Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy

The Company is dedicated to maintaining robust Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) standards. In accordance with applicable laws and regulatory requirements, financial institutions must collect, verify and retain sufficient information to properly identify every individual or entity opening an account.

Money laundering refers to the act of concealing the origin of funds obtained from unlawful activities — such as fraud, corruption, organised crime or terrorism — by converting them into assets or transactions that appear legitimate.

Stages of Money Laundering
Money laundering commonly occurs in three main phases:

1. Placement
   At this stage, illicit funds are introduced into the financial system. Criminals may:
   • deposit money into bank or payment accounts,
   • purchase negotiable instruments (cheques, transfers, prepaid products),
   • acquire high-value goods for later resale, or
   • use currency exchanges and similar institutions.
   To reduce suspicion, deposits are often split into smaller amounts and conducted over
   multiple transactions — a practice known as “smurfing.”

2. Layering
   The purpose of layering is to hide the origin of funds. This is achieved by moving money
   through numerous transactions, accounts or financial instruments. Repeated transfers,
   conversions and account changes make it difficult to trace the source of the funds.

3. Integration
   Finally, the funds are reintroduced into the economy and appear to be legitimate. They may
   be used to purchase services, investments, or assets.
   Company Commitment
   The Company follows strict AML principles and does not permit its services to be used for:
   • money laundering,
   • terrorist financing, or
   • any other criminal activity.
   Cash payments are neither accepted nor made. The Company reserves the right to suspend or
   refuse any transaction or account activity that it reasonably suspects to be unlawful.
   Company Procedures
   The Company takes reasonable steps to confirm it is dealing with genuine individuals or
   legitimate legal entities and operates in accordance with applicable laws and the regulations
   of Saint Vincent and the Grenadines and other relevant authorities.
   AML compliance is achieved through:
   • Know-Your-Customer (KYC) and due diligence procedures
   • Ongoing monitoring of client transactions
   • Record retention
   Know Your Customer (KYC) and Due Diligence
   Every client must complete an identity verification process before services are provided. The
   Company will only establish a business relationship once sufficient evidence of identity has
   been obtained.
   Enhanced due diligence may be applied to:
   • non-resident clients,
   • customers from high-risk jurisdictions, or
   • beneficial owners whose funds originate from higher-risk regions.
   Individual Clients
   During registration, each individual must provide:
   • full legal name
   • date of birth
   • country of residence
   • residential address
   To verify these details, clients must submit:
   Proof of Identity (one of the following):
   • valid passport
   • government-issued national ID card
   • driving licence with photograph
   • resident permit
   Proof of Address:
   • utility bill
   • bank statement
   • official government correspondence
   The document must show the client’s full name and residential address and be issued within
   the last 3 months.
   If documents are not in English, a notarised English translation may be requested.
   Corporate Clients
   If a company is publicly listed on a recognised exchange or is a wholly owned subsidiary of
   such a company, simplified verification may apply.
   For privately held companies, the following documentation is required:
   • Certificate of Incorporation (or equivalent)
   • Memorandum and Articles of Association
   • Registered address confirmation or certificate of good standing
   • Board resolution authorising account opening
   • Authorisation documents (if applicable)
   • Identification documents for directors
   • Identification documents for beneficial owners and authorised signatories
   Ongoing Monitoring
   The Company continuously reviews client transactions to detect unusual or suspicious
   behaviour.
   A transaction may be considered suspicious if it:
   • does not match the client’s expected activity, or
   • conflicts with the client’s known financial profile.
   Both automated monitoring systems and manual reviews are used to identify potential misuse
   of services.
   Record Retention
   The Company maintains records of:
   • identity verification documents
   • transaction histories
   • internal AML reports
   All records are retained for a minimum of seven (7) years after the business relationship
   ends.
   Deposits and Withdrawals
   To comply with AML/CTF requirements:
   • Third-party payments are prohibited.
   • Funds must originate from accounts or payment methods held in the same name as the
   trading account holder.
   • Withdrawals are returned only to the original funding source wherever possible.
   Withdrawals follow a First-In-First-Out (FIFO) principle.
   Example:
   If £100 is deposited via card and £1,000 profit is generated, the original £100 will be returned
   to the card and the remaining profit will be transferred to the client’s bank account in the
   same name.
   Initial withdrawals may require bank statement verification.
   Payments made under a different name than the registered account holder will not be
   accepted.
   Reporting and Enforcement
   Where the Company suspects that transactions may involve money laundering or criminal
   activity, it will:
   • investigate the activity,
   • report to the appropriate regulatory authority in Saint Vincent and the Grenadines
   where required by law, and
   • take appropriate action.
   The Company may, at its sole discretion:
   • delay transactions,
   • freeze an account temporarily, or
   • terminate the business relationship.