, product, and transaction risk;
- counterparty structure and ownership; and
- delivery, logistics, and payment arrangements.
Where elevated risk is identified, enhanced due diligence measures may be applied, or the engagement may be declined.
5. Sanctions, Restricted Parties & Jurisdictions
Naucom L.L.C. does not knowingly engage in business with individuals, entities, vessels, or jurisdictions subject to applicable sanctions, embargoes, or restrictive measures.
We reserve the right to:
- screen counterparties against relevant sanctions and watchlists; and
- refuse, suspend, or terminate engagements where risks cannot be adequately mitigated.
6. Ongoing Monitoring
Business relationships may be subject to ongoing review to ensure consistency with the nature and purpose of the engagement and applicable legal requirements.
Naucom L.L.C. reserves the right to request updated information or documentation at any time.
7. Record Keeping
Records relating to KYC, due diligence, and transactions are maintained in accordance with applicable UAE laws and other relevant regulatory requirements.
8. Confidentiality & Data Protection
Information collected for AML, KYC, and due diligence purposes is handled confidentially and processed solely for compliance, risk management, and legitimate business purposes, subject to applicable legal and regulatory disclosure obligations, including UAE data protection requirements.
9. Non-Circumvention of Controls
Naucom L.L.C. does not participate in, support, or facilitate transactions designed to evade or bypass regulatory, banking, sanctions, or compliance controls.
10. Reporting & Cooperation
Where required by law, Naucom L.L.C. will cooperate with competent authorities and comply with lawful requests made by regulators, courts, or law enforcement agencies in the UAE or other applicable jurisdictions.
11. No Reliance
This public summary:
- does not constitute legal advice;
- does not create contractual rights or obligations; and
- should not be relied upon as a complete description of Naucom L.L.C.’s internal AML, KYC, or due diligence procedures, which are maintained separately and are not publicly disclosed.
12. Contact
For general questions regarding this policy summary, please contact:
NaucomL.L.C.
Email: services@naucomllc.com