Miralles SC FZ-LLC
Registered Address: Al Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates

Money Laundering Reporting Officer (MLRO): Omar Jose Tua Giménez

1. Introduction

Miralles SC FZ-LLC (“the Company”) is fully committed to complying with international best practices and applicable laws regarding Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF).
This policy outlines the principles, internal controls, and procedures implemented to prevent the Company’s services from being used for criminal activities, in accordance with the regulations of the United Arab Emirates and the recommendations of the Financial Action Task Force (FATF).

2. Objectives

• Prevent the use of Miralles SC FZ-LLC’s services for money laundering or terrorist financing.
  
  
  

• Ensure proper identification and verification of customers and beneficial owners.
  
  
  

• Detect and report suspicious transactions to the relevant authorities.
  
  
  

• Maintain accurate and complete records as required by law.
  
  
  

• Provide ongoing training to staff regarding AML/CTF obligations.
  
  
  

3. Key Definitions

Money Laundering

The process of transforming proceeds from illegal activities into apparently legitimate assets. It consists of three stages:

1. Placement: introducing illicit funds into the financial or commercial system.
   
   
   

2. Layering: conducting multiple transactions to obscure the origin of the funds.
   
   
   

3. Integration: reintroducing the funds back into the economy as seemingly legitimate.
   
   
   

Terrorist Financing

The provision, collection, or transfer of funds intended to support terrorist activities—regardless of whether the funds originate from legal or illegal sources.

4. Risk-Based Approach (RBA)

Miralles SC FZ-LLC applies a Risk-Based Approach, in line with FATF standards:

• Assessing each customer’s risk profile prior to establishing a business relationship.
  
  
  

• Assigning risk levels: low, medium, high.
  
  
  

• Applying due diligence measures proportionate to the assessed risk.
  
  
  

• Conducting Enhanced Due Diligence (EDD) for higher-risk customers and jurisdictions.
  
  
  

High-risk jurisdictions include countries identified by FATF or UAE authorities as having inadequate AML/CTF controls.

5. Role of the MLRO

The Company appoints Omar Jose Tua Giménez as its Money Laundering Reporting Officer (MLRO).

Responsibilities include:

• Overseeing implementation of the AML/CTF policy.
  
  
  

• Reviewing and approving customer due diligence procedures.
  
  
  

• Assessing and investigating suspicious activities.
  
  
  

• Reporting suspicious transactions to the competent authority in the UAE.
  
  
  

• Coordinating internal and external AML/CTF audits.
  
  
  

• Organizing staff training and maintaining training records.
  
  
  

6. Customer Due Diligence (CDD/KYC)

6.1 Individual Customers

The Company collects and verifies:

• Full legal name
  
  
  

• Date of birth
  
  
  

• Nationality and country of residence
  
  
  

• Complete residential address
  
  
  

• Valid identification document (clear and unexpired):
  
  
  

  • Passport, or
    
    
    

  • National ID card, or
    
    
    

  • Driver’s licence with photograph
    
    
    

• Proof of address (utility bill, bank statement, etc.) not older than 3 months
  
  
  

6.2 Corporate Customers

Required documentation includes:

• Certificate of Incorporation or equivalent
  
  
  

• Memorandum & Articles of Association or equivalent
  
  
  

• Certificate of Good Standing or proof of registered address
  
  
  

• Board Resolution authorizing the opening of an account
  
  
  

• Powers of attorney or similar authorizations
  
  
  

• Identification of:
  
  
  

  • Directors
    
    
    

  • Authorized signatories
    
    
    

  • Ultimate Beneficial Owners (UBOs)
    
    
    

6.3 Enhanced Due Diligence (EDD)

EDD is applied in cases including:

• Customers from high-risk jurisdictions
  
  
  

• Politically Exposed Persons (PEPs)
  
  
  

• Complex or unusual transactions
  
  
  

• Corporate structures with opaque or multi-layered ownership
  
  
  

EDD may involve additional documentation and approval from senior management and the MLRO.

7. Ongoing Monitoring & Detection of Suspicious Activities

Miralles SC FZ-LLC continuously monitors customer activity through:

• Automated systems
  
  
  

• Manual review where necessary
  
  
  

A transaction is considered suspicious when it:

• Does not match the customer’s declared profile or source of funds
  
  
  

• Lacks clear economic or legal purpose
  
  
  

• Involves patterns consistent with layering
  
  
  

• Shows unusual size, frequency, or complexity
  
  
  

The MLRO will review and document all alerts and determine whether a report must be filed.

8. No-Cash Policy

Miralles SC FZ-LLC does not accept or disburse cash under any circumstances.
All transactions must be conducted through traceable, electronic payment methods.

9. Record Keeping

The Company keeps:

• Customer identification documents
  
  
  

• Transaction records
  
  
  

• Internal AML/CTF reports
  
  
  

• Suspicious Activity Reports (SARs) and related documentation
  
  
  

Records are maintained for at least 7 years from the termination of the business relationship or the date of the transaction, whichever is later.

10. Staff Training

Employees receive periodic training covering:

• AML/CTF legal obligations
  
  
  

• Identification of red flags and suspicious indicators
  
  
  

• Internal reporting procedures
  
  
  

• Individual responsibilities regarding compliance
  
  
  

Training is provided at least annually and whenever regulatory changes occur.

11. Reporting Suspicious Transactions

If suspicious activity is identified:

1. Staff must promptly report internally to the MLRO.
   
   
   

2. The MLRO conducts a documented investigation.
   
   
   

3. If required, an official Suspicious Transaction Report (STR) is filed with UAE authorities.
   
   
   

4. Staff must not inform the customer of any reporting (tipping-off prohibition).
   
   
   

12. Internal Measures & Corrective Actions

The Company reserves the right to:

• Request additional information or documentation
  
  
  

• Suspend transactions
  
  
  

• Temporarily freeze an account or activity
  
  
  

• Terminate the business relationship
  
  
  

These actions may be taken when suspicious behaviour is detected or when the customer fails to meet AML requirements.

13. Confidentiality & Data Protection

All information obtained for AML/CTF purposes is treated as strictly confidential.
It is used solely for compliance and regulatory purposes and protected according to applicable data protection standards.

14. Policy Review

This policy is reviewed at least annually or whenever significant regulatory changes occur, to ensure ongoing compliance and effectiveness.