AML and KYC policy

1. Client due diligence

We verify the identity and address of every client before real money trading is enabled, and we identify beneficial owners and controllers for corporate accounts. We assess source of funds and source of wealth where our risk assessment requires it.

2. Risk based approach

Each client is assigned a risk rating based on factors including jurisdiction, occupation, expected activity and exposure to politically exposed persons. Higher risk relationships receive enhanced due diligence and are reviewed more frequently.

3. Sanctions and screening

We screen clients and payments against applicable sanctions and watch lists at onboarding and on an ongoing basis. We do not open or maintain accounts for sanctioned parties, and we do not accept business from jurisdictions we have excluded.

4. Payments

• Deposits and withdrawals must be in your own name; third party payments are rejected.
• Cash and anonymised payment methods are not accepted.
• Withdrawals are normally returned to the source of the original deposit.

5. Monitoring and reporting

Transactions are monitored for unusual patterns, and staff must escalate suspicions internally. Where required, we report suspicious activity to the competent authority and we may be prohibited by law from telling you that a report has been made.

6. Records, training and governance

We keep due diligence and transaction records for the period required by law, train all staff on financial crime obligations, and subject the programme to independent review.