These policies (AML policies) relate to your use of the "Smart Savings Application/ website" available at the link: (www.smartsavings.sa).

Smart Savings platform owned by the Smart Savings Company for Financial Technology, which operates in the field of technology and provides electronic solutions to keep up with the digital transformation in the Kingdom of Saudi Arabia, which was established in accordance with the regulations in force in the Kingdom of Saudi Arabia, and its address: 2752, Street No. 412, Al-Malqa District, 13524, Riyadh, The Kingdom of Saudi Arabia (referred to herein as the “Smart Savings Platform” and using first-person pronoun).

Smart Savings platform specializes in providing all services related to the distribution of investment funds and real estate investment funds. The platform is also licensed by the Capital Market Authority to distribute investment funds and real estate investment funds issued in the Kingdom of Saudi Arabia in accordance with the regulations and laws regulated by the authority.

Smart Savings Platform operates acts as an intermediary between investors and owners of investment funds and real estate investment funds, and it allows investors who want to invest their money in investment funds or real estate investment funds to access all available funds through them and enable users to access offers made by investment funds and provide all information related the funds and make investments electronically so that the investor has specific ownership in the investment units; for an investor to choose which of them is suitable for their investment purposes. Smart Savings platform will in no way be liable for any loss or damage arising from any breach or violation of the regulations of the Capital Market Authority and applicable laws and regulations.

The platform presents the investment opportunity by adhering to the Capital Market law and the instructions for authorizing the experience of financial technology. The platform lists investment funds / real estate investment funds in the form of investment opportunities for investors to participate in it directly. The directors of the proposed funds are also responsible for any damage or loss to the customer.

You agree to be bound by any amendments to those policies and agree that we are not obliged to notify you of these changes. You also acknowledge that it is your responsibility to review these policies regularly for any modifications. Continuing use of our services after any modifications or changes to those policies means that you agree to these changes.

Purpose

Smart Savings company owned the platform has an obligation to implement anti-money laundering and terrorist financing requirements in order to achieve the highest standards of (AML) and Know Your Customer (KYC) to alleviate the risk of potential facilitation of financial crimes in order to the fully protect of credibility and integrity of the financial market for platform users.

The platform's staff are fully committed to adhering to the standards outlined in the anti- money laundering and terrorist financing International Guidelines.

Anti-money laundering policy rules are a set of procedures to eliminate money laundering, illegal activities, terrorist financing , or other criminal activity.

AML Policy does not include implemented KYC measures.

KYC: done through online financial institutions due to its importance in identifying and better understanding the client to manage potential risks if they exist.

Smart Savings platform take all necessary measures in case there is any suspicious activity and investor unusual behavior through sending that to the competent authority to investigate the matter.

As part of Smart Savings platform obligation to avoid the potential risk related to anti- money laundering and terrorist financing, The platform may request additional information in regards of customer’s\user’s account activities e.g., Source of Funds/Source of Wealth (SOF/SOW) or any other document we find essential.

Data obtained is being carefully handled, and all the records regarding users’ personal information are stored confidentially and according to Saudi Arabia personal data protection laws.

Definitions

Smart saving platform: Smart saving platform: Smart Savings Platform is owned by Smart Savings Company for Financial Technology; it is licensed by the Capital Market Authority to distribute investment funds and real estate investment funds in the Kingdom of Saudi Arabia that operates as a client/investor and between funds. We also refer to it in this policy as "(platform/system/application/service providers)".

Account: mean personal account created by the CustomerUser in order to benefit from platform’s services and invest their money in available funds.

CustomerUser: means the actual beneficiary from platform’s services, who may be any one purchases investments units in the available funds through our platform.

Investments funds: The Fund is an investment program aimed at providing investment opportunities and involving investors.

Funds: means Assets or property regardless their value or type, material or immaterial, tangible or intangible, movable or immovable, instruments, and documents in any form, including electronic or digital systems or bank credits, in which ownership or interest indicates, including but not limited to all types of cheques, transfers, shares, securities, bonds, bills of credit, and letters of credit.

Money Laundering: means conduct any action or try to commit it for the purpose of concealing or disguising the illicit origin of the property other than the legislation or a decree in order to be legal.

Terrorist financing: means funding terrorism operations, terrorists and terrorist organization.

Reporting: means reporting by platform informing the Investigation Unit for any suspected transaction, in the pre mention case The platform obligate to send the report which is include proven the doubts until the Investigation Unit do which is suitable regarding this matter related to the investor .

precautionary attachment: Temporary prohibition of transferring, exchanging, disposing of, moving, seizing or temporarily seizing funds and proceeds based on an order issued by a court or competent authority.

