Terms and Conditions

This website (accord7.com) is maintained by Accord Consulting FZC. Throughout the site, the terms “we”, “us” and “our” refer to Accord Consulting FZC. Accord Consulting FZC offers this website, including all information, tools and services available from this site to you, the user, conditioned upon your acceptance of all terms, conditions, policies and notices stated here.
By visiting our site and/ or purchasing something from us, you engage in our “Service” and agree to be bound by the following terms and conditions (“Terms of Service”, “Terms”), including those additional terms and conditions and policies referenced herein and/or available by hyperlink. These Terms of Service apply to all users of the site, including without limitation users who are browsers, vendors, customers, merchants, and/ or contributors of content.
Please read these Terms of Service carefully before accessing or using our website. By accessing or using any part of the site, you agree to be bound by these Terms of Service. If you do not agree to all the terms and conditions of this agreement, then you may not access the website or use any services. If these Terms of Service are considered an offer, acceptance is expressly limited to these Terms of Service.
Any new features or tools which are added to the current store shall also be subject to the Terms of Service. You can review the most current version of the Terms of Service at any time on this page. We reserve the right to update, change or replace any part of these Terms of Service by posting updates and/or changes to our website. It is your responsibility to check this page periodically for changes. Your continued use of or access to the website following the posting of any changes constitutes acceptance of those changes.

  • United Arab of Emirates is our country of domicile and the governing law is the local law
  • Customers using the website who are Minor/under the age of 18 shall not register as a User of the website and shall not transact on or use the website
  • The Cardholder must retain a copy of transaction records and Merchant policies and rules
  • We will not trade with or provide any services to OFAC and sanctioned countries
  • Visa or MasterCard debit and credit cards in AED will be accepted for payment
  • The user is responsible for maintaining the confidentiality of his/her account

Security

We value your trust in providing us with your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security. What is guaranteed that the card data, is not stored, as Privacy complies with the Payment Card Industry Data Security Standards (PCI-DSS), as well as any requirements under the Network Rules.

Online store terms

By agreeing to these Terms of Service, you represent that you are at least the age of majority in your emirate, state or province of residence, or that you are the age of majority in your emirate, state or province of residence and you have given us your consent to allow any of your minor dependents to use this site. You may not use our products for any illegal or unauthorized purpose nor may you, in the use of the Service, violate any laws in your jurisdiction (including but not limited to copyright laws). You must not transmit any worms or viruses or any code of a destructive nature. A breach or violation of any of the Terms will result in an immediate termination of your Services.

General Conditions

We reserve the right to refuse service to anyone for any reason at any time.
You understand that your content (not including credit card information), may be transferred unencrypted and involve (a) transmissions over various networks; and (b) changes to conform and adapt to the technical requirements of connecting networks or devices. Credit card information is always encrypted during transfer over networks. You agree not to reproduce, duplicate, copy, sell, resell or exploit any portion of the Service, use of the Service, or access to the Service or any contact on the website through which the service is provided, without express written permission by us. The headings used in this agreement are included for convenience only and will not limit or otherwise affect these Terms.

Accuracy, completeness and timeliness of information

We are not responsible if information made available on this site is not accurate, complete or current. The material on this site is provided for general information only and should not be relied upon or used as the sole basis for making decisions without consulting primary, more accurate, more complete or more timely sources of information. Any reliance on the material on this site is at your own risk.
This site may contain certain historical information. Historical information, necessarily, is not current and is provided for your reference only. We reserve the right to modify the contents of this site at any time, but we have no obligation to update any information on our site. You agree that it is your responsibility to monitor changes to our site.

Refund/Cancellation policy

Orders on this website cannot be cancelled by the customer once submitted.
You can only give notice and ask us to not renew your business centre agreement.
If you want to cancel your recurring payment prior to the next due date, you can write to us at legal@accord7.com to end the agreement.
Refunds will be done only through the Original Mode of Payment.
Refunds will be processed or denied at the sole discretion of the team at Accord Consulting FZC

To request a refund, please contact us at legal@accord7.com.

