INTRODUCTION



This Policy must be read in combination with Company's KYC Policy, ensuring full compliance with the applicable laws related to Money Laundering and Terrorism Financing activities.


The term "money laundering" is used to describe all procedures that aim to conceal the criminal origins of funds and in doing so make the origin of funds appear as of a legitimate source.


The Forex Market involves a high risk in relation to clients willing to use services for illegal purposes, which can be attributed to money laundering. Although, it does not constitute as a crime for the Company if such cases occur without the Company's knowledge of illegal assets, property, transactions and etc., the Company must ensure and do everything in its competence to avoid the transactions/ relationships involving any illegal, criminal or terrorist involvement or elements. Therefore, the Company closely and seriously has reviewed the anti-money laundering (hereinafter referred to as "AML") as well as relevant practices to it and has developed its internal AML Policy in order to avoid and prevent any money laundering, illegal or criminal activities. Through that, the Company will ensure that employees are not involved in money laundering and terrorism financing.



1. POLICY STATEMENT



The policy of the Company - the Company is taking security arrangements and has developed policies and procedures that promote high ethical and professional standards and prevent the Company from being used, intentionally or unintentionally, by criminal elements.


The directors, officers and staff of the Company shall at all times make every effort to maintain the highest standards of ethics, unity and discretion in the Company's management and administration so as to ensure that the Company creates and maintains a positive reputation.


The directors, officers and staff shall at all times act in such a manner as to maintain the reputation of Saint Vincent and the Grenadines as a major international financial center and to impede the use of the jurisdiction for illegal, criminal and terrorist purposes.



2. CUSTOMER DUE DILIGENCE



Effective Customer Due Diligence measures are essential to the management of money laundering and terrorist financing risk. Customer Due Diligence means identifying the customer and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with customer and on an ongoing basis. The customer identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.


The Company required to get all necessary information in order to identify each new customer and intended nature of the business relationship. The extent and nature of the information depends on the type of applicant (personal, corporate, etc.) and the expected size of the account.


In case, when an account has been opened, but problems of verification arise and cannot be resolved, the Company can close the account and return the money to the source from which it was received. While the transfer of an opening balance from an account in the customer's name in another organization subject to the same KYC standard will be considered, the Company follow its own KYC procedures. The Company can consider the possibility that the previous account manager may have asked for the account to be removed because of a concern about dubious activities.


As no single form of identification can be fully guaranteed as genuine, or representing correct identity, the identification process will need to be cumulative, and no single document or source of data must therefore be used to verify both name and permanent address. The company will take all measures to establish the identity of its clients.


Due Diligence


As part of its obligation to exercise due diligence in customer identification, the Company must confirm that the identity information which it holds for its customers remains fully updated with all necessary identification and information throughout the business relationship. The Company reviews and monitors on a regular basis the validity and adequacy of customer identification information in its possession. The Company has determined identification information and confirmation documents for Individual and Corporate customers.


Individual customers


The identity will be established to the Company's satisfaction by reference to official identity papers or such other evidence as may be appropriate under the circumstances. Information on identity will include, without limitation: full name, date of birth, nationality, complete residential address.


Names should be verified by reference obtained from a reputable source that bears a photograph, such as:

• Current valid full passport
• Government issued photo identification card

Identification documents must be valid at the time of the opening.

In addition to the customer's name verification, the current permanent address should be verified by obtaining any one of the following documents in certified document's form:

• Copy of a recent (no older than 3 months) utility bilil
• Bank statement
• Local tax authority bill
• Credit card monthly statement

Corporate customers


Where the applicant company is listed on a recognized or approved stock exchange or where there is independent evidence to show that the applicant is a wholly owned subsidiary or subsidiary under the control of such a company, no further steps to verify identity over and above the usual commercial checks and due diligence will normally be required.


Accounts for Corporate Customers:

• Company searches and other commercial enquiries to ensure that the applicant has not been or is not in the process of being dissolved, struck off, wound up or terminated.
• If changes to company structure occur or ownership occurs subsequent to opening of an account with the company, further checks should be made.
• Identity verification should aim to identify:
• the company,
• the directors,
• all persons duly authorized to operate the account,
• in case of private companies - the major beneficial shareholders,
• the company's business profile in terms of nat ure and scale of activities.