Money-laundering and financing-of-terrorism cases:

The platform considers any of the following actions, it will be regarded as money laundering and terrorist financing in the event of being performed by the customer/user, including but not limited to:

• The customer/user transfers funds to the portfolio of his personal account on the platform, with the platform knowing later that those funds arose from or participated in criminal activity, and his investment was for the purpose of concealing its illegal source.

• If any customer/user deliberately prevents, conceals or disguises the nature or source of funds and fails to provide the platform with sufficient evidence, with the aim of concealing that these funds are arising from or participating in criminal activity.

• If the customer/user participated in committing any of the acts constituting money laundering and forming terrorist groups or aiding or abetting them.

Our obligation as a platform to combat money laundering and terrorist financing is the following:

• The platform shall consider the nature of the activity, its organizational structure, and customers' operations and types when developing money laundering and the terrorist financing policies and procedures to combat either and to ensure that all taken procedures were adequate and appropriate to comply with the rules stipulated by the CMA on the rules against money laundering and the terrorist financing.

• The platform shall consider following the regulations and policies stipulated in the agreements ratified by Saudi Arabia government, when developing money laundering and terrorist financing policy and reporting any suspected processes according to the rules stipulated in those ratified agreements.

• We will designate a responsible who is aware of all the requirements for these policies when they are drafted and who will be required to revise them regularly due to his sufficient awareness of the regulatory and legal requirements related to these rules.

• The company shall designate a responsible to supervise on these policies related to the rules of combating money laundering and terrorist financing and shall collaborate with the Financial Investigation Unit and the competent authority to assurance from the proper application.

• The platform is committed to provide complete and full awareness to its employees and officials with sufficient and complete knowledge to understand these rules to prevent any money laundering and terrorist financing policy process in addition to with all training to keep them up with all procedures to prevent any suspended process and securing financial market integrity.

• The platform is committed to following all the applicable policies stipulated in Kingdom of Saudi Arabia to accept the Customer, deal with them, and take all due and continuous care regarding their transactions carried out in order to combat any transactions related to money laundering and terrorist financing, each according to the customers’ type and their transactions on the platform.

• The platform is committed to reviewing and supervise each investor is transaction, ascertaining the correctness of the information obtained from the responsible authority by verifying the investor’s identity before accepting them.

• In the case of accepting a customer from a country that does not apply the Anti- Money Laundering and Terrorist Financing Rules, we are obliged to scrutinize its transactions and be considered a high-risk customer.

• The platform is committed to maintaining all records of customer data, information, and documents obtained, as well as records of their transactions and any documents specific to that.

• The platform is committed to maintaining and updating these records to ascertain customer’s identity and to the extent which their transactions relate to the risks of money laundering and terrorist financing to be prevented and keep updating maintaining these records monthly/annually for at least ten years to submit them upon request of the competent authorities.

Customer acceptance guidelines:

• The platform shall require before activation of Customers’ accounts to fill out the "Know the Customer" form, which is prepared by the platform to obtain the full customers data and the reality of his financial situation and its investment objectives, in order to avoid opening fake or unreal accounts to persons who informed to be prohibited from dealing in the financial market by the General Authority the Financial Market, including but not limited to such following date:

  • In case he is a person (Saudi):

    - ID/family register

    - Address

    - Work location

  • In case he is a person (Expatriate):

    - Acc/passport

    - Address

    - Work location

  After we obtain the aforementioned documents relating to each customer's verification through the responsible entity for verifying the customer's data to determine whether if he real beneficiary and controller, according to the rules stipulated in the Anti-Money Laundering and Terrorist Financing rules.

• The platform shall regularly develop the Customer Acceptance Form in order to determine the client types whose acceptance may cause high risks related to money laundering and terrorist financing, and therefore we will follow the comprehensive and detailed procedures regarding continuous care taken towards those customers.

• The platform shall ensure that the customer is not included in the terrorism lists issued by the United Nations Committee established according to Security Council resolution num 1267 (1999), 1267 Committee, and subsequent resolutions.

• in case the customer is listed or may be included in the terrorist lists, the platform shall be immediately obliged to inform the Financial Intelligence Unit and keep his money reserved until the issuance of instructions by the competent authority, which is a collaborator with the financial Intelligence Unit.

