Legal documents » Anti-Fraud Policy

Anti-Fraud Policy


The Board of CFP TECHNOLOGY FZCO (“FZCO”) has a responsibility to satisfy themselves that its operations are being properly run and have appropriate corporate governance. One of the ways in which this is achieved
is to set policies and maintain them on a regular basis. It is the responsibility of each person to ensure that they comply with CFP Technology’s latest approved policies.

It is a fundamental principle of FZCO that it will protect itself against fraud. FZCO, recognizing the importance of safeguarding the assets of both CFP Technology and our clients, acknowledges that the values of quality, honesty, and trustworthiness lie at the heart of our products and reputation. This anti-fraud policy sets out FZCO ‘s approach to preventing fraud.

Definition of Fraud

FZCO defines fraud as:

  • Dishonestly obtaining the money or assets (including data, information, or services) of FZCO or its clients; or
  • Misusing one’s position within FZCO via unlawful or improper acts with the intention of causing a financial loss to FZCO, its clients, staff or suppliers.

CFP Technology’s Anti-Fraud Approach

FZCO’s anti-fraud approach consists of the following key elements:


It is the duty of all employees to protect the business by acting with propriety in the use of FZCO‘s resources and funds and to communicate concerns where potential fraud risks (including control weaknesses that may lead to fraud) are identified.

FZCO has adopted a risk-based approach to fraud prevention and management which reflects the particular risk factors affecting the firm, some examples of which are:

  • segregation of duties;
  • quality control checking;
  • External consultancy file checks;
  • External consultancy control checks;
  • review of accounts for suspicious transactions;
  • review of inactive or spasmodically operated accounts.

These are devised to prevent, deter and detect fraud. All staff and senior managers are tasked with the maintenance of existing procedures and, where required, the implementation of new cost effective procedures to prevent,
deter and detect fraud.

Response to fraud

FZCO will take firm and vigorous action against any individual or group perpetrating, or attempting to perpetrate, fraud against FZCO, its clients, staff or suppliers. Recovery of any losses and costs incurred will also be sought.
Any fraudulent activity by employees may lead to dismissal and prosecution.

FZCO will assist the local police authorities and other appropriate authorities in the investigation and prosecution of those suspected of fraud against FZCO, its clients or its suppliers. FZCO reserves the right to engage third parties to undertake investigations on its behalf.

Role of Employees

All employees are encouraged to be vigilant and to immediately report any suspicion of fraud to their manager, the local Compliance Officer, FZCO’s Head of Compliance, or another Senior Manager. This report can be made either orally or in a written statement.

Staff is expected to act with integrity and in accordance with acceptable behaviors at all times. There is a detailed whistle-blowing procedure that sets out staff’s detailed responsibilities together with advice and guidance in
dealing with suspected fraud which should be brought to all staff members’ attention.

Annual Review

This policy must be reviewed by FZCO’s Head of Compliance every year to ensure its alignment to appropriate legal and regulatory requirements as well as best practice compliance standards and its continued relevance to FZCO
the firm’s current and future operations. Every 12 months the Board must issue an up-to-date policy for FZCO. Any interim change to this policy must be proposed to the Board and, if agreed upon, requires the written approval of
members of the Board.


Dubai International Financial Centre
Operating Law No. 7 of 2018 – s.64


Internet Access Management (IAM) policy

Telecommunications and Digital Government Regulatory Authority (TDRA) implements the Internet Access Management (IAM) policy in the UAE, in coordination with National Media Council and Etisalat and Du, the licensed internet service providers in the UAE. Under this policy, online content that is used for impersonation, fraud and phishing and/or invades privacy can be reported to Etisalat and Du to be taken down.

Please, read the information about CFPS Fees and Limits on the Fees page.