AML POLICY

 

Introduction and Scope This document is the AML/CTF Policy (Policy) adopted by FxToday (hereinafter referred to as the "Company").

 

Money laundering (ML) is taking money from illegal services and making it appear to be legally obtained. It is the processing of criminal profits to disguise their illegal origin. Terrorism financing (TF) includes the financing of terrorist acts, terrorists, and terrorist organizations.

 

What is Money Laundering?

 

Money laundering is the process by which criminally obtained money or other assets (criminal property) are exchanged for "clean" money or other assets with no obvious link to their criminal origins.

 

Criminal property may take any form, including money or money’s worth, securities, tangible property, and intangible property. It also covers money, however obtained, which is used to fund terrorism.

 

What is Counter-Terrorist Financing (CTF)?

 

Terrorist financing is the process where legitimate businesses and individuals provide funding to resource terrorist activities or organizations for ideological, political, or other reasons. Firms must ensure that: (i) customers are not terrorist organizations themselves, and (ii) they are not providing the means through which terrorist organizations are being funded.

 

Terrorist financing may not involve the proceeds of criminal conduct but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

 

FxToday is an ethical and transparent company, and it takes the responsibility to ensure and maintain that its assets and resources are not used for money laundering, terrorism financing, or corruption. Despite not being explicitly required by local laws, the Company commits to identifying its customers before providing certain services.

 

The Policy and the procedures discussed hereunder apply to all employees and entities of the Company involved in the provision of Forex trading services, including but not limited to senior management, front-line employees, back-office personnel, and compliance officers.

 

The Compliance Department (CD) shall:

• Perform all functions specifically assigned under this Policy.
• Monitor compliance and report any significant concerns to the Board.
• Conduct ongoing assessments of the risks of money laundering and terrorist financing faced by the Company and develop strategies to manage and mitigate those risks.
• Receive internal reports of (suspicions of) money laundering.
• Investigate reports of suspicious events.
• Ensure the adequacy of arrangements made for the awareness and training of staff and advisers.
• Report at least annually to the firm’s governing body on the operation and effectiveness of the firm’s systems and controls.
• Monitor the day-to-day operation of anti-money laundering policies in relation to:
  • The development of new products.
  • The onboarding of new customers.
  • Changes in the firm’s business profile.
• Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the Compliance Department.

 

Compliance with FATF Guidelines

 

The Company acknowledges the importance of adhering to the Financial Action Task Force (FATF) requirements and maintaining a strong commitment to combating money laundering and terrorist financing. As a reputable financial institution, we are committed to upholding the highest standards of compliance and actively participating in global efforts to combat illicit financial activities.

 

To ensure compliance with FATF requirements, the Company has implemented the following measures:

 

Risk-Based Approach

 

The Company has adopted a risk-based approach to its AML/CFT policies and procedures, which enables the Company to identify, assess, and mitigate the specific risks associated with money laundering and terrorist financing. Risk assessments are conducted regularly to stay updated on emerging risks and adjust controls accordingly.

 

Customer Due Diligence (CDD)

 

The Company adheres to the FATF’s recommendations on customer due diligence by conducting thorough verification and screening procedures for all customers. This includes obtaining and verifying the necessary identification and beneficial ownership information, as well as conducting ongoing monitoring of customer transactions and activities.

 

Record Keeping

 

The Company maintains comprehensive and accurate records of customer transactions, due diligence activities, and internal AML/CFT controls as mandated by FATF. These records are securely stored and made available for inspection by regulatory authorities when required.

 

Training and Awareness

 

The Company provides regular training programs and awareness sessions to employees carrying out functions prone to AML/CFT risks to ensure they have a thorough understanding of relevant AML regulations and FATF recommendations, their obligations, and the importance of compliance in preventing money laundering and terrorist financing.

 

Risk Assessment

 

As part of the risk-based approach, the Company conducts and documents a risk assessment of the ML/TF risks it is exposed to and develops strategies to mitigate them.

 

Customer Identification and Verification

 

Before providing services to a customer, the Company shall:

• Collect certain minimum customer identification information.
• Verify that information using reliable, independent sources or a third-party provider if required.
• Identify and verify the beneficial owner(s) of a customer.
• Identify whether a customer is a Politically Exposed Person (PEP) and take steps to establish the source of funds for the transaction when necessary.
• Obtain information on the purpose and intended nature of the business relationship or transaction(s) when required.

 

Transaction Monitoring

 

The Company routinely collects and monitors customer transactional activity to detect activity indicative of suspicious matters, including structured transactions, misleading identification information, or the use of multiple profiles. Enhanced Due Diligence (EDD) measures are applied where necessary.

 

Know Your Customer (KYC)

 

The Company requires all customers to provide:

• Full Name
• Residential Address

Verification must be based on reliable, independent sources such as:

• A government-issued document with the customer’s full name and residential address.
• A valid passport or national identity card.

 

Government and Sanction List Screening

 

The Company screens all customers against government and sanctions lists from authorities such as the European Union (EU), the U.S. Office of Foreign Assets Control (OFAC), and the United Nations (UN). Customers found on these lists are subject to account suspension or termination.

 

Politically Exposed Persons (PEPs)

 

The Company identifies PEPs and applies enhanced due diligence, including additional verification of the source of wealth and source of funds.

 

Due Diligence

 

The Company implements:

• Customer Due Diligence (CDD) – standard identification procedures.
• Enhanced Due Diligence (EDD) – for higher-risk customers.
• Source of Funds and Wealth Verification – in applicable cases.

 

Restricted Countries

 

The Company prohibits providing services to customers in countries subject to economic and trade sanctions or identified as high-risk for ML/TF activities. The list of restricted countries is periodically reviewed and updated.

 

FxToday is committed to maintaining the highest standards of compliance with global AML/CFT regulations and ensuring that its financial services remain free from money laundering and terrorist financing risks.