AML / KYC Policy

General

In order to ensure the compliance with international trade standards we operate exclusively in accordance with the legislation on combating illicit money laundering and countering terrorism financing. To monitor the compliance with legal requirements and recommendations of FATF, we have established a Compliance department developing Anti-money laundering and Know your customer (AML / KYC) procedures, obligatory for all employees and customers and determining the policy of engagement with any person who intends to become our customer.

The Compliance Department ensures that all the operations of the Company are consistent with the international standards to combat money laundering and all the documents provided by the Customer are up-to-date and comply with relevant legal requirements.

AML / KYC rules

As our client you irrevocably agree with the following rules and undertake to observe them:

• You are obliged to follow our AML and KYC requirements while you are our client. Upon the request of the Company the additional documents and information should be provided by you. Filling of the respective KYC questionnaire may also be an obligatory requirement under Company’s sole decision. You agree with such requirements of the Company and undertake to follow them;
• The withdrawal of any assets is carried out only to the account that belongs to you. The withdrawal of Assets to third parties is prohibited. Internal transfers between the Company’s customers are also forbidden;
• The Company is obliged and has the right without obtaining prior consent to share with financial institutions and law enforcement agencies any information about you, as required by applicable law, and you give the Company your consent to these actions. In order to comply with this paragraph, the Company holds a records about your transactions for the last five years at least;
• You undertake to follow the legislation, including international ones, aiming to combat illicit trafficking, financial fraud, money laundering and legalisation of funds obtained by illegal means. You should use your best efforts to avoid direct or indirect participation in illegal financial activities and any illegal transactions using the Company’s Website and Services;
• You guarantee the legal origin, legal ownership and the right to use the assets transferred to your account. In case of the evidence of suspicious transactions in your account, cash replenishments from untrusted sources (for example, the data of assets’ sender and Traders Room’s owner is different) and / or any actions with attributes of fraud (including any refunds or cancellation of payments), the Company reserves the right to conduct an internal investigation, to block or close your Traders Room or any account, cancel any payment or trading order and to suspend operations on the accounts before the end of the official investigation. When making the decision the Company is guided by the provisions of the applicable law, FATF recommendations or by common practice;
• The Company has the right to request additional information about you if the method of withdrawal is different from the depositing method. The Company also reserves the right to block your Traders Room or any account during the investigation if you refused to provide the additional information requested by the Company;
• In the course of investigation, the Company has the right to request additional copies of documents confirming your identity or identity of other individuals in the corporate structure, as well documents confirming place of living and lawful possession and legal origin of funds. The Company also has the right to demand the provision of original documents for review in case of any doubts from Company’s side;
• The Company does not provide Services to the persons and legal entities who are located at the jurisdictions that are “blacklisted” by FATF. Also the Company does not provide services to citizens and residents of U.S.A;
• The Сompany refuses to perform the operations that from Company’s point of view are considered to be suspicious. The use of preventive measures (such as blocking or closing of a customer’s Traders Room or any account) is not the reason for civil liability of the Company for failure to fulfil obligations to you;
• The Company is not obliged to inform you or other persons about the measures taken to fulfil the AML/CFT legislation. Also the Company is not obliged to inform you or other persons about any suspicions, about the reasons for refusal of execution of your trading order, refusal to open the account, need for providing any documents, etc;
• This document is just a summary, whose goal is to clarify our rights and our intention to contribute to the worldwide AML initiative. However, each Company has its own internal AML & KYC procedures and rules, that may supplement rules specified in this summary. Nothing in this summary should be understood as an immutable rule that cannot be supplemented by a local AML policy of respective Company;
• This anti-money laundering and knowing your customer policy is an integral part of any agreement concluded between you and the Company. Non-compliance with this policy can be a ground for termination of the agreement at the Company’s sole discretion.