1. AML policy goal
This document was written to ensure that all AML requirements have been met.
2. AML related knowledge of the Company
The SM and/or CO of the Company have experience and knowledge in AML-related matters. Responsible personnel regularly visit AML- and other related- workshops and webinars to stay up to date. The CO's file about the latter is kept in Company and optionally also of SM or any other Senior Executive.
3. The meaning of the AML policy
The Company has made it a priority to ban and effectively deter money laundering as well as any activity that aids money laundering or any other illegal financial activity.
The SM, and eventually the CO, are responsible for putting the policy into action. For the above implementation of the present Manual, the CO specifies the AML based procedures.
4. Specification of the term “Client”
In the context of financial brokerage services, a client or prospective client is a legal entity or physical person who has entered into a service agreement with the company.
As a result, the background information of the aforementioned organization or individual is attributed to the legal system for AML risk assessment.
5. Client Acceptance Policy (CAP)
Since the risk of money laundering varies depending on the characteristics of the specific client, the Company does not admit new clients that meet any of the following criteria:
- Refusal or other forms of failure to provide adequate due diligence or an acceptable degree of communication
- Client having doubtful creditworthiness or negative reputation
- Client functions as a shell bank
Risks associated with geographical location:
- Clients who live in any one of the countries mentioned on our Risk-List (which is revised regularly): Libya, Sudan, Iraq, Afghanistan, and United States of America
- Clients who live in countries that don't follow the Financial Action Task Force's (“FATF”) recommendations:
- North Korea*
*Jurisdictions subject to the FATF’s countermeasures to protect the international financial system from the jurisdictions' ongoing and severe money laundering and terrorist financing threats.
**Jurisdictions that have not made significant progress in resolving strategic AML/CFT deficiencies or have not committed to an action plan established with the FATF to resolve the deficiencies. The FATF urges its members to understand the risks associated with each jurisdiction's deficiencies, which are mentioned below.
***Identified in the FATF document, "Improving Global AML/CFT Compliance: On-going Process" due to their progress in substantially addressing their action plan agreed upon with the FATF
Risks associated with business types:
Clients with undesirable corporate profiles, such as:
- Companies operating huge amounts of cash
- Weapons and ammunition vendors
- Companies providing adult industry goods and services,
- Unregulated charities and non-profit organizations.
In addition to the aforementioned risk factors, the Company's SM and/or CO can refuse to engage in any business/client partnership at their sole discretion.
6. Client Acceptance Decision
The SM and/or CO can take the Company’s decision for acceptance of a client. In the event of a disagreement between SM and CO, the CO decision prevails. A rejection of a client is followed by a Company Communication to the affected party informing of same with reference to the CAP only (without the need of detailed justification of the reasons).
In the case of rejection for reasons linked to a high risk of money laundering, pursuant to an SM and/or CO decision justifying notification to the authorities, the CO will notify in order to prevent the refused party from finding refuge by other arrangements/providers in the related territory/jurisdiction.
7. Default Normal Risk Classification
Because the minimum Simple Due Diligence is always applied, the Company classifies and handles all of its customers as per the CAP's Normal Risk Classification group.
8. Business Profile Categorization
Based on the zones of expertise of the company: New clients are assigned to one of the two basic business categories by the SM and/or CO:
1 of 2: Personal investment interest in financial instrument trading
2 of 2: Investment service providers' corporate relationships
9. Company Clients Norms and Non-Face-to-Face Applicability
The typical Client of the Company seeks investment interest in trading financial instruments on the Company's online platform(s).
As a result of the above, the common client of the Company is not face-to-face, as is the practice in the applicable industry.
10. Know-your-Client (KYC) and Client Information
ID/Passport verification, Corporate credentials verification (if applicable), and Additional Information Collection are all accomplished via communication with the Client prior to or shortly after the start of the business partnership.
Additional Information that is being gathered by the Company:
- The reason for opening a trading account;
- ID and contact information of each executive, and beneficiary of the Client (if a legal entity);
- Professional status and related history of the Client’s executives, or beneficiary (if a legal entity);
- A utility bill or a bank statement that includes the residence's address;
- A complete set of corporate/statutory documentation (if a legal entity);
Pieces of information that may be also requested by the Company:
- Bank reference;
- Certificate of Incumbency;
Third-party inspection at CO's discretion: World Compliance®* Passport/ID verification, Structure name check, PEP check, and Adverse Facts check of each executive/beneficiary of the Client
*World Compliance® is a database service that provides accurate screening and information to help companies comply with:
OFAC, Office of Foreign Affairs FATF, Financial Action Task Force 3rd EU Anti-Money Laundering Directive
11. Continual Monitoring
According to the design of the Company's core philosophy and its platform/systems, the occurrence of client-related events (transactions, deviations from standard, etc.) is dynamically and closely controlled by SM and CO.
Particular incidents, including but not limited to the Risk-alerts mentioned below, necessitate an interim analysis of client details and the Company affairs, as well as an effort to obtain clarifications from the client's side.
Indicative, but not exhaustive list of Risk-alerts:
- The current Power of Attorney that restricts the Director's authority.
- Request for a cash deposit agreement in excess of a pre-determined essential level set at USD 10,000 monthly;
- Dramatical rise of the volume of operations in a short period of time.
- Frequent change of the Account’s and the information
- Lack of communication with clients / inability to contact clients / information delivery delays
- Transaction requests that are unusually complex or inconsistent with the client's profile and expertise acquired by the Company
- Mismatches or omissions in important banking, legal, or guidance records
12. Maintenance of Client List
At Company, both the SM and CO are in charge of keeping a reference Client List of Company that includes at least the following information:
- Name of Person/Entity
- Contact information
- Date of account opening
- Account ID
- Account Balance
- Trading volume
13. Records storing
Following a complete termination of the client partnership, the Company keeps track of all client information in its hands (hard-copy or soft-copy) for a period of 7 years.
14. Long-term scheduled Review of Client information
The Company reserves the right to perform a review of client information for the following reasons:
- If it is considered appropriate to perform an all-current-clients analysis (usually occurs every three years);
- If a significantly involved client expands into new industry and Company affairs;
- At a more regular or different period, and at the sole discretion of SM &/or CO; or, whichever happens first:
- If a client has been comparatively inactive for a reasonable amount of time;
- If a client who has been inactive for at least one year returns to the Company with activity;
15. Internal Assessment and Reporting to the Authority
Any information or suspicion of money laundering, terrorist funding, or related activities that may occur in the Company is recorded on the report and then reviewed jointly by the Director, SM, and CO. Finally, if the CO wishes to notify authorities in this regard, the CO submits the necessary details.