Legal

AML & Counter-Terrorist Financing Policy

Innovation Rise Solutions LLC Last updated: 14 June 2026

Innovation Rise Solutions LLC ("we", "us", "our"), a software studio registered at Sharjah Publishing City, Sharjah, United Arab Emirates under 2113078, is committed to preventing money laundering, terrorist financing and any use of our business as a channel for illicit funds.

We have zero tolerance for money laundering (ML) and the financing of terrorism (TF). This Policy sets out how we identify, manage and mitigate ML/TF risk in our operations and client relationships.

1. Purpose and commitment

We are committed to conducting business with integrity, only with legitimate clients and for legitimate purposes. We will not knowingly enter into, facilitate or maintain any relationship that involves the proceeds of crime, sanctions evasion, or the financing of terrorism.

2. Scope

This Policy applies to all directors, employees, contractors and partners of Innovation Rise Solutions LLC, and to all client engagements, payments and supplier relationships. It applies with particular care to higher-risk activities, including work in the prop trading and prop betting verticals and any engagement involving payment-processor integration or Merchant-of-Record flows.

3. Legal and regulatory framework

We operate in line with applicable UAE legislation, including Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and its implementing regulations, and we have regard to international standards such as the FATF Recommendations. Where a client engagement is subject to additional or foreign AML obligations, those obligations apply in addition to this Policy.

4. What we are guarding against

  • Money laundering, processing or disguising the proceeds of crime to make them appear legitimate.
  • Terrorist financing, providing or collecting funds to be used for terrorism.
  • Sanctions evasion, dealing with sanctioned persons, entities or jurisdictions.
  • Fraud and predicate offences, engagements designed to facilitate illegal activity.

5. Risk-based approach

We assess ML/TF risk before and during each engagement, considering: the client's identity and ownership, the nature of their business, the jurisdictions involved, the type and source of funds, and the purpose of the engagement. The level of due diligence we apply is proportionate to the assessed risk.

6. Client due diligence (KYC)

Before onboarding a client, and on a risk basis thereafter, we may require:

  • the legal name, registration details and address of the client entity;
  • identification of the individuals we deal with and their authority to act;
  • identification of beneficial owners (typically those owning or controlling 25% or more);
  • understanding of the client's business and the purpose of the engagement; and
  • confirmation of the source of funds where relevant.

We reserve the right to refuse or discontinue an engagement if satisfactory information is not provided.

7. Enhanced due diligence (EDD)

We apply enhanced measures to higher-risk situations, including:

  • clients in regulated or higher-risk sectors (e.g. trading, betting/gaming, crypto, payments);
  • politically exposed persons (PEPs) and their close associates;
  • clients connected to high-risk or sanctioned jurisdictions; and
  • unusually complex ownership structures or unclear sources of funds.

EDD may include senior-management approval, additional verification and closer ongoing monitoring.

8. Sanctions and watchlist screening

We do not deal with persons or entities subject to applicable sanctions. On a risk basis, we screen clients and counterparties against relevant sanctions and terrorist lists (including UAE Local Terrorist Lists and UN Security Council lists, and other applicable regimes). A positive match results in suspension of the relationship and, where required, a report to the competent authority.

9. Payments

  • All payments are made upfront through traceable, legitimate banking or regulated payment channels.
  • We do not accept anonymous payments, or payments from third parties unconnected to the engagement, without satisfactory explanation and verification.
  • We do not accept large or unusual cash payments.
  • Payments that are inconsistent with the engagement, structured to avoid thresholds, or otherwise suspicious will be queried, held or refused.

10. Ongoing monitoring

We monitor client relationships and transactions on a risk-sensitive basis for activity that is unusual, inconsistent with our knowledge of the client, or lacking an apparent lawful purpose, and we keep client information up to date.

11. Suspicious activity reporting

Where any director, employee or contractor knows or suspects ML/TF, they must report it internally to the Compliance Officer / MLRO without delay. The MLRO assesses each report and, where required by law, files a Suspicious Activity / Transaction Report with the UAE Financial Intelligence Unit (FIU) through the official channel (e.g. the goAML system). Internal reporting must not be skipped.

12. Tipping-off

Employees and contractors must not disclose to a client or any third party that a suspicion has been raised or a report made, where doing so could prejudice an investigation. Tipping-off may be a criminal offence.

13. Prohibited and refused business

We will decline or terminate any engagement that:

  • involves suspected proceeds of crime or terrorist financing;
  • involves sanctioned persons, entities or jurisdictions;
  • has an unclear, unlawful or evasive purpose; or
  • where the client refuses to provide required due-diligence information.

14. Record keeping

We retain client due-diligence records, engagement documentation and transaction records for at least the period required by applicable law (in the UAE, generally five years after the end of the relationship or transaction), and make them available to competent authorities on lawful request.

15. Compliance Officer / MLRO

Responsibility for this Policy sits with our designated Compliance Officer / Money Laundering Reporting Officer (MLRO):

Name: Jonathan Villanueva Contact: [email protected]

The MLRO oversees AML/CFT measures, receives internal reports, liaises with authorities and maintains this Policy.

16. Training and awareness

Relevant personnel receive AML/CFT awareness appropriate to their role, so they can recognise and escalate red flags.

17. Review

This Policy is reviewed at least annually and updated to reflect changes in law, regulation, risk and our business.

18. Contact

Innovation Rise Solutions LLC Sharjah Publishing City, Sharjah, United Arab Emirates Email: [email protected] WhatsApp: +971 56 236 4355 Web: https://innovationrisesolutions.com