Service Delivery Policy

Description of Service

Accord Consulting FZC provides services in accordance with the United Arab Emirates laws and regulations in force. You may use the Services for your business use or for internal business purposes in the organization that you represent or as an independent individual user. You may apply to the Services Request using any Internet browser. You are responsible for obtaining access to the Internet and the equipment necessary to use the Services.

Subscription to Beta Service

We may offer certain Services as closed or open beta services (“Beta Service” or “Beta Services”) for the purpose of testing and evaluation. You agree that we have the sole authority and discretion to determine the period of time for testing and evaluation of Beta Services. We will be the sole judge of the success of such testing and the decision, if any, to offer the Beta Services as commercial services. You will be under no obligation to acquire a subscription to use any paid Service as a result of your subscription to any Beta Service. We reserve the right to fully or discontinue, at any time and from time to time, temporarily or permanently, any of the Beta Services with or without notice to you. You agree that Accord Consulting FZC will not be liable to you or to any third party for any harm related to, arising out of, or caused by the modification, suspension or discontinuance of the Beta Services for any reason.

Modification of Terms of Service

We may modify the Terms upon notice to you at any time through a service announcement or by sending an email to your primary email address. If we make significant changes to the Terms that affect your rights, you will be provided with at least 30 days’ advance notice of the changes by email to your primary email address. You may terminate your use of the Services by providing Accord Consulting FZC notice by email within 30 days of being notified of the availability of the modified Terms if the Terms are modified in a manner that substantially affects your rights in connection with the use of the Services. In the event of such termination, you will be entitled to prorated refund of the unused portion of any prepaid fees. Your continued use of the Service after the effective date of any change to the Terms will be deemed to be your agreement to the modified Terms.

User Sign-Up Obligations

You need to provide all required information in order to access or use the Services. If you represent an organization and wish to use the Services for corporate internal use, we recommend that you, and all other users from your organization, provide your corporate contact information. In particular, we recommend that you use your corporate email address. You agree to (a) provide true, accurate, current and complete information about yourself; and (b) maintain and promptly update the information provided to keep it true, accurate, current, and complete. If you provide any information that is untrue, inaccurate, outdated, or incomplete, or if Accord Consulting FZC has reasonable grounds to suspect that such information is untrue, inaccurate, outdated, or incomplete, we may terminate your account and refuse current or future use of any or all of the Services.

Personal Information and Privacy

The personal information you provide to Accord Consulting FZC through the Service is governed by Privacy Policy. Your choice to use the Service indicates your acceptance of the terms of the Privacy Policy. You are responsible for maintaining the confidentiality of your financial data and other sensitive information. You are responsible for all activities that occur on your behalf, and you agree to inform us immediately of any unauthorized use of your personal data occurred by email to legal@accord7.com or by calling us on any of the numbers listed on +1 (720) 3162 777. We are not responsible for any loss or damage to you or to any third party incurred as a result of any unauthorized access and/or use of your data, or otherwise.

Communications

The Service may include certain communications from Accord Consulting FZC, such as service announcements, administrative messages and newsletters. You understand that these communications shall be considered as part of using the Services. As part of our policy to provide you total privacy, we also provide you with the option of opting out of receiving newsletters from us. However, you will not be able to opt out from receiving service announcements and administrative messages.

Complaints

If we receive a complaint from any person/company/authorities against you with respect to your activities as part of the use of the Services, we will forward the complaint to the primary email address of your user account. You must respond to the complainant directly within 10 days of receiving the complaint forwarded by us. If you do not respond to the complainant within 10 days from the date of our email to you, we may disclose your name and contact information to the complainant for enabling the complainant to take legal action against you. You understand that your failure to respond to the forwarded complaint within the 10 days time limit will be construed as your consent to the disclosure of your name and contact information to the complainant.

Fees and Payments

The Services are available under a 1-year subscription plan unless otherwise mentioned. Payments can be made by bank transfers From time to time, we may change the price of a Service or charge for use of Services that are currently available free of charge. Any increase in charges will not apply until the expiry of your current billing cycle.

