AML AND TERRORIST FINANCING PREVENTION POLICY

ANTI MONEY LAUNDERING AND TERRORIST FINANCING PREVENTION POLICY

  1. This Anti money laundering and terrorist financing prevention policy is the Policy of Trades.com and its affiliates to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Trades.com is committed to the highest standards of the Anti-Money Laundering (hereinafter: AML) compliance and Terrorist Financing Prevention. Trades.com requires its officers, employees, and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.

 

  1. For the purposes of this Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

 

  1. com will make sure that it is dealing with a real person or legal entity. We perform all the required measures in accordance with applicable law and regulations, issued by monetary authorities. In order to prevent and detect money laundering and terrorist financing, the We make sure that each employee, whose duties are associated with the provision of products and services of the Trades.com and who directly or indirectly deals with the clientele, is expected to know the requirements of the applicable laws and regulations which affect his or her job responsibilities, and it shall be the affirmative duty of such employee to carry out these responsibilities at all times in a manner that complies with the requirements of the relevant laws and regulations

 

  1. The obligations from the previous paragraphs of this Policy include:

 

  1. Assessment of risks of misuse for money laundering and financing of terrorism for a particular Client, business relationship, transaction or product.
  2. Due diligence of the Client in a manner and under conditions defined by this Policy.
  3. Taking measures for prevention and detection of money laundering and terrorist financing.
  4. Appointing authorized persons and their deputies for implementation of the measures and ensuring conditions for their work in accordance with this Policy and the law.
  5. Allow regular professional training and education of employees and ensuring regular control in the tasks and obligations in accordance with this Policy and the law.
  6. Development and regular topping the list of indicators for identifying suspicious Clients and transactions for which there are grounds for suspicion of money laundering or terrorist financing,
  7. Information and documentation on transactions and persons in accordance with this Policy and the law,
  8. Ensure retention and protection of data and maintain records in accordance with these Policy and the Law,
  9. Development of the information system within in order to be fast, timely and fully to provide information on whether Trades.com maintains a business relationship with a particular person or entity, and what is the nature of that relationship.

 

  1. To ensure that this general policy is carried out, management of the Trades.com has established and maintains an ongoing program for the purpose of assuring compliance with the relevant laws and regulations and the prevention of money laundering. This program seeks to coordinate the specific regulatory requirements throughout the group within a consolidated framework in order to effectively manage the group’s risk of exposure to money laundering and terrorist financing across all business units, functions, and legal entities.

 

  1. We will share information with other financial institutions regarding individuals, entities, organizations and countries for purposes of identifying and, where appropriate, reporting activities that we suspect may involve possible terrorist activity or money laundering. Before we share information with another financial institution, we will take reasonable steps to verify that the other financial institution has submitted the requisite notice, either by obtaining confirmation from the financial institution or by consulting a list of such financial institutions that we will make available. We understand that this requirement applies even to financial institutions with which we are affiliated, and that we will obtain the requisite notices from affiliates and follow all required procedures.

 

  1. We will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information, for example, by segregating it from the firm’s other books and records as describe by other procedures.

 

  1. In addition to gathering information from the clients, Trades.com continues to monitor the activity of every client to identify and prevent any suspicious transactions. We will carefully monitor the business activities carried out by his client, monitor and verify compliance of the Client with the expected nature and purpose of a business relationship, resources with a source of funds, and operations or transactions of the Client with his usual scope of operations or transactions.

 

  1. For each client we assess risk of money laundering or terrorist financing. Risk analysis is a procedure in which the Trades.com defines the evaluation of the likelihood that his business could be misused for money laundering or terrorist financing, and the criteria, which will be the particular Client, business relationship, product or transaction be classified as more or less risky in the field of money laundering or terrorist financing.

 

  1. We will define the risk category by criteria defined in this Policy, under which the implementation of measures in the analysis of the Client, certain clients, business relationship, product or transaction considered, a risk category will be assigned. In determining the risk category We may, with respect to the criteria of risk, classifies particular client, business relationship, product or transaction as a high risk of money laundering or terrorist financing, and will make a deep analysis of the Client. In evaluating the risk the we will use the list of indicators for identifying suspicious transactions and in relation to which there are reasons for suspicion of money laundering or terrorist financing.

 

 

  1. In assessing the risk of the Client, business relationship, product or transaction, the we will take into account the following criteria:

 

  1. The type, business profile and structure of the Client.
  2. Geographical origin of the Client.
  3. The nature of the business relationship, product or transaction.
  4. Past experience with the Client.

 

  1. Before opening an account, and on an ongoing basis, we will check to ensure that a Client does not appear on the SDN list or is not engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC. Because the SDN list and listings of economic sanctions and embargoes are updated frequently, we will consult them on a regular basis and subscribe to receive any available updates when they occur. With respect to the SDN list, we may also access that list through various software programs to ensure speed and accuracy.

 

  1. If we determine that a customer is on the SDN list or is engaging in transactions that are prohibited by the economic sanctions and embargoes administered and enforced by OFAC, we will reject the transaction and/or block the Client’s assets and file a blocked assets and/or rejected transaction form with OFAC within 10 days.

 

  1. Each of the our affiliates is required to comply with AML policy.

 

  1. All identification documents and services records shall be kept for the minimum period of time required by local law.

 

  1. All new employees shall receive anti money laundering training as part of the mandatory new-hire training program. All applicable employees are also required to complete AML and KYC training monthly. Participation in additional targeted training programs is required for all employees with day-to-day AML and KYC responsibilities.