AML AND TERRORIST FINANCING PREVENTION POLICY

ANTI MONEY LAUNDERING AND TERRORIST FINANCING PREVENTION POLICY

It is the policy of the Trades.com to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements. 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.  We are committed to the highest standards of the Anti-Money Laundering (hereinafter: AML) compliance and Terrorist Financing Prevention by requiring its officers, employees, and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.

What is money laundering

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.

How we contribute to fighting money laundering and terrorist financing

We make sure that each employee, whose duties are associated with the provision of products and services of the Trades, and who directly or indirectly deals with the Client, knows the requirements of the applicable 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 The employee will also ensure that the firm keeps and maintains all of the required AML records and will ensure that Clients conduct is being monitored. The employee is vested with full responsibility and authority to enforce AML Policy. We perform all the required measures in order to prevent and detect money laundering and terrorist financing,

The employee 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.

 

Responsibility of the management

To ensure that this policy is carried out, management of the Trades.com has developed ongoing employee training under the leadership of the AML Compliance and senior management. Our training will occur on at least every three months. It will be based on our firm’s size, its Client base, and its resources and be updated as necessary to reflect any new developments. This training 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. Management will employ strict procedures both to ensure that only relevant information is shared and to protect the security and confidentiality of this information.

 

Maintenance and Confidentiality

We will hold any supporting documentation confidential. 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, 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.

 

Continues monitoring of activities

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 account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. The AML Compliance will be responsible for this monitoring, will review any activity that our monitoring system detects, will determine whether any additional steps are required, will document when and how this monitoring is carried out, and will report suspicious activities to the appropriate authorities.

 

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. It is important to us that we obtain sufficient information about each Client to allow us to evaluate the risk presented by that Client and to detect and report suspicious activity. In assessing the risk of the Client, business relationship, product or transaction, 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.

 

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.

Identifying and Reporting Suspicious Activity

The first action by any employee who suspects suspicious activity is to escalate the matter to the AML Officer. Under no circumstance should any of the parties be informed before, during or after any investigation whether formally reported or not. The Officer should assess any report and decide whether to escalate the matter.

 

Storage

Our records are held securely for required period from the date of the transaction or receiving from a Client. Our staff will ensure that all photographed or photocopied or scanned passport and/ or driving license records are disposed of in a secure manner and/ or stored in secure lockable filing cabinets.

 

Review and Updating

This Policy reflects the firm’s current risks. It will be reviewed annually or sooner in the event of needed changes.