Disclaimer of Warranties

You expressly understand and agree that the use of the services is at your sole risk. The services are provided on an as-is-and-as-available basis. Accord Consulting FZC shall expressly disclaim all warranties of any kind, whether express or implied, including, but not limited to, the implied warranties of merchantability and fitness for a particular purpose. Accord Consulting FZC shall make no warranty that the services will be uninterrupted, timely, secure, or error-free. Use of any material downloaded or obtained through the use of the services shall be at your own discretion and risk and you will be solely responsible for any damage to your computer system, mobile telephone, wireless device or data that results from the use of the services or the download of any such material. No advice or information, whether written or oral, obtained by you from Accord Consulting FZC, its employees or representatives shall create any warranty not expressly stated in the terms.

Limitation of Liability

You agree that Accord Consulting FZC shall, in no event, be liable for any consequential, incidental, indirect, special, punitive, or other loss or damage whatsoever or for loss of business profits, business interruption, computer failure, loss of business information, or other loss arising out of or caused by your use of or inability to use the service, even if a group of companies has been advised of the possibility of such damage. In no event shall a group of companies shall entire liability to you in respect of any service, whether direct or indirect, exceed the fees paid by you towards such service.

Indemnification

You agree to indemnify and hold harmless Accord Consulting FZC, its officers, directors, employees, suppliers, and affiliates, from and against any losses, damages, fines and expenses (including attorney’s fees and costs) arising out of or relating to any claims that you have used the Services in violation of another party’s rights, in violation of any law, in violations of any provisions of the Terms, or any other claim related to your use of the Services, except where such use is authorized by Accord Consulting FZC.

Dispute resolution

Any controversy or claim arising out of or relating to the Terms shall be settled by the Courts of Dubai in accordance with the laws of the United Arab Emirates.

Suspension and Termination

We may suspend your user account or temporarily disable access to whole or part of any Service in the event of any suspected illegal activity, extended periods of inactivity or requests by law enforcement or other government agencies. Objections to suspension or disabling of user accounts should be made to legal@accord7.com within 30 days of being notified about the suspension. We may terminate a suspended or disabled user account after 30 days. We will also terminate your user account at your request.

In addition, we reserve the right to terminate your user account and deny the Services upon reasonable belief that you have violated the Terms and to terminate your access to any Beta Service in case of unexpected technical issues or discontinuation of the Beta Service. You have the right to terminate your user account if Accord Consulting FZC breaches its obligations under these Terms and in such event, you will be entitled to prorated refund of any prepaid fees. Termination of the user account will include denial of access to all Services, deletion of information in your user account, such as your email address and password and deletion of all data in your user account.

End of Service Delivery Policy

If you have any questions or concerns regarding this Agreement, please contact us at legal@accord7.com

Complaint and Dispute Resolution Policy

Our aim is to give you the highest quality service at all times. However, if you have a complaint, you are invited to let us know as soon as possible.

Introduction

This Complaint Handling and Dispute Resolution Policy aims to provide a structured approach to resolving complaints and disputes that is fair and equitable, and that will lead to solutions that are acceptable to all parties.

Complaint

A complaint is an expression of dissatisfaction, made to the association, related to the association’s activities, operations, policies, employees, volunteers or the complaints handling and dispute resolution process itself, where a response or resolution is explicitly or implicitly expected.

Complainant

A party that makes a complaint or files a formal charge, for example, a member of the public, association members, employees, volunteers, suppliers and contractors.

Dispute

Means an unresolved complaint. In other words, it is a matter that has been dealt with as a complaint under this Policy, but where the complainant is still not satisfied with the outcome.

Purpose of Policy

The purpose of this Policy is to outline a set of procedures to effectively and fairly respond to complaints and disputes in a professional and timely manner.

This Policy provides a process for handling and resolution of complaints and disputes between Accord Consulting FZC and its members, employees, speakers and contractors relating to the company’s activities and operations.

The objectives of this Policy are to establish a process to:

  • Record, action and resolve complaints and disputes;
  • Provide complainants, dissatisfied with a decision, a referral to an external process for resolution of their complaint;
  • Review and monitor the company’s performance against the procedures outlined in this Policy.

Overview

The complaint and dispute resolution process at Accord Consulting FZC operates in two stages:

  • An internal dispute resolution process under which the company will use its best efforts to resolve a complaint or dispute to the mutual satisfaction of the company and the complainant;
  • Failing resolution is an external dispute resolution process under which the complainant, dissatisfied with the company’s decision, can refer the complaint to the company’s external dispute resolution officer/mediator or other external mediation body/service for resolution.

