AML and KYC policies

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy establishes a framework for Excellence Traders Limited to:

• Prevent money laundering and terrorist financing activities
• Comply with applicable AML and counter-terrorism financing regulations
• Verify the identity of all clients and beneficial owners
• Monitor and report suspicious transactions
• Maintain comprehensive records and documentation

Our AML/KYC program is designed to comply with:

• Financial Action Task Force (FATF) recommendations
• Local anti-money laundering legislation
• Counter-terrorism financing regulations
• International sanctions and embargo requirements
• Industry-specific regulatory guidelines

We implement a risk-based approach, considering:

• Client risk profile and geographic location
• Product and service risk assessments
• Transaction patterns and behavioral analysis
• Delivery channels and technological risks
• Ongoing monitoring and review processes

2.1 Identity Verification Requirements

All clients must provide the following documents for identity verification:

Individual Clients

• Government-issued photo identification (passport, driver’s license, national ID)
• Proof of address (utility bill, bank statement, government letter)
• Proof of income or financial status (bank statement, employment letter)
• Arbitrage trading risk: Spreads may adversely affect positions
• Additional documents as required for risk assessments

Corporate Clients

• Certificate of incorporation or equivalent
• Memorandum and articles of association
• Register of directors and shareholders
• Beneficial ownership information
• Authorized signatory documentation

2.2 Document Verification Process

Our verification process includes:

• Document authentication: Verifying the legitimacy and validity of documents
• Data cross-referencing: Comparison with reliable data sources
• Biometric verification: Advanced identity verification (where applicable)
• Address verification: Confirmation of residential or business address
• Third-party verification: Use of approved verification service providers

2.3 Acceptable Document Standards

All submitted documents must meet the following conditions:

• Original documents or certified copies
• Clear, legible, and unaltered
• Current and within validity period
• Issued by a recognized authority
• In English or with certified translations

3.1 High-Risk Client Categories

The following client categories require enhanced due diligence:

• Politically Exposed Persons (PEPs): Government officials, senior executives
• High-risk jurisdictions: Countries blacklisted by FATF
• Complex ownership structures: Trusts, foundations, shell companies
• Cash-intensive businesses: Currency exchange, gambling

3.2 Source of Funds and Wealth

For high-risk clients, we require the following details:

• Source of funds: Specific origin of funds used for trading
• Source of wealth: Overall wealth accumulation and origin
• Business activities: Nature and legitimacy of business operations
• Financial history: Previous trading experience and financial background
• Purpose of relationship: Intended use of our services

3.3 Ongoing Enhanced Monitoring

High-risk clients are subject to:

• More frequent periodic reviews (quarterly vs. annually)
• Lower transaction monitoring thresholds
• Senior management approval for account opening
• Enhanced transaction analysis and reporting
• Regular updates to risk assessments

4.1 Sanctions List Monitoring

We screen all clients against the following sanctions lists:

• United Nations Security Council: UN sanctions lists
• OFAC: U.S. Office of Foreign Assets Control sanctions
• EU Sanctions: European Union restrictive measures
• National lists: Local government sanctions and restrictions
• PEP lists: Politically Exposed Persons databases

4.2 Screening Procedures

Our screening process includes:

• Real-time screening: Automated screening during onboarding
• Ongoing monitoring: Periodic rescreening against updated lists
• Fuzzy logic matching: Advanced name-matching algorithms
• Manual review: Human verification of potential matches
• Documentation: Comprehensive records of screening results

4.3 Prohibited Jurisdictions

We do not provide services to residents of the following jurisdictions:

• High-risk countries: North Korea, Iran, Syria, Afghanistan
• Restricted regions: Crimea, Donetsk, Luhansk, Gaza Strip
• FATF-listed: Myanmar, countries under enhanced monitoring, updated per FATF guidelines

5.1 Automated Monitoring Systems

We employ advanced monitoring systems to detect:

• Unusual transaction patterns: Abnormal trading behavior or frequency
• Large transactions: Transactions exceeding predetermined thresholds
• Rapid movements: Quick deposits and withdrawals
• Structuring activities: Attempts to avoid reporting thresholds
• Geographic anomalies: Transactions from unexpected locations

5.2 Suspicious Activity Indicators

Red flags that may trigger enhanced scrutiny include:

• Behavioral Indicators
• Reluctance to provide identification
• Inconsistent or evasive responses
• Urgency in transactions
• Requests for excessive confidentiality
• Knowledge gaps regarding transactions
• Transactional Indicators
• Round-sum transactions
• Unusual sources of funds
• Rapid withdrawal of profits
• Complex transaction structures
• Third-party funding

5.3 Reporting Procedures

When suspicious activity is identified, we:

• Conduct internal investigations and analysis
• Document findings and supporting evidence
• File Suspicious Activity Reports (SARs) with authorities
• Maintain strict confidentiality throughout the process
• Provide ongoing cooperation with law enforcement

6.1 Data Security Measures

We implement robust security measures to protect client data:

• Encryption: End-to-end encryption for data transmission and storage
• Access controls: Role-based access with multi-factor authentication
• Audit trails: Comprehensive records of all data access and modifications
• Backup systems: Regular backups with offsite storage
• Incident response: Data breach management procedures

6.2 Data Privacy Compliance

Our data management practices comply with:

• General Data Protection Regulation (GDPR)
• Local data protection laws
• Cross-border data transfer regulations
• Industry-specific privacy requirements
• Client confidentiality obligations

7.1 Training Program

All employees receive comprehensive AML/KYC training covering:

• Regulatory requirements: Current AML and counter-terrorism financing laws
• Risk assessment: Identifying and evaluating money laundering risks
• Red flag identification: Detecting suspicious activities and behaviors
• Reporting procedures: Proper escalation and reporting protocols
• Customer due diligence: Verification and ongoing monitoring procedures

7.2 Roles and Responsibilities

• Compliance Officer
• Overall oversight of the AML/KYC program
• Regulatory reporting and liaison
• Policy development and updates
• Employee training coordination
• Audit and review support
• Frontline Staff
• Client onboarding and verification
• Initial risk assessments
• Suspicious activity detection
• Document collection
• Escalation of concerns

7.3 Ongoing Professional Development

Our commitment to compliance excellence includes:

• Annual refresher training for all employees
• Specialized training for compliance staff
• Participation in industry conferences
• Support for professional certifications
• Regular updates to policies and procedures

8.1 Client Responsibilities

All clients must:

• Provide accurate information: Complete and truthful personal and financial information
• Submit required documents: All requested identification and verification documents
• Notify of changes: Promptly report any changes in circumstances
• Cooperate with reviews: Assist with periodic reviews and account updates
• Declare source of funds: Provide evidence of legitimate sources of funds when requested

8.2 Ongoing Obligations

Clients must continuously:

• Maintain current and accurate account information
• Respond promptly to information requests
• Report suspicious activities they observe
• Comply with all applicable laws and regulations
• Authorize sharing of necessary information with authorities

8.3 Consequences of Non-Compliance

Failure to comply with AML/KYC requirements may result in:

• Account restrictions or limitations
• Enhanced monitoring and scrutiny
• Suspension of services
• Account termination
• Reporting to regulatory authorities

9.1 Periodic Review Schedule

This policy is subject to:

• Annual review: Comprehensive annual policy assessment
• Regulatory updates: Immediate updates for regulatory changes
• Risk assessment updates: Revisions for changes in risk assessments
• Incident-driven reviews: Updates following significant events
• Best practice integration: Incorporation of industry best practices

9.2 Stakeholder Engagement

Policy updates involve:

• Senior management approval
• Legal and compliance review
• Operational impact assessment
• Employee training updates
• Client communication (where applicable)

9.3 Implementation and Communication

Policy changes are implemented through:

• Employee notification and training
• System and procedure updates
• Client notification when required
• Regulatory filings for significant changes
• Website and documentation updates