The purpose of the AML Policy is to lay down the Company’s major internal measures, procedures and controls relevant to the prevention of Money Laundering and Terrorist Financing. All amendments and/or changes of this Policy must be approved by the Board of Directors.
The Company, prior to engaging in business relationship with its potential clients, notifies the potential clients of the clients’ classification in use by the Company. Clients will be categorized into one of the following two categories: retail or professional.
Each client, who is not a professional client, is considered to be a retail client. It is noted that Retail Clients are afforded with the highest level of protection.
Professional client is a client who possesses the experience, knowledge and expertise to make its own investment decisions and properly assess the risks that it incurs.
Option To Change Classification – Request For Different Classification
A professional client is allowed to request non-professional treatment when he is not in a position to properly assess and manage the risks involved in the transactions and the Company may agree to provide a higher level of protection. On the other hand, retail clients are also allowed to request to be treated as professional clients, provided that at least two of the following criteria are satisfied:
- Trading experience (more than 10 transactions of significant size in the past year)
- Investment portfolio above 500,000 USD
- Working experience in the financial sector for a significant period of time
In this case, the Client will be afforded a lower level of protection.
It should be stressed that both kind of requests may be submitted to the Company but the Company reserves the right to decline any of the above requests.
Customer KYC and due diligence:
In order to comply with the AML Laws and Regulations the Company shall establish the identity and verify the identity of any customer of the Company by requiring the customer to produce an identification record or such other reliable, independent source document.
If the transaction is conducted by a natural person, the Company should identify and verify the information below:
- The person’s name and address
- The national identity card (ID), passport, social security document or other applicable official identifying document
- The source of funds
If the transaction is conducted by a legal person or legal arrangement, the Company should identify and verify the information below:
- The Company’s proof of incorporation or similar evidence of establishment or existence
- The customer’s name, legal form, head office address and identities of directors and source of funds
Funding and Withdrawals
- The Client has the right to deposit in their trading account only using the payment systems available by the Company.
- In case there are any delays in depositing the account, the Company holds no responsibility for the result of trading operations on the Client’s account.
- In case a Client’s trading account is funded by a third party or a Client submits a withdrawal request on the name of a third party the Company has the right to cancel/reject the Client’s deposit or withdrawal. In such a case the funds deposited will be transferred back to the same bank details they came from. If this occurs, the Client is charged with all costs for funds transfer.
- In the event the trading account is credited in any currency other than the one in which the trading account is maintained, such funds are to be credited to the trading account on the basis of an internal exchange rate adopted by the Company from the Bank serving the Company at the date of deposit.
- When processing a withdrawal request, the Company shall use its internal currency rates adopted by the Company from the Bank serving the Company at the date of withdrawal.
- If the trading account cannot be credited automatically, the appropriate application will be fulfilled within 72 hours since the client’s notice on crediting the trading account is received.
- The funds can only be withdrawn into such payment system that was used for crediting the trading account or to another payment system, at the Company’s discretion. If this requires additional documents from the Customer side, the Company will not be liable for any delays incurred.
- The Client is the only responsible party for the adequacy of all the information set out in its application for the withdrawal of funds.
- If the Client uses the same payment systems for deposits and withdrawals but simultaneously with different bank details, the Company has the right to refuse the Client’s withdrawal request.
- The Company undertakes to take any and all expedient actions to preclude any illegal financial operations and money laundering with the employment of the Company’s resources.
Recognition and reporting of suspicious transactions by the company
The Company is obliged to report to the relevant Supervisory Authority any attempt of executing transactions which knows or suspects that are related to money laundering or terrorist financing.
More particularly, the Company shall conduct ongoing due diligence on its business relationships in order to ensure that the transactions being conducted comply with the relevant laws and are consistent with information that the Company has of its customers.
Whenever the Company suspects or has reasonable grounds to suspect that any transaction is related to the Commission of a money laundering offence or terrorist financing shall take reasonable measures to ascertain the purpose of the transaction, the origin and ultimate destination of the funds involved and the identity and address, of any ultimate beneficiary. In addition, the Company will monitor suspicious transactions for AML purposes and report accordingly to the relevant Anti-Money Laundry Combat Units.