Effective and Efficient Complaint and Dispute Resolution Process

The company will adopt an effective and efficient complaint and dispute resolution process that:

  • Is communicated to the company’s members, employees, speakers and contractors;
  • Has stated time limits for each stage of the process;
  • Is reviewed annually;
  • Is documented

Committee and Management Commitment

The Executive Director, Client Service and Business Development Department of Accord Consulting FZC are committed to the implementation of this Policy, as evidenced by:

  • Ensuring the company’s members, employees, speakers and contractors are aware of the association’s Policy;
  • Implementing management systems and reporting procedures to ensure timely and effective complaints handling and dispute resolution, and monitoring.

Complaint Handling and Dispute Resolution Coordinator

The Executive Director, Client Service and Business Development Department of Accord Consulting FZC are committed to the implementation of this Policy, as evidenced by:
All complaints should be directed to the Complaint Handling and Dispute Resolution Coordinator, The Executive Director, Client Service and Business Development Department.

Communication

This Policy is displayed in a public area on the company’s website (accord7.com).
Periodically (at least annually), the Complaint Handling and Dispute Resolution Coordinator must remind the abovementioned stakeholders about this Policy.

Procedures for Receiving Complaints

If a complaint is submitted to Accord Consulting FZC, the company:

  • Must, if the complaint is verbal, either resolve it “on the spot”, or if that is not done, request the complainant to submit a written complaint to the Complaint Handling and Disputes Resolution Coordinator;
  • Must, if the complaint is in writing, acknowledge in writing receipt of the complaint as soon as practicable and in any event within 14 days from receipt, and enclose a copy of this Policy for the complainant’s information;
  • Must ensure that the complaint receives proper consideration resulting in a determination by the Complaint Handling and Dispute Resolution Coordinator as the person designated by the association as appropriate to handle complaints;
  • Must act in good faith in dealing with and resolving the complaint;
  • Must investigate the complaint including by seeking all relevant information from the complainant and obtaining all relevant information from the company’s employees/Speakers/suppliers.
  • May at its discretion give any appropriate remedy to the complainant, including any of the following:
    Information and explanation regarding the circumstances giving rise to the complaint;
    An apology and compensation for loss incurred by the complainant.
  • Must communicate to the complainant in relation to the complaint as soon as practicable and in any event not more than 45 days after receipt by the company of the complaint:
    The determination in relation to the complaint;
    The remedies (if any) available to the complainant;
    Information regarding any further avenue for complaint.

When a Complaint will be Treated as Resolved by the Company

Written Complaints – where the complainant has been notified in writing of a decision and no response has been received, the complaint will be treated as resolved by the company.

Verbal Complaints – will be treated as resolved by the company where the complaint has been resolved to the complainant’s satisfaction “on the spot” or where the complainant has been notified of a decision about a complaint and no response has been received.

Confidentiality

The complaint handling and dispute resolution process will keep the complainant’s identity private to guard against inconvenience or discrimination.

Sensitivity

The company will treat each complaint separately and on its merits.

Complaints and Disputes Register

The Complaint Handling and Dispute Resolution Coordinator must ensure that a Complaints and Disputes Register is established, maintained and kept up-to-date. The Register will be comprised of a copy of each Complaint Report.
At a minimum, the Register must include the following information about every complaint that is received:

  • Date complaint is made;
  • Nature of complaint/issue;
  • Action is taken to investigate the complaint;
  • Date resolved;
  • How resolved.

The Complaint and Dispute Resolution Coordinator must periodically review the Register to check that complaints are being handled appropriately, including in accordance with this Policy, and within the required timeframes.
The Complaints Register must also be tabled annually at Association Executive Committee meetings.

Timetable for Complaints Handling

The company will attempt to resolve complaints and notify the complainant as soon as possible.

Annual Review of this Policy

The Complaint Handling and Dispute Resolution Coordinator is responsible for ensuring this policy is adhered to.
Periodically (at least annually), the Complaint Handling and Dispute Resolution Coordinator will review this Policy and report the outcome of this review to the Executive Committee.

