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AML/KYC Policy

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Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy for TradeSphere Ltd.

1. Purpose and Scope

This policy outlines TradeSphere Ltd.’s commitment to preventing and detecting any activities related to money laundering and terrorist financing. As a forex trading company licensed in the Republic of Mauritius, TradeSphere Ltd. is committed to complying with the laws and regulations of the Republic of Mauritius, including the Financial Intelligence and Anti-Money Laundering Act 2002, and other relevant regulations.
This policy applies to all employees, officers, directors, agents, and any other individuals or entities acting on behalf of TradeSphere Ltd.

2. Definitions

  • Money Laundering: The process by which criminals attempt to conceal the origins of illegally obtained money, typically by passing it through complex sequences of banking transfers or commercial transactions.
  • Terrorist Financing: The provision of funds to individuals or groups who engage in terrorist activities, including through legal or illegal means.
  • KYC (Know Your Customer): A process that allows the company to verify the identity, suitability, and risks involved with maintaining a business relationship with a customer.

3. AML Program Structure

TradeSphere Ltd.’s AML program includes the following components:

  • Customer Due Diligence (CDD)
  • Enhanced Due Diligence (EDD)
  • Monitoring and Reporting
  • Record Keeping
  • Employee Training

3.1 Customer Due Diligence (CDD)
All customers must undergo CDD, which includes:

  • Identification Verification: Collecting and verifying personal information, such as name, date of birth, nationality, and proof of address.
  • Document Verification: Acceptable identification documents include government-issued IDs (passport, national ID card) and recent utility bills or bank statements as proof of address.
  • Risk Assessment: Assess each customer’s risk level based on factors such as geography, business type, and transaction history.

3.2 Enhanced Due Diligence (EDD)
For higher-risk customers, additional due diligence is required, including:

  • Source of Funds: Verifying the source of funds to ensure they are legitimate.
    Enhanced Monitoring: Closely monitoring transactions for any suspicious activity.
  • Senior Management Approval: Approval from senior management before onboarding or continuing a relationship with high-risk customers.

4. Ongoing Monitoring and Reporting
TradeSphere Ltd. will monitor customer transactions to identify unusual or suspicious activities. This includes:
Real-Time Transaction Monitoring: Implementing a system to monitor transactions in real-time to identify patterns of suspicious behavior.
Suspicious Activity Reports (SARs): Filing SARs to the Financial Intelligence Unit (FIU) of Mauritius within a specified timeframe.
Threshold-Based Reporting: Reporting transactions that exceed a certain threshold to relevant authorities, as mandated by Mauritian law.

5. Record Keeping
TradeSphere Ltd. will retain records of customer identification, account files, and business correspondence for at least five years after the end of the customer relationship. These records will be readily available to regulatory and enforcement authorities upon request.

6. Employee Training
All employees will receive training to understand AML and KYC procedures, recognize potential red flags, and report suspicious activities. Training will be conducted annually and updated as necessary to reflect changes in regulations and company policies.

7. Independent Audit
TradeSphere Ltd. will conduct regular independent audits to assess the effectiveness of its AML and KYC program. Audits will identify any weaknesses in the AML procedures, ensuring full compliance with the regulatory requirements of Mauritius.

8. Penalties and Disciplinary Measures
Employees who violate the AML and KYC policy may face disciplinary action, including termination and potential legal consequences. TradeSphere Ltd. is committed to maintaining the highest level of compliance and transparency and expects all employees to adhere to this policy.

9. Amendments to the Policy
This policy may be reviewed and amended periodically to reflect changes in regulatory requirements and industry best practices. Any significant amendments will be approved by the Board of Directors and communicated to all employees.

10. Approval and Acknowledgement
This AML and KYC policy is approved by the Board of Directors of TradeSphere Ltd. All employees, contractors, and third parties acting on behalf of the company are required to read, understand, and acknowledge this policy.