AML 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 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 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 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 is paid 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.