If an Individual asks about the Complaint Handling and Dispute Resolution Procedures

If an individual asks for information about the company’s complaints handling and dispute resolution methods, employees must refer the request to the Complaint Handling and Dispute Resolution Coordinator as soon as possible. The Complaint Handling and Dispute Resolution Coordinator must ensure the individual is provided with a copy of this Policy within seven business days of the request.

If an Individual asks for Assistance in Formulating or Lodging Complaint

If an individual asks for assistance in the formulation and lodgment of his/her complaint, employees, members, and speakers must refer the request to the Complaint Handling and Dispute Resolution Coordinator as soon as possible. The Complaint Handling and Dispute Resolution Coordinator must ensure reasonable assistance is provided to the individual.

Where a Complaint is not Resolved to an Individual’s Satisfaction

For each complaint that cannot be resolved to the complainant’s satisfaction within the abovementioned 45 days, the Complaint Handling and Dispute Resolution Coordinator must inform the complainant in writing that they have the option to pursue resolution of their complaint with the company’s external Dispute Resolution Officer/Mediator and provide details about how to access them.

External Resolution of Disputes

Failing resolution of a complaint through the company’s dispute company resolution process as outlined in this Policy, complainants can refer their complaint to an external mediation body/service for resolution.

AML/CFT Policy

AML/CFT Policy / Federal Decree-law No. (20) of 2018

ON ANTI-MONEY LAUNDERING AND COMBATING THE FINANCING OF TERRORISM AND FINANCING OF ILLEGAL ORGANISATIONS

 

Policy Statement

(a) Accord Consulting is committed to providing its world-leading corporate services in a responsible and legally compliant fashion. The Company recognises its legal responsibilities and impresses upon its staff and management the importance of vigilance and compliance aimed toward the prevention of money laundering and the financing of terrorism in accordance with applicable law and FATF standards;

(b) The Company operates a risk-sensitive approach to managing money laundering and terrorism financing risks associated with its business, both when beginning new-client-relationships and on an ongoing basis;

(c) Accord Consulting trains its employees on the Company’s legal obligations, giving them an adequate understanding of the policies and procedures in place to report and guard effectively against AML/CFT risk;

(d) Responsibility rests with all staff, led by the Legal and Compliance Department and senior management. AML/CFT duties are allocated appropriately between management, Accord Consulting compliance, and other staff;

(e) Accord Consulting conducts documentary and research-based due diligence on all customers, ascertaining and verifying the (i) identity of ultimate beneficial owners (UBOs) and (ii) Clients’ use of services provided by the Company in accordance with the risk-based approach set out by the procedures below. This takes place at the beginning of engagements and on an ongoing basis as required by law and Accord Consulting’policies.

 

Application of a risk-based approach, and identification and assessment of risks

Accord Consulting will take reasonable steps to identify and assess its money laundering and financing of terrorism risks and apply a risk-based approach with regard to the following areas:

(a) establishment of internal policies, procedures and controls in order to prevent activities related to money laundering and the financing of terrorism;

(b) identification and verification of the identity of UBOs;

(c) the extent of customer due diligence measures for existing customers, that is, enhanced, normal or simplified customer due diligence measures;

(d) the extent of customer due diligence measures for new customers, that is, enhanced, normal or simplified customer due diligence measures;

(e) determining the extent of enhanced customer due diligence measures to be performed for politically exposed persons and politically exposed persons who have stepped down, including their immediate family members and close associates, except in cases where the business relationship or transactions with Accord Consulting present a high risk for money laundering or the financing of terrorism;

(f) understanding the risks of money laundering and the financing of terrorism in the countries or territories that a third party that Accord Consulting wishes to rely on operates in;

(g) the extent of ongoing monitoring.

Accord Consulting will take the following steps in order to apply a risk-based approach:

(a) Identify the money laundering and financing of terrorism risks that are relevant to it;

(b) Assess the risks identified according to different categories;

(c) Develop different extent of controls to mitigate the assessed risks;

(d) Monitor the implementation of these controls and enhance them if necessary; and

(e) Document the risk assessment, keep it up to date and be able to provide it to ACRA if required.

