Introduction
91.community owned and operated by Ninety-One 91 Ltd, Company Limited by shares, with the license number 07010414 with the head office address at RAK DAO Business Centre, Al Rifaa, Sheikh Mohammed Bin Zayed Road, Ras Al Khaimah, United Arab Emirates ‘’the company or 91.community’’ is committed to the highest standards of compliance in the fight against money laundering (AML) and the financing of terrorism (CFT). The objective of 91.community AML is to actively prevent and mitigate the risks associated with money laundering and terrorist financing activities. To assist government efforts in combating these activities, financial institutions, including 91.community, are required by law to obtain, verify, and record information that identifies each person who opens an account. 91.community is obligated to report any suspicious client activity that may be relevant to money laundering.

Money Laundering: Definition and Stages
Money Laundering is the process of converting funds derived from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that appear legitimate, thereby concealing the true source of the funds.The money laundering process typically occurs in three sequential stages:

Placement: At this stage, illicit funds are introduced into the financial system. This may involve converting cash into financial instruments like checks or bank deposits or purchasing high-value goods that can be resold. To avoid detection, multiple smaller transactions may be made instead of a single large deposit, a practice known as "smurfing."

Layering: This stage involves moving funds through a series of financial transactions to obscure their origin. Funds may be transferred to different accounts or converted into various financial instruments to break the link between the funds and their illicit source.

Integration: The funds are reintroduced into the economy as legitimate money, often through the purchase of goods and services, thereby completing the laundering process.91.community adheres to the principles of Anti-Money Laundering and actively prevents any actions that could facilitate the legalization of illegally obtained funds. 91.community has set up a verification process through the plateform ONDATO that allows to be compliant with all the KYC standarts. Our AML policy is designed to prevent the use of 91.community services for money laundering, terrorist financing, or other criminal activities. 91.community does not accept or make payments in cash under any circumstances. The company reserves the right to suspend the operations of any client if there is suspicion of illegal activities or money laundering.

Company Procedures
91.community will ensure the identity of every client, whether an individual or a legal entity, is thoroughly verified. The company takes all necessary measures in accordance with applicable laws and regulations issued by the relevant authorities. The AML policy at 91.community is enforced through the following measures:• Know Your Customer (KYC) Policy and Due Diligence• Monitoring of Customer Activity• Record Maintenance Know Your Customer (KYC)As part of 91.community commitment to AML and KYC policies, each client must complete a thorough verification process. Before 91.community begins any relationship with a client, the company ensures that satisfactory evidence is provided, or other measures are taken to prove the identity of any client or counterparty. Increased scrutiny is applied to clients who reside in or whose funds originate from countries identified as having inadequate AML standards or posing a high risk of crime and corruption. Individual Clients During the registration process, each client must provide personal information, including:
• Full name
• Date of birth
• Country of origin
• Full residential address

To verify this personal information, clients are required to submit the following documents (with notarized translations in English if necessary):
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•A valid passport (showing the first page with the photo and signature clearly visible), or• A driving license with a photograph, or
•A national identity card (showing both the front and back)Corporate ClientsIf the applicant company is listed on a recognized stock exchange or has independent evidence proving it is a wholly-owned subsidiary, no further verification is typically required.

However, if the company is not listed or is new to 91.community, the following documentation is necessary:• Certificate of incorporation or national equivalent
• Memorandum and Articles of Association or national equivalent
• Certificate of good standing or other proof of the company’s registered address
• Resolution from the board of directors to open an account and grant authority to those who will operate it
• Copies of powers of attorney or other authorities granted by the directors
• Proof of identity of the directors, final beneficiaries, or any person authorized to act on behalf of the company (in accordance with individual identity verification rules)

Monitoring Customer Activity
In addition to collecting customer information, 91.community continuously monitors client activity to detect and prevent suspicious transactions. A suspicious transaction is defined as one that is inconsistent with the client's known business or transaction history. 91.community has implemented both automated and manual transaction monitoring systems to prevent criminals from using its services.

Record Maintenance
91.community is committed to maintaining records of all transaction data, client identification documents, and all documentation related to money laundering issues, such as suspicious activity reports (SARs) and AML account monitoring records. These records are kept for a minimum of seven years after the account is closed.
Measures Taken
If 91.community suspects that a transaction is related to money laundering or other criminal activities, the company will act in accordance with applicable laws and report the suspicious activity to the relevant regulatory authority. 91.community reserves the right to suspend any client operation that appears illegal or related to money laundering and has full discretion to temporarily block the suspicious client’s account or terminate the relationship.Contact Information If you have any questions about these Terms, our Privacy Policy, the Service, or any of our Platforms, please contact us at legal@91.community.com