AML Policy
Anti-Money Laundering policy for FundingOptimal, outlining controls to prevent ML/TF and ensure compliance with UAE regulations.
Table of Contents
AML Policy FundingOptimal
FundingOptimal is the brand operated by House of Optimal Professional Development Training (FZCO), licensed in the UAE. FundingOptimal operates as a training brand providing access to demo accounts in a fully simulated trading environment only. The company is not a broker, does not provide real-market execution, does not hold client funds for investment purposes, and is not licensed as a financial brokerage.
FundingOptimal is committed to preventing money laundering (ML), terrorist financing (TF), and sanctions evasion. This policy outlines the main AML/CFT controls applied across onboarding, payments, simulated trading, payouts, and partner engagement.
Purpose & Scope
This Policy defines the principles and controls used to comply with UAE AML/CFT laws and international standards. It applies to all FundingOptimal operations, staff, contractors, partners, and all customers purchasing demo evaluation programs.
Legal & Regulatory Framework (UAE)
FundingOptimal complies with applicable UAE AML legislation, including:
Federal Decree-Law No. 20 of 2018
Cabinet Resolution No. 10 of 2019
Federal Law No. 7 of 2014 (Combating Terrorism Crimes)
UAE Penal Code & Cybercrime Law
United Nations Sanctions & FATF Recommendations
FundingOptimal is not regulated by the UAE Central Bank or the Securities and Commodities Authority (SCA).
Risk-Based Approach
Customers are assessed based on geography, payment method, behavior, device/IP data, and transaction patterns. Proportionate SDD, CDD, and EDD measures are applied and reviewed periodically or upon trigger events.
KYC & Customer Due Diligence
All clients must:
Complete identity verification using a valid government-issued ID.
Use payment methods matching the verified identity.
Declare the purpose of the relationship (simulated trading evaluation only).
KYC is performed through certified third-party providers. For higher-risk clients, Enhanced Due Diligence (EDD), including source-of-funds verification and additional checks, may be required.
Sanctions Screening & Restricted Jurisdictions
Customers and transactions are screened against the UN Consolidated Sanctions List and the UAE Local Terrorist List. Services are not provided to comprehensively sanctioned or prohibited jurisdictions. Any potential matches are immediately restricted and reviewed.
Transaction Monitoring & Red Flags
FundingOptimal applies automated and manual monitoring for:
Multi-account or shared device/IP usage
VPN or proxy abuse
Split payments and unusual volumes
Rapid payout attempts and excessive refunds
Mismatched payer information
Coordinated or abusive trading behavior
Suspicious activity is escalated to Compliance and accounts may be temporarily suspended during investigations.
Suspicious Activity Reporting (goAML)
All employees must immediately escalate suspicious activity to the designated Compliance Officer (MLRO). Where legally required, reports are submitted via the UAE goAML system. All reporting is strictly confidential and tipping-off is prohibited.
Record-Keeping & Training
KYC, transaction, investigation, STR, audit, and training records are retained for at least 5 years. All staff receive annual AML/CFT training, with enhanced training for risk-exposed roles.
Third-Party Providers
Only vetted payment service providers and certified KYC vendors with appropriate AML controls are used. Contracts include AML, data protection, and audit provisions.
Breaches, Sanctions & Enforcement
Violations of this Policy may result in internal disciplinary measures, account termination, reporting to authorities, and potential criminal liability under UAE law. UAE penalties for ML/TF offenses may include substantial fines and imprisonment.
Client Responsibility & No Legal Defense
House of Optimal Professional Development Training (FZCO), operating as FundingOptimal, does not provide legal defense, legal representation, or advocacy for any client in AML-related investigations or proceedings. Clients remain fully responsible for the legality and source of their funds. FundingOptimal will cooperate with competent authorities where legally required.
Data Protection
Personal data is processed in accordance with UAE law and FundingOptimals Privacy Policy using strict security and access-control measures.
Policy Review & Updates
This Policy is reviewed at least annually and updated upon any material legal, operational, or risk-related changes.