Accord Consulting will identify and assess the relevant money laundering and financing of terrorism financing risks that it potentially faces and will implement appropriate extent of controls to manage and mitigate the assessed risks. This is subject to any variables in risks that Accord Consulting may encounter.

 

Development of controls to mitigate money laundering and financing of terrorism risks

In developing controls to mitigate its risks, Accord Consulting will perform different extents of customer due diligence measures and perform different extents of ongoing monitoring. Accord Consulting will have controls:

(a) for the identification and scrutiny of complex or unusually large transactions, unusual patterns of transactions which have no apparent economic or visible lawful purpose and any other activity which Accord Consulting regards as particularly likely by its nature to be related to money laundering or the financing of terrorism;

(b) that specifies the taking of additional measures, where appropriate, to prevent the development of new products and new business practices, including new delivery mechanisms, for money laundering and the financing of terrorism, and the use of new or developing technologies, for both new and pre-existing products, for money laundering and the financing of terrorism, paying special attention to those that favour anonymity;

(c) that determine whether a customer, beneficial owner or agent is a politically exposed person during the performance of customer due diligence measures.

 

Monitoring effectiveness and enhancement of controls

Accord Consulting may consider one or more of the following indicators or other relevant indicators, in monitoring whether its controls are effective and deciding whether enhancement is needed:

(a) a sudden unaccounted increase in business from an existing customer, for example, the same customer requesting incorporation of many companies;

(b) uncharacteristic transactions which are not in keeping with the customer’s known business activities and profile;

(c) unaccounted peaks of activity at particular locations or at particular times;

(d) unaccountable or atypical types of customer transactions.

In monitoring the effectiveness of its controls, Accord Consulting will consider whether the controls are able to identify any transactions or activities that are unusual or suspicious to Accord Consulting.

 

Performance of customer due diligence measures

Accord Consulting will perform customer due diligence on its customers, UBOs and agents by performing the following measures before it enters into a business relationship with potential clients:

(a) identifying the customer and agent and verifying their identities by asking for reliable and independent documents, data or information;

(b) identifying and verifying the identity of any UBO using reliable and independent documents, data or information;

(c) obtaining information on the purpose and intended nature of any business relationship.

Accord Consulting will apply a risk-based approach as described in paragraph 1.2 to determine the extent of customer due diligence measures that it will perform, that is, simplified, normal or enhanced customer due diligence.

In performing customer due diligence measures, Accord Consulting will take measures to determine whether a customer, beneficial owner or agent is a politically exposed person or a close associate.

Accord Consulting applies a risk-based approach as described in paragraph 1.2 to determine the extent of enhanced customer due diligence measures to be performed for politically exposed persons, and politically exposed persons who have stepped down, including their immediate family members and close associates. Where Accord Consulting is of the view that the intended nature of the business relationship or transaction presents a high risk for money laundering or the financing of terrorism, Accord Consulting’senior management will consider whether a Suspicious Transaction Report would need to be made.

If Accord Consulting has established a business relationship with a politically exposed person, the Company will perform enhanced ongoing monitoring over the course of the business relationship. Where Accord Consulting is of the view that the nature of the business relationship or transaction now presents an increased risk of money laundering or the financing of terrorism, Accord Consulting’senior management will consider whether a Suspicious Transaction Report would need to be made.

Accord Consulting will perform enhanced customer due diligence measures and enhanced ongoing monitoring in other situations where the risk of money laundering and the financing of terrorism is high.

In performing customer due diligence measures, Accord Consulting may require its customers and agents to provide their particulars using a customer acceptance form and require the provision of relevant documents and information for verification purposes.

If Accord Consulting is unable to perform or complete customer due diligence measures, it will:

(a) not carry out any transaction with or for the customer;

(b) not establish a business relationship with the customer;

(c) terminate any existing business relationship with the customer;

(d) consider whether it is required to file a suspicious transaction report under section 39(1) of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act; and section 8 or 10 of the Terrorism (Suppression of Financing) Act.

 

Filing a suspicious transaction report

Accord Consulting will ensure that its staff and employees are trained on its internal reporting procedures and made aware of the persons to whom they have to report, in the event that they detect suspicious activities or transactions concerning money laundering or the financing of terrorism and a suspicious transaction report may have to be filed.

