1. General Terms
AMarkets LLC (hereinafter referred to as “Company”) aims at maintaining high standards in AML (Anti-Money Laundering) and CFT (Combating the Financing of Terrorism) procedures.
The Company takes necessary measures to ensure that Clients, Investors, Agents, Intermediaries and other entities involved in business are not engaged in any form of illegal activities, including but not limited to money laundering, terrorist financing, proliferation of weapons of mass destruction, drug trafficking, blackmailing, smuggling, concealment of corruption schemes, tax evasion and cybercrime actions.
This policy offers general information to potential or existing Clients of the Company, outlining its general responsibilities towards Client verification and the steps taken to detect and prevent Money Laundering and Terrorist Financing.
Before registering a trading account on the platform, the Client acknowledges having read and agreed to the Company’s AML/CFT policy and the List of Prohibited Jurisdictions.
2. Anti-Money Laundering Definition
Anti-Money Laundering (AML) refers to procedures, regulations, and laws designed to reveal attempts to disguise illegally obtained funds. Hiding the source of funds from financial regulators or law enforcement entities may be considered a financial crime, leading to serious consequences.
The expansion of the financial industry prompted the implementation of AML regulations and laws due to the growing concerns around money laundering in our rapidly evolving society. These measures have been adopted globally, leading to organizations and individuals involved in such activities encountering challenges with official regulators and law enforcement agencies.
3. The policy of Anti-Money Laundering and Combating the Financing of Terrorism adopted at AMarkets LLC
The Company fully complies with the laws and regulations of the Cook Islands that are aimed at preventing Money Laundering and Terrorist Financing. Detailed information regarding these laws and regulations can be found on the website of the Financial Supervisory Commission (FSC) of the Cook Islands.
Money Laundering and the Financing of Terrorism are considered criminal offenses in the Cook Islands.
In accordance with the Financial Transactions Reporting Act 2017 (FTRA), the Company has implemented the following Compliance Programme for combating Money Laundering and Terrorist Financing:
3.1 Development of the AML/Compliance Department
The AML/Compliance Department oversees the Compliance Programme within the Company.
The AML/Compliance Department is responsible for the following:
- Developing, implementing, and updating internal AML policy that is in compliance with the FTRA.
- Supervising and facilitating training for the staff on identifying suspicious financial patterns.
- Providing assistance to Financial Intelligence Units in the detection and prevention of suspicious financial activity.
- Informing the Board of Directors and Senior Management about the Compliance Programme and the Company’s financial risks.
- Conducting verification and monitoring of the Company’s Clients (Customers).
The AML/Compliance Department is led by a Money Laundering Reporting Officer (MLRO) appointed by the Board of Directors.
3.2 Mandatory Know Your Customer policy
The Know Your Customer (hereinafter referred to as “KYC”) is a mandatory procedure for verifying a Client’s identity. It helps to protect the Client’s and Company’s interests by minimizing risk of fraudulent activities.
Opening fraudulent and anonymous trading accounts in financial institutions is strictly prohibited by applicable laws.
The KYC procedure includes, but is not limited to, verifying the Client’s:
- Document validity;
- Personal Information;
- Email and Phone Number;
- Country of Residence.
The Company reserves the right to request additional information for completing the KYC procedure when deemed necessary. Submitting insufficient or incorrect data by a Client may lead to rejection or termination of services.
Client verification is performed with documents submitted electronically via the third-party service provider.
The confidential information collected by the Company can be disclosed to a third-party only if the request complies with applicable laws.
Any inquiries related to the KYC procedure can be sent to email@example.com.
3.3 Automated Risk-Scoring System
The Company uses an Automated Risk-Scoring System for detecting suspicious Clients and transactions when the risk of Money Laundering and Terrorist Financing appears to be higher.
The Company reserves the right to regulate this System when deemed necessary.
Customers’ risk profiles are reviewed on a regular basis by the AML/Compliance Department.
Detailed information about the Risk-Scoring System and internal procedures of the Company is not disclosed publicly due to security reasons.
Based on the data collected, the AML/Compliance Department estimates the risks for the Company and takes the measures required.
3.4 Informing Employees about Anti-Money Laundering Regulations
Anti-Money Laundering Policies apply not only to bad actors trying to launder illegally procured funds, but also to financial institution employees who take part in monitoring and processing transactions, if there is a possibility of any Money Laundering activity.
Employees of the Company are informed and instructed on a continuous basis about the AML regulations and suspicious patterns attributed to organizations or individuals wishing to launder illegally obtained funds.
Employees of the Company who have suspicions based on the AML instructions and this Policy inform their supervisor and the AML/Compliance Department for further investigation.
3.5 Regulations on Politically Exposed Persons (PEPs)
A Politically Exposed Person in the context of this Policy stands for a person stipulated by Article 3 of the FTRA and includes:
- An individual, who has been entrusted with prominent public functions;
- Family members and close associates of this individual as specified by the FTRA.
Clients who declare having the PEP status are obliged to provide copies of documents confirming such status to the AML/Compliance Department via the email address firstname.lastname@example.org. These documents must be provided before registering a trading account on the platform.
Each case of doing business with a PEP is discussed in private between the parties involved, considering the applicable legislation.
The Company is obliged under the applicable law to be informed about Politically Exposed Persons using its services. The Company reserves the right to use the Third-Party services for confirming the PEP status and ask for additional information when deemed necessary.
The Company keeps records in the English language in relation to identification, verification and financial operations of its Clients, including but not limited to:
- Information provided by the Client for identity verification;
- Methods used for depositing/withdrawing the funds;
- Information about the Client obtained from third-party databases;
- Any discrepancies that arise during the Client’s verification process.
These records are retained for six years from the date of the Client’s last financial activity or the closure of the Client’s account. The Company keeps all records related to any suspicious Client activity for a period of six years.
Any questions or requests regarding the AML and CFT procedures of AMarkets LLC or this policy in general should be directed to email@example.com.
Date of Last Revision 16/11/2023
AMarkets LLC registered in the Cook Islands with registration number LLC14486/2023