AML Policy - Credit Amanah

ANTI-MONEY LAUNDERING (AML) POLICY STATEMENT

Last Updated: Shawwal 1447 H | April 2026 CE

1. Introduction

Credit Amanah Limited (“we,” “us,” or “our”) is committed to the highest standards of anti-money laundering (AML), counter-terrorist financing (CTF), and anti-fraud compliance. As a Shariah-compliant trade finance and Islamic finance advisory firm, we recognise that our responsibility to prevent financial crime extends beyond mere legal obligation — it is a fundamental expression of our commitment to the Islamic principles of Amanah (trust), Adl (justice), and Ihsan (excellence in conduct) that are central to everything we do.

We recognise that the international trade finance and Islamic finance sectors carry inherent financial crime risks, and we are firmly committed to ensuring that our services are not used, directly or indirectly, for the purposes of money laundering, terrorist financing, fraud, sanctions evasion, or any other form of financial crime.

This AML Policy Statement sets out our public commitment to financial crime prevention and outlines the framework within which Credit Amanah Limited operates to ensure that all transactions and advisory engagements are legitimate, transparent, and fully compliant with applicable laws, regulations, and Islamic finance principles.

2. Legal and Regulatory Framework

Credit Amanah Limited conducts all its activities in full compliance with the following applicable laws, regulations, and international standards:

Proceeds of Crime Act 2002 (POCA) — the primary UK legislation governing money laundering offences and the obligation to report suspicions of money laundering
Terrorism Act 2000 — governing counter-terrorist financing obligations
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — setting out the due diligence and reporting obligations for businesses in the regulated sector
Sanctions and Anti-Money Laundering Act 2018 — governing the UK’s sanctions regime post-Brexit
Financial Services and Markets Act 2000 (FSMA) — as applicable to Credit Amanah Limited’s FCA Annex 1 authorisation application and ongoing regulatory obligations
FCA Financial Crime Guide (FCG) — the FCA’s guidance on financial crime prevention for regulated and applicant firms
Financial Action Task Force (FATF) Recommendations — the internationally recognised standards for AML and CTF compliance
FATF Guidance on Money Laundering and Terrorist Financing in the Islamic Finance Sector — specifically applicable to Credit Amanah Limited’s Islamic finance activities
Wolfsberg Group Principles — internationally recognised guidance for financial institutions on AML, KYC, and correspondent banking standards
UK Office of Financial Sanctions Implementation (OFSI) Guidelines — governing compliance with UK financial sanctions
United Nations Security Council Sanctions — applicable international sanctions regimes
AAOIFI Governance Standards — as a guiding framework for Shariah-compliant governance and ethical conduct across all our activities

Credit Amanah Limited monitors regulatory developments continuously and updates its internal policies and procedures accordingly to ensure ongoing compliance with all applicable laws, regulations, and standards.

3. Our Commitment

Credit Amanah Limited is firmly committed to:

Ensuring that our business is not used as a vehicle for money laundering, terrorist financing, fraud, or any other form of financial crime
Conducting thorough due diligence on all clients, transactions, and counterparties before providing any service
Upholding the Islamic principle of Amanah — trust and integrity — in all our dealings with clients, partners, issuing banks, and regulatory authorities
Maintaining robust internal controls, policies, and procedures designed to detect, prevent, and report financial crime
Cooperating fully with the FCA, law enforcement agencies, regulatory authorities, and financial intelligence units where required by law
Refusing to engage with any client, transaction, or counterparty that presents an unacceptable risk of financial crime or that is inconsistent with Islamic finance principles
Training and maintaining awareness among all relevant personnel on AML and CTF obligations and Islamic finance compliance requirements
Continuously reviewing and improving our AML framework in line with evolving regulatory requirements, FCA guidance, and Islamic finance industry best practice
Maintaining the highest standards of transparency, integrity, and professionalism in all our dealings — values that are both legally required and Islamically mandated

4. Know Your Customer (KYC) and Client Due Diligence (CDD)

Credit Amanah Limited applies a rigorous Know Your Customer (KYC) and Client Due Diligence (CDD) process to all clients prior to the provision of any service. Our due diligence process is designed to meet both UK regulatory requirements and Islamic finance governance standards and includes but is not limited to:

Standard Due Diligence — applied to all clients:

Verification of the client’s identity and legal existence
Collection and verification of Certificate of Incorporation and company registration documents
Identification and verification of principal shareholders and beneficial owners
Collection of passport copies and National Identity documents of principal shareholders and directors
Verification of the client’s registered address and principal place of business
Assessment of the nature and purpose of the proposed transaction including its Shariah compliance requirements
Review of the client’s bank statements and financial standing where applicable
Screening against international sanctions lists, politically exposed persons (PEP) databases, and adverse media sources
Assessment of the source of funds and source of wealth

Enhanced Due Diligence (EDD) — applied in higher risk situations:

Where a client, transaction, or jurisdiction presents a higher risk of money laundering or terrorist financing, Credit Amanah Limited will apply Enhanced Due Diligence measures. Circumstances that may trigger EDD include but are not limited to:

Clients or transactions involving high-risk jurisdictions as identified by FATF
Clients identified as Politically Exposed Persons (PEPs) or their close associates
Transactions that are unusually large, complex, or lack an apparent legitimate commercial or Shariah-compliant purpose
Clients or beneficiaries operating in sectors with elevated financial crime risk
Transactions involving jurisdictions where Islamic finance regulation is nascent or inconsistent
Any other circumstances that give rise to a higher risk assessment

Credit Amanah Limited reserves the right to request additional documentation or information at any stage of the client relationship where it considers this necessary for due diligence purposes, and to decline or terminate any engagement where satisfactory due diligence cannot be completed.