A suspicious transaction report may be made with the Suspicious Transaction Reporting Office via SONAR.

 

Performance of ongoing monitoring of business relationships

Accord Consulting will conduct ongoing monitoring of a business relationship with a customer. “Ongoing monitoring” means:

(a) scrutiny of transactions undertaken throughout the course of the relationship (including, where necessary, the source of funds) to ensure that the transactions are consistent with its knowledge of the customer, and its business and risk profile;

(b) keeping the documents, data or information obtained for the purpose of applying customer due diligence measures up to date.

Accord Consulting will apply a risk-based approach as described in paragraph 1.2 to decide the extent of ongoing monitoring, for example, whether a higher or lower frequency of ongoing monitoring is required, and the timing of the ongoing monitoring.

When Accord Consulting is required to perform enhanced ongoing monitoring, it is required to increase the frequency of ongoing monitoring over the course of the business relationship concerned over and above the frequency used for customers subject to the standard and simplified due diligence measures.

For customers who are considered high risk where enhanced due diligence was performed during onboarding will have to monitor and due diligence documents obtained on an annual basis, while those on the medium or low-risk tier would be monitored and due diligence documents would be obtained on a 2-yearly basis.

 

Record-keeping

Accord Consulting will keep the following records for the entire duration of its business relationship with a customer, and for at least 5 years from the date it ends its business relationship with a customer:

(a) a copy of each of the information and evidence of the customer’s and agent’s identity (including that of any UBO in relation to the customer). These include:

(i) copies of all documents used in establishing and verifying the customer’s, UBO’s and agent’s identity;

(ii) the agent’s authority to enter into a business relationship on behalf of a customer;

(iii) information on the purpose and intended nature of the business relationship;

(iv) written records of the basis of Accord Consulting’determination that a customer falls into the categories for which inquiry into the existence of a beneficial owner is not required;

(v) Accord Consulting’risk assessment where the Company performs simplified customer due diligence measures and the nature of the simplified customer due diligence measures;

(vi) written records of Accord Consulting’findings with regard to a politically exposed person;

(vii) written records of Accord Consulting’findings with regard to other high-risk customers or transactions;

(viii) written records of Accord Consulting’measures taken in relation to the screening and training of its employees;

(ix) supporting records.

These records should be sufficient to permit the reconstruction of individual transactions.

Accord Consulting has the discretion to keep these records in different formats.

 

Screening of employees and training

Accord Consulting will:

(a) implement screening procedures for the hiring of fit and proper persons as its employees;

(b) ensure that its employees are trained on the laws for the prevention of money laundering and the financing of terrorism;

(c) ensure that its employees are trained on prevailing methods, and trends in, money laundering and the financing of terrorism;

(d) ensure that its employees are trained on its internal policies, procedures and controls for the prevention of money laundering and financing of terrorism, including the roles and responsibilities of officers and employees of Accord Consulting with regard to the implementation of these internal policies, procedures and controls;

(e) ensure that all records of screening and training are documented.

Accord Consulting may consider the following factors when conducting screening of persons who it potentially wishes to hire as employees:

(a) whether the person has been convicted in UAE, of any offence involving fraud or dishonesty punishable with imprisonment for 3 months or more;

(b) whether the person is an undischarged bankrupt in UAE;

(c) whether, if the person has been previously registered as a Filing Agent or qualified individual, his conduct and compliance history as a registered Filing Agent or a registered qualified individual had been satisfactory.

 

Audit function, compliance management and internal communication

Accord Consulting will implement and maintain an audit function that is independent, and able to assess regularly the effectiveness of the internal policies, procedures and controls for the prevention of money laundering and the financing of terrorism.

Accord Consulting will develop compliance management arrangements to continually review and update the internal policies, procedures and controls for the prevention of money laundering and financing of terrorism and appoint an employee or officer in a management position as the compliance officer in relation to anti-money laundering and countering the financing of terrorism.

Accord Consulting will develop internal communication procedures so that its employees, officers and registered qualified individuals are aware of its internal policies, procedures and controls for the prevention of money laundering and financing of terrorism, and their roles in the prevention of money laundering and the financing of terrorism.