Where the applicant is an unquoted company, it will be subject to a procedure aimed to identify it, confirm its existence, good standing and authority of persons acting on its behalf. Documentation required for such purposes may change depending on each particular jurisdiction and will typically include:

1. Certificate of incorporation/certificate of trade or the equivalent, evidencing the company is indeed incorporated in a particular jurisdiction under the respective legislation;
2. Certificate of Incumbency or an equivalent document, listing current directors of the company;
3. Statutes, Memorandum and Articles of Association or equivalent documents confirming the authority of the respective officers of the company to legally bind it and the manner in which this may be done;
4. Extract from the Commercial Register of the country of incorporation may also be used to confirm the aforementioned information, if such information is provided in the extract.

Additional documents required:

• Where appropriate a search of the file at the Companies' Registry
• Identity of individuals who are connected with the company

In addition to identification information, it is necessary to collect and record information covering the following:

1. Source of wealth (activity, which generated the net worth)
2. Source of funds to be invested
3. References or other documentation (reputation information where available)
4. Independent background checks through a screening system

Notwithstanding the above and taking into account the degree of risk, if it becomes apparent at any time during the business relationship that the Company lacks sufficient or reliable evidence (data) and information on the identity and financial profile of an existing customer, the Company will immediately take all necessary actions using the identification procedures and measures to provide due diligence, in order to collect the missing data and information as quickly as possible and in order to determine the identity and create a comprehensive financial profile of the customer.


Furthermore, the Company monitors the adequacy of the information held and identity and economic portrait of its customers when and where one of the following events occurrences: conduct of a suspicious transaction that appears to be unusual and/or significant compared to the usual type of trade and economic profile of the customer.


A significant change in the situation and legal status of the customer such as:

• Change of corporate name and/or trade name;
• Change of registered shareholders and/or actual beneficiaries;
• Change of directors/secretary;
• Change of registered office;
• Change of trustees;
• Change of main trading partners and/or significant new business;
• A significant change in the operating rules of the customer's account, such as:
• Change of persons authorized to handle its account;
• Request for opening a new account in order to provide new investment services and/or financial instruments.

Where the customer refuses or fails to provide the Company with the required documents and information for identification and creation of a financial portrait, before entering into the business relationship, or during the execution of an individual transaction without adequate justification, the Company will not proceed in a contractual relationship or will not execute the transaction. If during the business relationship the customer refuses or fails to submit all required documents and information, within reasonable time, the Company has the right to terminate the business relationship and close the accounts of the customer.



3. PERSONNEL



AML Compliance Officer


The Company shall appoint a qualified compliance Officer who will be fully responsible for the Company's Anti-Money Laundering program and report to the Board of Directors of the Company about any breaches of the internal AMLpolicy and procedures and of the regulations and standards of good practice.


AML Compliance Officer's responsibilities include:

1. Ensuring the Company's compliance with the requirements of the Regulations;
2. Establishing and maintaining internal AML program;
3. Training employees to recognize suspicious transactions;
4. Receiving and investigating internal suspicious activity and t ransaction reports from staff;
5. Ensuring that proper AML records are kept;
6. Obtaining and updating international findings concerning countries with inadequate AML systems, laws or measures.

Employees


All Company employees, managers and directors must be aware of this policy. Employees, managers and directors who are engaged in AML related duties must be suitably vetted. This includes a criminal check done at the time of employment and monitoring during employment. Any violation of this policy or an AML program must be reported in confidence to the AML Compliance Officer, unless the violation implicates the AML Compliance Officer, in which case the employee must report the violation to the Chief Executive Officer.


Employees who work in areas that are susceptible to money laundering or financing terrorism schemes must be trained in how to comply with this policy or the AML program. This includes knowing how to be alert to money laundering and terrorism financing risks and what to do once the risks are identified.