Anti-Money Laundering (AML) Policy

Rust Innovations is committed to preventing money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.

1. Introduction

Rust Innovations LLP is committed to combating money laundering, terrorist financing, and financial crimes. This policy is designed to ensure compliance with all applicable AML regulations in Pakistan and internationally, while maintaining the integrity of our operations across all jurisdictions where we operate.

2. Objectives

• Prevent misuse of Rust Innovations LLP’s services for illegal financial activity.
• Ensure all clients are properly verified and monitored.
• Maintain a secure financial environment through transparency, due diligence, and cooperation with financial institutions and regulatory authorities.
• Comply fully with local and international AML and Counter-Terrorist Financing (CTF) laws.

3. Client Due Diligence (CDD)

We strictly follow Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures. No business activity is conducted with any client without proper due diligence. This includes:

• Full identification: CNIC/passport, valid contact number, current address.
• Payment source verification: All clients are required to confirm that their payment source is clean, legal, and not related to any illicit activity.
• Client location: Geographical location is recorded and preserved for compliance review.
• Secure record-keeping: All client data including identity proof, contact details, and trade/payment history are securely stored in compliance with data protection policies.

4. Transaction Transparency & Banking Cooperation

All business transactions are processed through official banking channels. We maintain detailed trade/payment history for each client to:

• Provide transparency for audits or inquiries.
• Respond to bank compliance teams during periodic reviews.
• Submit client transaction justifications when required by financial institutions.

5. Risk-Based Approach & Monitoring

We apply a risk-based approach based on the nature of the client, country of origin, and transaction behavior. Higher-risk clients (e.g., cross-border payments) are subject to enhanced monitoring and documentation.

6. Sanctions Screening

Rust Innovations LLP strictly screens all clients and partners against the following international sanctions lists:

• Office of Financial Sanctions Implementation HMT (OFSI)
• United Nations Security Council Sanctions List (UN)
• U.S. Department of the Treasury – Office of Foreign Assets Control (OFAC)
• European Union Consolidated Sanctions List (EU)

We do not engage in any transactions involving:

• Entities or individuals listed on the above sanctions lists.
• Clients from restricted, blacklisted, or high-risk countries.
• Any person or organization under financial, economic, or trade sanctions.

7. Jurisdictional Compliance

We ensure full compliance with local AML and anti-terror financing laws in every country where we operate. These include:

• Pakistan (FATF guidelines & SBP directives)
• UAE, Indonesia, and other jurisdictions where we offer services.
• International AML best practices as advised by FATF and global regulators.

8. Internal Controls, Reporting, and Recordkeeping

• All suspicious transactions are internally flagged and, if necessary, reported to authorities such as FIA or respective financial institutions.
• Comprehensive internal logs are maintained for at least 3 years.
• AML policy is reviewed annually and updated as per regulatory or operational changes.

9. Employee Awareness & Training

• Key staff and compliance team are trained to identify high-risk transactions and report them immediately.
• All employees are informed of their responsibility under this AML Policy.