Anti‑Money Laundering (AML) Policy
Policy Statement
Goldman Whites Real Estate L.L.C (“we”, “us”, “our”) is fully committed to preventing money laundering, terrorist financing, and other financial crimes. We conduct our business in compliance with all applicable Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) laws and regulations of the United Arab Emirates. This Policy outlines the principles, controls, and procedures we implement to detect, deter, and report suspicious activities.
Scope of This Policy
This AML Policy applies to:
All clients, customers, and business partners
All property transactions facilitated by the Company
All employees, agents, and representatives of Goldman Whites Real Estate L.L.C
All services offered through https://gwrealestates.com/
Legal & Regulatory Framework
We adhere to UAE AML/CFT regulations, including but not limited to:
Federal Decree-Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism
Cabinet Decision No. (10) of 2019 and its amendments
Guidance issued by relevant UAE regulatory authorities
Customer Due Diligence (CDD)
We apply appropriate due diligence measures before establishing business relationships or conducting transactions, including:
Identification and verification of clients using valid, official documents
Identification of beneficial owners, where applicable
Understanding the purpose and nature of the business relationship
Ongoing monitoring of transactions to ensure consistency with client profiles
Enhanced Due Diligence (EDD) may be applied for higher-risk clients or transactions.
Risk-Based Approach
We adopt a risk-based approach to AML compliance by assessing:
Client risk (e.g., individuals, corporates, politically exposed persons)
Transaction risk (value, structure, payment methods)
Geographic risk
Property and service risk
Controls and monitoring levels are adjusted based on the assessed risk.
Politically Exposed Persons (PEPs)
Where a client or beneficial owner is identified as a Politically Exposed Person (PEP), we:
Apply enhanced due diligence measures
Obtain senior management approval prior to proceeding
Conduct ongoing monitoring of the relationship
Monitoring & Reporting of Suspicious Activity
We actively monitor transactions and client behavior for indicators of suspicious activity. Where suspicion arises, we:
Conduct internal reviews
File Suspicious Transaction Reports (STRs) with the relevant UAE authority, as required
Maintain strict confidentiality and do not disclose reporting actions to the client (“tipping-off” is strictly prohibited)
Record Keeping
We maintain records related to:
Client identification and verification
Transaction details
Due diligence documentation
Records are retained for the period required under applicable UAE laws and regulations.
Training & Awareness
Failure to comply with this AML Policy may result in disciplinary action, termination of business relationships, or reporting to relevant authorities, where required.
Non-Compliance
Failure to comply with this AML Policy may result in disciplinary action, termination of business relationships, or reporting to relevant authorities, where required.
Policy Review & Updates
This AML Policy is reviewed periodically and updated to reflect changes in laws, regulations, or business practices. Updates will be published on this page with a revised “Last Updated” date.
Contact Information
For AML-related queries or compliance concerns, please contact:
Goldman Whites Real Estate L.L.C
Email: info@gwgroup.ae
Phone: +971-47-700-871