5. Shariah Compliance and AML Interaction

Credit Amanah Limited recognises that Islamic finance structures present unique AML and CTF considerations that require specific attention. In particular:

Murabahah transactions involve the purchase and resale of assets and require careful verification of the underlying asset and the legitimacy of the trade transaction to prevent the use of fictitious trade transactions for money laundering purposes
Musharakah and Diminishing Musharakah structures involve equity participation and require thorough verification of the source of funds contributed by all partners
Wakalah structures involve agency relationships that require careful assessment of the identity and legitimacy of all principals and agents involved
Kafalah guarantees require verification of the underlying obligation being guaranteed and the legitimacy of the guaranteed transaction

Credit Amanah Limited applies specific due diligence procedures to each Islamic finance instrument type to address these unique risks and ensure that all transactions are both Shariah-compliant and fully compliant with applicable AML and CTF regulations.

6. Sanctions Screening

Credit Amanah Limited screens all clients, beneficiaries, counterparties, and transactions against the following sanctions lists prior to and throughout the course of any engagement:

UK HM Treasury Consolidated Sanctions List
United Nations Security Council Sanctions List
European Union Sanctions List
Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List
Any other applicable sanctions regimes relevant to the jurisdiction of the client or transaction

Credit Amanah Limited will not engage with any individual, entity, or jurisdiction that is subject to applicable financial sanctions. Any potential sanctions match identified during screening will be escalated immediately and the transaction will be suspended pending investigation.

Credit Amanah Limited is particularly vigilant regarding sanctions compliance in connection with its Islamic finance activities, given that a significant proportion of its client base and transaction counterparties may be located in jurisdictions subject to heightened sanctions scrutiny.

7. Suspicious Activity Reporting

Credit Amanah Limited maintains robust internal procedures for the identification, escalation, and reporting of suspicious activity. Where we have knowledge or reasonable suspicion that a transaction may involve money laundering, terrorist financing, or any other financial crime, we are legally obliged to submit a Suspicious Activity Report (SAR) to the UK National Crime Agency (NCA) via the NCA’s online reporting system.

In accordance with applicable legislation, Credit Amanah Limited will not disclose to any client or third party that a SAR has been submitted or that an investigation is underway, as such disclosure may constitute a “tipping off” offence under the Proceeds of Crime Act 2002.

Credit Amanah Limited is equally vigilant regarding the misuse of Islamic finance structures and Shariah terminology to disguise or facilitate financial crime. Any transaction that appears to use Islamic finance structures for illegitimate purposes will be treated with the same level of suspicion and subjected to the same reporting obligations as any other suspicious transaction.

8. Record Keeping

Credit Amanah Limited maintains comprehensive records of all client due diligence documentation, transaction records, Shariah compliance assessments, and compliance activities in accordance with applicable legal requirements. Specifically:

KYC and client due diligence records are retained for a minimum of five years following the end of the business relationship, in accordance with the Money Laundering Regulations 2017
Transaction records are retained for a minimum of five years from the date of the transaction
Shariah compliance assessment records are retained for a minimum of six years in line with UK financial record-keeping requirements
FCA related records are retained in accordance with FCA record-keeping requirements as applicable to Credit Amanah Limited’s Annex 1 authorisation
SAR records and related documentation are retained in accordance with NCA guidance

All records are stored securely with access restricted to authorised personnel only.

9. Risk-Based Approach

Credit Amanah Limited adopts a risk-based approach to AML and CTF compliance, as required by the Money Laundering Regulations 2017 and in line with FCA guidance. This means that we assess the level of risk associated with each client, transaction, and business relationship and apply proportionate due diligence measures accordingly. Our risk assessments take into account the following factors:

The nature and purpose of the transaction including its Islamic finance structure where applicable
The jurisdiction of the client, beneficiary, and counterparty
The type of financial instrument or Islamic finance structure requested
The client’s business sector and ownership structure
The source of funds and source of wealth
Any PEP status or adverse media findings
The Shariah compliance requirements of the proposed transaction
Any prior suspicious activity or compliance concerns
The level of Islamic finance regulation in the client’s jurisdiction

Our risk assessments are reviewed and updated throughout the course of each client relationship and transaction to ensure that our due diligence remains proportionate, current, and consistent with both regulatory requirements and Islamic finance governance standards.

