This Anti-Money Laundering and Know Your Customer Policy ("AML/KYC Policy") sets out Noblelesse QFC LLC(Q)'s ("Noblelesse", "we", "us", "our") approach to preventing money laundering, terrorist financing, and other financial crimes on our Platform.
This Policy supports our compliance with applicable AML/CTF regulations, including Qatar Financial Centre Anti-Money Laundering and Counter-Terrorist Financing Rules (AML/CTF Rules) and international standards.
1. Purpose and scope
Our Commitment
Noblelesse is committed to preventing our Platform from being used for money laundering, terrorist financing, sanctions evasion, or other financial crimes.
This Policy covers:
- • Customer Due Diligence (CDD) requirements
- • Identity verification procedures
- • Ongoing monitoring obligations
- • Suspicious activity reporting
- • Record keeping standards
This Policy applies to:
- • All Platform users and transactions
- • Third-party service providers
- • Noblelesse staff and contractors
- • Business partners and intermediaries
2. Customer Due Diligence (CDD)
Standard CDD Requirements
We perform CDD on all customers before establishing a business relationship or conducting transactions above specified thresholds.
Identity Verification
- Government-issued photo ID (passport, national ID, or driver's license)
- Biometric verification where available
- Cross-referencing with reliable databases
- Face matching and liveness detection
Address Verification
- Recent utility bill, bank statement, or government correspondence
- Property ownership documents
- Tenancy agreements
- Documents must be dated within the last 3 months
Source of Funds/Wealth
- Employment details and salary certificates
- Business ownership documentation
- Bank statements showing fund sources
- Investment portfolios or inheritance documentation
Sanctions & PEP Screening
- Real-time screening against global sanctions lists
- Politically Exposed Person (PEP) checks
- Adverse media screening
- Ongoing monitoring and periodic re-screening
3. Enhanced Due Diligence (EDD)
When EDD is Required
Enhanced Due Diligence measures apply to higher-risk customers, transactions, and jurisdictions to ensure appropriate risk mitigation.
EDD Triggers:
- Politically Exposed Persons (PEPs) and their associates
- High-risk jurisdictions or sanctions-adjacent countries
- Large or unusual transaction patterns
- Complex ownership structures
- Adverse media or reputational concerns
Additional EDD Measures:
- Senior management approval for business relationship
- Enhanced source of wealth verification
- More frequent periodic reviews
- Enhanced transaction monitoring
- Additional documentary evidence requirements
4. Ongoing monitoring and periodic reviews
Transaction Monitoring
- • Real-time transaction screening
- • Pattern and anomaly detection
- • Threshold-based alerts
- • Cross-border transaction scrutiny
Periodic Reviews
- • Annual customer reviews (minimum)
- • More frequent for high-risk customers
- • Updated documentation collection
- • Risk rating reassessment
Continuous Screening
- • Daily sanctions list updates
- • PEP status monitoring
- • Adverse media alerts
- • Regulatory watch list checks
5. Suspicious activity reporting
Reporting Obligations
We have a legal obligation to report suspicious transactions to the Qatar Financial Intelligence Unit (FIU) and other relevant authorities as required by law.
Suspicious Activity Indicators:
- Unusual transaction patterns or amounts
- Reluctance to provide required documentation
- Inconsistent information or documentation
- Transactions with no apparent economic purpose
- Use of multiple payment methods or accounts
Our Response Process:
- Immediate escalation to compliance team
- Investigation and documentation
- Filing of Suspicious Transaction Reports (STRs)
- Account restriction or termination if necessary
- Cooperation with law enforcement
6. Record keeping and data retention
Retention Periods
- Customer records: 5 years after relationship ends
- Transaction records: 5 years after transaction completion
- STRs and investigations: 5 years minimum
- Training records: 5 years
Record Security
- • Encrypted storage and transmission
- • Access controls and audit trails
- • Regular backup and recovery testing
- • Secure disposal procedures
7. Staff training and awareness
Training Requirements
- • Initial AML/CTF training for all staff
- • Annual refresher training
- • Role-specific advanced training
- • Regular regulatory updates
- • Suspicious activity recognition
- • Escalation procedures
- • Confidentiality requirements
- • Competency assessments
8. Contact Details
Company Information
- Company Legal Name: Noblelesse LLC
- Registration No: QFC No. 01409
Contact Details
- Compliance: compliance@noblelesse.com
- Support: support@noblelesse.com
- Phone/WhatsApp: +974 5589 5603
Registered Office: Fintech Circle, QFC Tower 1, Floor 9, Doha, Qatar