Last updated: April 2026

Introduction and Legal Basis

Yooshi Jewelry Retail Company O.P.C is committed to implementing the provisions of Law No. (106) of 2013 on Combating Money Laundering and Terrorism Financing, its Executive Regulations, and all related ministerial resolutions, including Ministerial Resolution No. (431) of 2016 regarding the trade in gold, precious metals, and gemstones, and Resolution No. (8) of 2025 concerning the Executive Regulations of the Committee for the Implementation of UN Security Council Resolutions.

This policy aims to establish a clear framework for due-diligence procedures, transaction monitoring, and suspicious-activity reporting, ensuring full compliance with national and international standards, particularly the recommendations of the Financial Action Task Force (FATF).

Appointment of the Compliance Officer

Mrs. Ayah Dashti has been appointed as the company’s Compliance Officer, responsible for supervising the implementation of legal and regulatory AML/CFT requirements.

Contact Details:

• Nationality: Kuwaiti
• Phone: +965 9787 7034
• Email: ayah@yooshijewelry.com
• Postal Address: P.O. Box 2943 Safat 13030, Kuwait

Customer Due Diligence (CDD)

The company must identify and verify the customer’s and ultimate beneficial owner’s identity before and during any business relationship, using reliable and independent documents or data, as follows:

1. Individual Customers:

• Kuwaiti Civil ID or a valid passport.
• Verification of the data and its match with the customer in person or via a trusted electronic method.
• Signing a declaration of identity and personal information.

2. Corporate Customers:

• Commercial license and registration certificate.
• Memorandum and Articles of Association.
• Names and IDs of authorized signatories.

3. Prohibitions:

• No transactions with anonymous, fictitious, or digital-only clients.
• No acceptance of cash or third-party payments from unknown sources.

Enhanced Due Diligence (EDD)

Enhanced measures apply to high-risk customers as identified in the risk assessment, including:

• Politically Exposed Persons (PEPs)
• Non-resident customers
• Customers with large or unusual transactions

Special Procedures:

• Obtain prior approval from the business owner before executing the transaction.
• Verify the source of funds and wealth, and confirm annual income level.
• Continuously monitor the relationship and document all observations.
• Increase transaction monitoring to ensure alignment with the customer profile.

Periodic Customer Review

• Low risk: Every 3 years
• Medium risk: Every 2 years
• High risk: Annually or upon any change in transaction pattern

High-Risk Countries

• The company shall not deal with clients or entities listed by the FATF on either the Grey List or Black List.
• The company shall also refrain from dealing with any client or entity appearing on the Kuwait Financial Intelligence Unit or other national/international sanctions lists.
• These lists are reviewed and updated periodically from official domestic and international sources.

Payment and Transaction Controls

• All payments are made through KNET or approved electronic payment gateways.
• Cash payments are strictly prohibited.
• No payments shall be accepted from unidentified or unrelated third parties.

Employee Requirements

• Employees must be familiar with Law 106/2013 and relevant Ministry of Commerce resolutions.
• All must attend annual AML/CFT training.
• Employees must have no prior criminal convictions involving dishonesty or breach of trust.

Training Program

• Mandatory annual training for all staff on AML/CFT policies and procedures.
• Specialized training for the Compliance Officer upon any legislative or regulatory update.

Duties of the Compliance Officer

• Oversee the implementation of the company’s AML/CFT policies and procedures.
• Periodically review and update the risk-assessment study.
• Prepare and submit suspicious-transaction reports to the Financial Intelligence Unit (FIU).
• Ensure compliance with national and international sanctions lists.
• Review purchases and verify their consistency with Know Your Customer (KYC), CDD, and EDD requirements.

External Audit

• An annual internal audit is conducted by an independent external party to verify the company’s compliance with AML/CFT policies and procedures.

Record Keeping

• All customer and transaction records are retained for at least five years from the transaction date.

Reporting to the Kuwait Financial Intelligence Unit

• Any suspicious transaction or attempted transaction must be reported immediately to the Kuwait FIU through official channels.

Sanctions Lists

• Screen all customers before initiating a business relationship to ensure they are not listed under any sanctions.
• Refrain from offering services if a match is found, and notify the Ministry of Foreign Affairs immediately.

Retention of Risk Assessment

• A written and updated risk assessment is kept on file and made available to the Ministry of Commerce and Industry upon request.

Electronic System for Contracting and Data Storage

• The company employs a secure electronic system for storing customer and transaction data, integrated with sanctions lists for automatic screening and compliance.