10. Prohibited Activities

Credit Amanah Limited strictly does not engage in, facilitate, or knowingly assist with any of the following:

Money laundering or the concealment of proceeds of crime
Terrorist financing or the financing of proliferation of weapons of mass destruction
Sanctions evasion or dealings with sanctioned individuals, entities, or jurisdictions
Fraud, misrepresentation, or the use of false documentation
“SBLC leasing,” “SBLC purchase,” “SBLC funding,” “monetisation of bank instruments,” or “investment against bank guarantee” — these are not legitimate trade finance or Islamic finance practices and are commonly associated with financial fraud
The misuse of Islamic finance structures or Shariah terminology to disguise, facilitate, or legitimise financial crime
Fictitious trade transactions or the use of trade finance instruments to launder funds
Any transaction that lacks a clear and legitimate commercial and Shariah-compliant purpose
Any activity that would constitute a financial crime under applicable UK or international law
Any activity that is inconsistent with the Islamic principles of Amanah, Adl, and Ihsan that govern our business

Any client found to be engaged in any of the above activities will have their engagement terminated immediately and the matter reported to the relevant authorities without prior notification to the client.

11. Regulatory Commitment and Future Authorisation

Credit Amanah Limited is committed to operating to the highest standards of regulatory compliance and financial crime prevention. As part of our long-term commitment to building a fully regulated and institutionally credible Islamic finance business, Credit Amanah Limited is actively working towards obtaining authorisation under Annex 1 of the Financial Services and Markets Act 2000 (FSMA) from the Financial Conduct Authority (FCA).

In anticipation of and preparation for FCA authorisation, Credit Amanah Limited:

Maintains a comprehensive AML and CTF compliance framework designed and structured to meet FCA standards and expectations
Conducts all its activities in accordance with the FCA’s Financial Crime Guide (FCG) and all applicable FCA guidance on AML and CTF compliance as a matter of best practice
Is committed to full transparency and cooperation with the FCA and all relevant regulatory authorities
Will update this AML Policy Statement upon receipt of FCA authorisation to reflect its full regulatory status and obligations as an FCA authorised firm

12. Internal Controls and Governance

Credit Amanah Limited maintains a framework of internal controls designed to prevent and detect financial crime whilst upholding Islamic finance governance standards. This framework includes:

Clear policies and procedures governing client onboarding, due diligence, Shariah compliance review, transaction monitoring, and suspicious activity reporting
Designated responsibility for AML and CTF compliance within the organisation
Designated Shariah compliance oversight to ensure that all activities remain consistent with Islamic finance principles and AAOIFI standards
Regular review and update of internal AML policies and procedures to reflect changes in applicable laws, regulations, FCA guidance, and Islamic finance industry best practice
Ongoing monitoring of client relationships and transactions throughout the course of each engagement
Maintenance of a culture of compliance, integrity, and zero tolerance for financial crime at all levels of the organisation — consistent with both regulatory requirements and Islamic values

13. Third Party Reliance

Where Credit Amanah Limited relies on third parties such as introducers, brokers, Islamic finance institutions, or business partners for the referral of clients, Credit Amanah Limited maintains ultimate responsibility for ensuring that appropriate due diligence has been conducted on all referred clients. Credit Amanah Limited does not outsource its AML obligations and retains full responsibility for compliance regardless of the source of the client introduction.

Where third party Shariah advisers are engaged in connection with a transaction, Credit Amanah Limited ensures that all such advisers are subject to appropriate confidentiality and compliance obligations.

14. Non-Compliance and Consequences

Credit Amanah Limited takes a zero-tolerance approach to financial crime. This position is not only a legal obligation but a fundamental reflection of our Islamic values and our commitment to conducting business with the highest standards of integrity and trust. Any client, counterparty, or third party found to have provided false information, misrepresented their identity or the nature of a transaction, or engaged in any form of financial crime in connection with our services will face the following consequences:

Immediate termination of the business relationship
Forfeiture of any fees paid where permitted by law
Reporting to the NCA, FCA, OFSI, or any other relevant regulatory or law enforcement authority
Potential civil or criminal legal action where appropriate

15. Contact and Reporting

If you have any concerns regarding potential financial crime, suspicious activity, or misuse of our services, or if you wish to verify the legitimacy of any communication or offer made in our name, please contact us immediately at:

Credit Amanah Limited 14/2E, Docklands Business Centre, 10-16 Tiller Road, London, E14 8PX, United Kingdom

Company Registration Number: 13612807 Email: [email protected] Website: www.creditamanah.com

Credit Amanah Limited is committed to responding to all compliance-related enquiries promptly and in accordance with our legal and Islamic ethical obligations.

16. Policy Review

This AML Policy Statement is reviewed and updated regularly to reflect changes in applicable laws, regulations, FCA guidance, and Islamic finance industry best practice. The most recent version of this policy will always be published on this page with an updated revision date. Upon receipt of FCA Annex 1 authorisation, this policy will be comprehensively updated to reflect Credit Amanah Limited’s full regulatory status and obligations as an FCA authorised firm.