AML and KYC Policy

• 3.1.1  Identifies its Clients and/or Partners and ensures that they are indeed the persons who claims to be by requesting a photo of an identification document which is issued by an independent, reliable and reputable official source that carries the Client’s or Partner’s photo, full legal name, date of birth, issue and expiry date, signature and identification number;
• 3.1.2  Identifies and verifies the Client’s and/or Partner’s permanent address though the provision of a recently issued document
• 3.1.3  Carries out sufficient monitoring of the transactions and the business relationship to enable the detection of unusual and/or suspicious transactions.
• 3.1.4  Gathering, evaluation and examination of information related to suspicious transactions and reporting of suspicious transactions to the relevant authorities though the appropriate channels.
• 3.1.5  Carries on an on-going monitoring of any reported suspicious activities and closely collaborate with the relevant authorities.
• 3.1.6  Retains copies of the documents and information which are necessary to comply with the due diligence requirements, supporting evidence and records of transactions which are necessary to identify transactions and supporting records of correspondence with the Clients and/or Partners and other persons with whom business relationship is maintained for a minimum of 7 years, following the end of the business relationship and/or termination of the Client’s Agreement and/or Terms and Conditions and/or Partner’s Agreement between the Company and the Client and/or Partner or after the date of the execution of an occasional transaction;
• 3.1.7  Ensures that all staff members are fully aware of their legal obligations, according to the AML/CFT Law and are sufficiently trained in the appropriate KYC and AML procedures, as well as in what constitutes suspicious activity and the internal reporting process of such activity to the Compliance Officer of the Company..
• 3.1.8  Uses all resources and information available to ensure that all suspicious activities have been investigated.

A. Proof of Identity

• 1 Physical Persons:
  • i.  Proof of Identity which can be a copy of the national identification card and/or driver’s license and/or passport front and back which has been issued within the last 10 years;
• 2  Legal Persons:
  • i.  Recent (up to 3 months) Certificate of good standing or recent (up to 3 months) Bank Statement on the name of the Legal Person;
  • ii.  Recent (up to 6 months) Corporate Documents of the Legal Person. These include Certificate of Incorporation, Certificate of Directors, Certificate of Shareholders, Certificate of Registered Address.
  • iii.  Memorandum and Articles of Association of the Company;
  • iv.  Resolution of the Board of Directors of the Legal person for the opening of the account and granting authority to those who will operate it;
  • v.  Declaration of the Ultimate Beneficial Owner;
  • vi.  Proof of Identity for all the Directors of the Company, UBOs (who hold more than 10%) and the Manager of the Account.
  • vii.  Proof of Address for all the Directors of the Company, UBOs (who hold more than 10%) and the Manager of the Account

B. Proof of Address

• i.  Utility Bill such as electricity bill, water bill, gas bill, landline phone bill, TV/Internet bill, local authority tax bill, property tax, municipality fees and home insurance documents which includes the Client’s and/or Partner’s full name, full residential address, full name of the issuing institution/authority and issue date which must be no longer than 6 months;
• ii.  Bank Statement/ Bank Confirmation which indicates the Client’s and/or Partner’s full name, full residential address, logo or clear stamp of the bank and issue date which must be no longer than 6 months;
• iii.  Certificate of residence issued by local municipality, police station etc. which includes the Client’s and/or Partner’s full name, full residential address, full name of the issuing authority and clear stamp of the issuing authority.
• iv.  Affidavit which indicates the Client’s and/or Partner’s full name, full residential address, signature and stamp of the public notary or a public’s official and/or any other Government issued document which includes the above-mentioned information.

C. Proof of Payment Method

• i.  Full name of cardholder;
• ii.  Date of expiry of the card;
• iii.  Showing ONLY the last 4 digits (these should match with the card number from which the account was funded). Please make sure that the first 12 digits of the card and CVV code are covered/not shown; and
• iv.  Signature on the designated space provided on the card.

Confirmation of deposit through wire transfer or Bank statement must include:

• i.  full name;
• ii.  date of transaction;
• iii.  reference number used when making the deposit;
• iv.  amount deposited;
• v.  bank account name/number where the funds were deposited.

The Company in its sole discretion may request by the Client to provide any other document serving as proof of payment method as it deems necessary according to the deposit method used.

• i.  Gender;
• ii.  Date of Birth;
• iii.  Nationality;
• iv.  Telephone number;
• v.  Passport or ID number;
• vi.  Tax ID (where applicable);
• vii.  Home Address;
• viii.  Investor’s Information

• a)  recent payslip (up to 3 months); or
• b)  bank statement demonstrating the last 3 months of income; or
• c)  Tax return or tax certificate; or
• d)  Written confirmation signed by the employer confirming Client’s annual salary; or
• e)  Passport or ID number;
• f)  Bank statement showing the balance; or
• g)  Property sale agreement; or
• h)  Annual income statement

• 4.4.1  The Company will not accept as Clients and/or Partners persons engaged in unethical behavior or in illegal activities;
• 4.4.2  The Company will not accept as Clients and/or Partners parties that cannot make a well informed and reasonable judgment as to the activities in which they are engaged.
• 4.4.3  The Company will not accept new Clients and/or Partners and may terminate the business relationship with existing Clients and/or Partners if the persons are unwilling to provide sufficient documents/data and information as requested by the Company and/or persons who provide false and/or edited and/or forged and/or incomplete documents and/or information according to the Company’s sole discretion.
• 4.4.4  The Company will accept only those new Clients and/or Partners who complete the appropriate account opening procedure and provide the Company with all necessary verification documents and information to the satisfaction of the Company.
• 4.4.5  The Company will accept a prospective or potential Client and/ or Partner only when it becomes fully satisfied that the Client and/or Partner complies the AML and KYC procedures to ensure that a new relationship with the potential Client and/or Partner does or will not negatively affect the reputation of the Company.

• 4.8.1  terminate the business relationship
• 4.8.2  nullify any profits of the Client and/or commissions of any Partner
• 4.8.3  close all accounts they hold with the Company
• 4.8.4  reject any withdrawal request
• 4.8.5  set the account to read-only where the Client and/or Partner will only be able to log-in in his/her portal without being able to proceed with any other action in relation to his/her account
• 4.8.6  retain any costs from any of the Client’s trading accounts and/or Client’s and/or Partner’s e-wallets if these are deemed necessary
• 4.8.7  take any other measure as described in the Termination and Default section of the Client’s Agreement and/or Terms and Conditions and/or Partner’s Agreement.

• 4.12.1  Where required by law or a competent court
• 4.12.2  Where requested by any regulatory authority
• 4.12.3  To relevant authorities to investigate or prevent fraud, money laundering or other illegal activity
• 4.12.4  To credit reference and fraud prevention agencies, third authentication service providers and other financial institutions for credit reference agencies, fraud prevention agencies, third authentication service providers and other financial institutions for credit checking, fraud prevention, anti-money laundering purposes, identification or due diligence checks of the Client. To do so they may check the details the Client supplied against any particulars on any database (public or otherwise) to which they have access. They may also use Client details in the future to assist other companies for verification purposes. A record of the search will be retained.
• 4.12.5  Where necessary in order for the Company to defend or exercise its legal rights;