Highly risk customers\users standards related to money laundering and terrorist financing:

• The platform shall have standards, whether this customer is a high-risk one or not; these standards are including but not limited to: -customers’ information and background.
  -customers’ business (especially political persons, if any) and to what extent related to money laundering and terrorist financing
  -Obtaining a report on the reasons for having an account and its purpose.
  -customer’s workplace, particularly if his place of business was designated by the Financial Action Group, which is aware that standards relating to money-laundering and the terrorist financing regulations are not applied adequately.
  -lack of clarity regarding the ownership structure of the funds that customers will invest in the platform.
  -In the event of payment, If the sum that the customer provided to the platform to deposit in his account is withdrawn from a third party that is unrelated to customer/user.
  -in case we receive any financial entity rejection to deal with that customer/user.
  -in case the customer/user creates another account other than his own.
  -in the event that any transactions are odd or inconsistent with his prior transactions
  - If the customer/s/user’s transaction involved larger sums of money than his prior transaction, which called for doubt.
  -in case we don’t have sufficient information about customer/user or assure from our doubts.

• The platform shall faithfully and effectively uphold our standards in all customer/user transactions to guarantee that the source of the customer's wealth is unrelated to money laundering or the funding of terrorism.

• Our standards obligations are different from customer to other depend on their works, transactions and sequencing related to it.

• The platform shall provide customers\users with risk determinants according to their respective activities and their geographic location, without neglecting stating any other risks.

• The platform shall designate someone to be in charge of determining which customers\users are high-risk or not in order to identify any suspicious or unusual transaction in a timely manner.

• If The platform found that the due information was not taken about either customer when created their account, we shall suspend it before doing any suspended transaction and taking the proper action regarding that.

The competent authority responsible for platform customers\users identification:

• The process of verifying the identity of customers\users on behalf of the platform requires that they be either a commercial bank or financial institution that practices securities activity.

• The platform is required to have the solvency and ability of the authority whether it is a commercial bank or a financial institution to conduct customers\users identification to the same degree with respect to their own customers\users.

• The platform requires the responsible one for verifying the identity to make all customers\users whether it is a commercial bank or a financial institution, to provide him at any time with copies of the documents and information obtained from customers\users regarding verifying their identity, by concluding an agreement in which the responsible one, whether It was a commercial bank or a financial institution to authorize the application at any time to personally review and review the documents related to verifying the identity of customers\users and to follow the procedures to be taken with respect to each customers\users.

• The application is committed to make sure that the responsible one for verifying the identity of customers on its behalf, whether it is a commercial bank or a financial institution, is licensed and subject to supervision and monitoring by the Saudi Arabia government's competent authority, and that responsible party is responsible whose job it is to keep customer records in accordance with the FATF's guidelines against money laundering and the terrorist financing, and is committed to providing the platform with it at any time it needs these records.

The required procedures related to investment funds and real estate investment funds:

• The platform shall ensure that the investment funds or real estate investment funds in which the customer\user will invest are licensed by the Saudi CMA and subjected to the competent supervision entity.

• The application shall ensure that the investment funds or real estate investment funds operate according to the FATF's guidelines related to money laundering and the terrorist financing rules.

Our obligations in the case of suspicious transactions:

• The responsible one is responsible for discovering suspend transactions, and in case found it, He shall immediately inform the financial investigation unit of any complex, huge, unnatural activity, operation, or transaction that is suspected to be related to money laundering and the terrorist financing

• in the aforementioned case, the platform shall provide all data and information about customer\user and his operations within 10 days from the date of reporting to the financial investigation unit.

• Among these data, which the platform shall provide to the financial Investigation Unit upon submitting the report, the statements of account of the customer\user, copies of all account opening documents, i.e. data related to the nature of operations and documents supporting justifications for suspicion.

• The platform entrusts the responsible one to discover a suspend transactions, found any suspend transactions, his responsibility to inform financial investigation unit and provide it with a proven documents demonstrating that this transaction related to money laundering and the terrorist financing, considering that has ability to do that.

• The platform obliges this responsible party to follow up with the financial investigation unit and collaborate with the competent authority in case needed any documents during their investigation in any transaction related to money laundering and the terrorist financing.

Our obligation is to refrain from alerting customers\users to their transactions we suspect:

• The platform, its employees, and the responsible one for reporting refrain from alerting customer\user about their transactions are related to money laundering and terrorist financing and about all sending matters to the financial investigation unit related to suspended transactions.

• The platform, its employees, and the responsible one for reporting any operations related to money laundering and terrorist financing are required to refrain from disclosing information in the event that we have informed the financial investigation unit about any suspended transactions.

• The platform, its employees, and the responsible one for reporting any operations related to money laundering and terrorist financing are obligated to provide the financial investigation unit with any needed documents during their investigations and not disclose to customer\user about anything related to their transactions which may be related to money laundering and the terrorist financing.