Earnflow's Anti-Money Laundering and Counter-Financing of Terrorism framework.
Last updated: 22 April 2026
Earnflow Technologies Ltd. ("Earnflow") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) compliance. This policy applies to all Earnflow employees, contractors, directors, and users of the Platform, and is designed to meet the requirements of:
Earnflow applies a risk-based approach to AML/CFT, allocating compliance resources proportionate to the level of risk identified. All users are assigned a risk classification at onboarding and re-assessed periodically or upon triggering events.
| Risk Level | Criteria | Due Diligence |
|---|---|---|
| Low | Verified individual, low-value transactions, established corridor | Standard CDD — ID + proof of address |
| Medium | New user, moderate transaction volumes, or first-time corridor | Standard CDD + source of funds declaration |
| High | PEP, high-value transactions (>$10,000/month), complex ownership, or adverse media | Enhanced Due Diligence (EDD) — senior management approval required |
| Prohibited | Sanctioned individual or entity, FATF high-risk jurisdiction, or confirmed fraud | Account blocked — no services provided |
All users must complete Customer Due Diligence before accessing payment services. Standard CDD requires:
Enhanced Due Diligence (EDD) is applied to Politically Exposed Persons (PEPs), high-risk users, and users from FATF-identified high-risk jurisdictions. EDD requires additional documentation including source of wealth, source of funds, and senior management sign-off.
Earnflow screens all users and transactions against the following sanctions lists in real time:
| List | Authority |
|---|---|
| Specially Designated Nationals (SDN) | OFAC (US Treasury) |
| Consolidated List | UN Security Council |
| Financial Sanctions List | HM Treasury (UK) |
| Consolidated Sanctions List | European Union |
| Local Terrorist List | UAE Cabinet Resolution No. 83 of 2023 |
| DFSA Sanctions Register | Dubai Financial Services Authority |
Any potential match triggers an immediate account freeze pending review by our Money Laundering Reporting Officer (MLRO). Confirmed matches result in permanent account closure and mandatory reporting to the UAE Financial Intelligence Unit (FIU).
Earnflow operates automated transaction monitoring to detect suspicious patterns, including but not limited to:
Suspicious activity is escalated to the MLRO for review. Where warranted, a Suspicious Activity Report (SAR) is filed with the UAE FIU via the goAML platform.
| Threshold | Amount | Action |
|---|---|---|
| Single transaction | USD 10,000+ | Enhanced review + source of funds required |
| Monthly aggregate | USD 25,000+ | EDD review + MLRO notification |
| Suspicious activity | Any amount | SAR filing with UAE FIU |
| Sanctions match | Any amount | Immediate freeze + mandatory report |
Earnflow has appointed a designated Money Laundering Reporting Officer (MLRO) responsible for overseeing AML/CFT compliance, reviewing escalated cases, filing SARs, and maintaining the AML programme. The MLRO reports directly to the Board of Directors.
Earnflow retains all KYC documentation, transaction records, and compliance files for a minimum of five (5) years from the date of account closure or the completion of the transaction, in accordance with DIFC AML/CFT regulations. SAR records and related investigation files are retained for a minimum of ten (10) years.
All Earnflow employees and contractors with access to customer data or payment processing systems receive mandatory AML/CFT training at onboarding and annually thereafter. Training covers recognition of suspicious activity, reporting obligations, sanctions screening procedures, and the consequences of non-compliance.
By using the Platform, you agree to: