Anti-Money Laundering (AML) & Counter-Terrorism Financing (CTF) Policy
Effective Date: May 16th, 2024
We are committed to complying with international best practices.
1. Purpose
To prevent our services from being used for money laundering or terrorist financing.
2. Risk-Based Approach
We assess the risk of each client based on:
• Jurisdiction
• Nature of services requested
• Payment methods and volume
3. Customer Due Diligence
We collect and verify:
• Legal name and contact details
• ID verification for individuals
• Incorporation documents and ownership structure for companies
4. Record-Keeping
All client identification and transaction records are retained for at least 5 years after termination of services.
5. Reporting
We will report any suspicious activity to the proper authorities in UAE
6. Know Your Customer (KYC) Policy
To ensure transparency and mitigate risk, we conduct KYC checks on clients whose payments exceed $10,000 CAD/month.
KYC Measures:
• Individuals: Valid government-issued ID and proof of address
• Businesses: Certificate of incorporation, beneficial ownership, and business license (if applicable)
• High-risk clients: Enhanced Due Diligence (EDD) may apply
Failure to provide documentation may delay or prevent service initiation.
7. Sanctions & Restricted Parties Policy
We do not conduct business with:
• Individuals or entities listed on the official Sanctions List, OFAC, EU, or UN sanctions lists
• Clients operating in high-risk jurisdictions (e.g., North Korea, Iran)
We regularly screen clients and partners using automated tools.
9. Acceptable Use Policy (AUP)
Clients may not use our services to:
• Promote illegal products (e.g., drugs, counterfeit goods)
• Spread hate, violence, or harassment
• Mislead consumers through deceptive advertising
• Violate third-party intellectual property
Violation of this policy may result in suspension or termination of services without notice.
10. Code of Ethics & Business Conduct
We commit to:
• Transparency in pricing and communication
• Honesty in campaign performance and metrics
• Respect for client confidentiality
• No manipulation of search engines or advertising platforms in breach of their terms
Employees and partners must act in accordance with these principles.
11. Client Onboarding Policy
We onboard clients through a structured process:
• Initial consultation
• Identity and business verification (if required)
• Scope of work agreement
• Acceptance of Terms and Conditions and Privacy Policy
Clients may be declined if deemed high-risk or non-compliant with our AUP or AML obligations.
12. Data Protection & Security Policy
We implement robust security measures to protect client data:
• HTTPS encryption across all platforms
• Role-based access control for internal systems
• Data backups and disaster recovery plans
• Two-factor authentication for sensitive portals
Personal data is only retained as long as necessary for the purpose collected and in compliance with United Arab Emirates privacy law.
13. Third-Party Services & Subprocessors List
We may use third-party services for:
• Hosting (e.g., AWS, Google Cloud)
• Analytics (e.g., Google Analytics, SEMrush)
• Payment processing (e.g., Stripe, PayPal)
• Email marketing (e.g., Mailchimp)
14. Complaints Handling Policy
Clients may submit complaints to info@draken.dev Complaints are acknowledged within 3 business days and fully resolved within 14 business days unless otherwise specified.
Escalation: Unresolved complaints may be referred to management or legal counsel as necessary.
15. Legal Notice (Impressum)
Draken Dev Marketing Solutions FZE LLC
Registered Address: BLA-337, AMC-Boulevard Building, Boulevard A, Ajman Media City
Email: info@draken.dev
16. Service Level Agreement (SLA) (optional but recommended)
We aim to deliver:
• Campaign setup within 3–5 business days of onboarding
• Weekly reporting every Friday by 5 PM EST
• Client response time within 1 business day
Uptime Guarantee for dashboard (if provided): 99.5% monthly
17. Accessibility Statement
We are committed to making our website and services accessible in accordance with international regulations.
If you encounter barriers while accessing our content, contact us at info@draken.dev so we can assist you.