Compliance Framework

AML, CFT & CFP Framework

إطار مكافحة غسل الأموال وتمويل الإرهاب

Anti-Money Laundering, Counter Financing of Terrorism, and Counter Financing of Proliferation — our commitment to safeguarding the integrity of the global financial system.

Compliance Overview

Anti-Money Laundering · Counter Financing of Terrorism · Counter Financing of Proliferation

ABQ Finance Limited, as a wholly-owned subsidiary of Ahli Bank Q.P.S.C. (the "Guarantor"), operates under the comprehensive AML, CFT & CFP compliance framework established by the Bank. Ahli Bank Q.P.S.C. was established in the State of Qatar in 1983 and is licensed, regulated, and supervised by the Qatar Central Bank (QCB). The Bank is listed on the Qatar Stock Exchange (QE) under reference code ABQK.

Money laundering, financing of terrorism, and financing the proliferation of weapons of mass destruction represent global threats to the stability of financial systems. Ahli Bank Q.P.S.C. is committed to actively safeguarding the integrity of the financial sector by implementing robust controls aligned with international standards and Qatari regulatory requirements.

Legal & Regulatory Foundation

The framework is built upon the following legislative and regulatory instruments:

Qatar Law No. (20) of 2019

Combating Money Laundering and Terrorism Financing

The primary legislative instrument governing AML/CFT obligations for all financial institutions operating in the State of Qatar, aligned with FATF recommendations.

QCB Regulations

Qatar Central Bank AML, CFT & CFP Regulations

Issued by the Qatar Central Bank to financial institutions, prescribing detailed operational requirements for compliance with the national AML/CFT law.

FATF Standards

Financial Action Task Force Recommendations

The international standard-setting body whose 40 Recommendations form the basis of coordinated global responses to money laundering, terrorist financing, and proliferation financing.

Board-Approved Policy & Procedures Manual

To ensure compliance with Qatari law, FATF Recommendations, and QCB regulations, Ahli Bank Q.P.S.C. has developed and implemented a comprehensive "AML, CFT & CFP Policy and Procedures Manual", approved by the Board of Directors. The Manual safeguards the Bank and its subsidiaries — including ABQ Finance Limited — from money laundering and terrorism financing risks.

01

ML, FT & FP Risk Identification

Identification and assessment of potential money laundering, terrorist financing, and proliferation financing risks relevant to the Bank's activities.

02

Customer Acceptance Policy

Rigorous customer acceptance criteria to ensure compliance before onboarding new relationships.

03

Customer Identification (CID)

Formal customer identification process aligned with regulatory requirements for verifying identity and beneficial ownership.

04

Risk-Based Classification

Customer risk-based classification system to assign appropriate levels of due diligence and ongoing monitoring.

05

Know Your Customer (KYC)

Comprehensive KYC procedures including ongoing verification, document collection, and periodic updates of customer information.

06

PEP Screening

Enhanced identification, risk assessment, and ongoing monitoring of Politically Exposed Persons (PEPs) and their associates.

07

Enhanced Due Diligence (EDD)

Enhanced due diligence measures for high-risk customers, complex structures, and correspondent banking relationships.

08

Transaction Monitoring

Automated rule-based transaction monitoring system to detect unusual patterns and generate exception alerts for investigation.

09

Sanctions Screening

Real-time scanning of names against international and local blacklists, including UN, OFAC, EU, and QCB sanctions lists.

10

Suspicious Activity Reporting

Internal procedures for monitoring and reporting suspicious persons and transactions to Qatar Financial Information Unit (QFIU).

11

Wire Transfer Controls

All wire transfer channels interfaced with the AML system for beneficiary screening against sanction lists prior to transmission.

12

Staff Training Programme

Ongoing staff training on KYC, AML, CFT & CFP awareness including relevant laws, recommendations, and regulatory updates.

Shell Bank Prohibition

The Bank is strictly prohibited from conducting any relationship or establishing, maintaining, administering, or managing an account for, or on behalf of, a shell bank — in full compliance with international anti-money laundering standards and QCB directives.

Tax Compliance — FATCA & CRS

FATCA
Foreign Account Tax Compliance Act

Ahli Bank Q.P.S.C. is a FATCA-Compliant Financial Institution with Reporting Model 1 FFI status. The Bank maintains full compliance with US tax reporting requirements through the inter-governmental agreement framework.

ABQ GIIN

9B5U0P.00000.LE.634

ABC (Brokerage) GIIN

9B5U0P.00001.ME.634

CRS
Common Reporting Standard

Ahli Bank commenced CRS Annual Reporting in 2018, collecting tax residency status information from customers through specific due diligence forms for Individuals, Entities, and Controlling Persons in accordance with CRS standards and OECD guidelines.

Tax Identification Number (TIN)

5000838938

Issuing Authority

General Tax Authority (GTA) / Ministry of Finance (MOF)

Code of Ethics & Business Conduct

All directors, officers, and employees of ABQ Finance Limited and Ahli Bank Q.P.S.C. are bound by a strict Code of Ethics designed to maintain the highest standards of professional and personal conduct.

Conflict of Interest

Strict protocols to identify, disclose, and manage situations where personal interests could interfere with the objective performance of duties.

Confidentiality & Data Protection

Absolute confidentiality of non-public information, adhering to international data privacy standards to protect stakeholder and investor data.

Market Integrity

Zero tolerance for insider trading or market manipulation. Full compliance with QFMA regulations regarding price-sensitive information.

Anti-Bribery & Corruption

Prohibition of any form of bribe or improper inducement in all jurisdictions where we operate, in line with international best practices.

Whistleblowing

A secure, confidential channel for reporting unethical behavior or policy breaches without fear of retaliation.

Record Keeping

Comprehensive record keeping and retention requirements for all customer and transaction data as mandated by QCB regulations.

Unconditional Guarantee

All debt securities issued by ABQ Finance Limited are unconditionally and irrevocably guaranteed by Ahli Bank Q.P.S.C. (the "Guarantor"), a public shareholding company regulated by the Qatar Central Bank.

Compliance Authority

Head of Compliance

Khaldoun Al-Khateeb

Last Policy Update

1 May 2024

Regulatory Bodies

QCB · QFMA · QFIU

Registered Office — ABQ Finance

c/o Maples Corporate Services Limited, PO Box 309, Ugland House, George Town, Grand Cayman, KY1-1104, Cayman Islands

ABQ Finance — Legal Status

Exempted company with limited liability, Reg. No. 309204 — Cayman Islands (Incorporated 3 March 2016)

Ahli Bank — Commercial Registration

CR No. 8989 — Ahli Bank Q.P.S.C., State of Qatar (Established 1983)

For more information on Ahli Bank Q.P.S.C. and regulatory authorities:

Compliance Inquiries

For questions regarding our AML/CFT framework, compliance policies, or regulatory reporting.