Documents

Read the important documents that govern the use of our services and keep you safe.

AML / CTF Policy

1. General Provisions

Compliance with anti-money laundering, counter-terrorist financing, anti-fraud, sanctions compliance and other unlawful financial activity prevention requirements is a mandatory part of the Company’s internal policy.

The Company adheres to the principles of AML — Anti-Money Laundering, CTF — Counter-Terrorist Financing, as well as KYC — Know Your Customer procedures aimed at identifying clients, verifying their identity, assessing the source of funds and monitoring financial activity within the scope of the services provided.

The Company also follows a risk-based approach to compliance, meaning that the level of verification, monitoring and control applied to a client may vary depending on the nature of the client’s activities, geographic location, transaction patterns and overall risk profile. The Company seeks to maintain effective internal controls designed to prevent misuse of its services and to comply with applicable legal and regulatory requirements.

The Company does not permit the use of its services, trading accounts, payment infrastructure, investment products or any other services for:

money laundering;
terrorist financing;
concealing the illegal origin of capital;
conducting fraudulent transactions;
circumventing international sanctions;
using nominee or proxy persons;
transferring funds derived from criminal activity;
any other activity that contradicts applicable law and the Company’s internal rules.

The Company may implement internal procedures, automated monitoring systems and manual review processes to identify and prevent prohibited activities. Any attempt to misuse the Company’s services may result in immediate restrictions, enhanced review procedures or termination of the business relationship.

All employees, representatives, partners, agents and contractors of the Company are required to comply with this Policy and immediately report any transactions that may indicate illegal, suspicious or economically unjustified activity.

This document also governs certain aspects of the relationship between the Company and the client in connection with the use of additional financial services, including capital provision programs, co-financing programs, credit financing, trading credit facilities and other related services provided under separate agreements, appendices or contracts. Such relationships are treated separately from standard brokerage services and are governed by additional terms applicable alongside this Policy.

The Company regularly reviews and updates its AML/CTF framework to reflect changes in legislation, regulatory expectations, industry best practices and emerging financial crime risks.

2. Definition of Money Laundering

Money laundering is the process of giving a legal appearance to funds, assets or other financial instruments obtained as a result of unlawful activity.

As a rule, money laundering involves an attempt to conceal:

the actual source of capital;
the actual owner of the funds;
the economic purpose of the transaction;
the route of funds movement;
the connection between the funds and criminal or unlawful activity.

Money laundering is commonly described as a process consisting of several stages, including placement, layering and integration. During these stages, illicit funds may be introduced into the financial system, transferred through multiple transactions and ultimately reintroduced as seemingly legitimate assets.

The process of money laundering may include depositing funds into accounts, transferring them between different companies, using nominee persons, splitting payments, conducting fictitious transactions, performing false investment operations, using cryptocurrency transactions, as well as other methods of disguising the origin of capital.

Modern money laundering schemes may involve complex international structures, shell companies, offshore entities, digital assets, decentralized financial platforms and cross-border payment systems. The Company remains vigilant regarding evolving methods used to conceal the origin of funds.

3. Know Your Customer Policy — KYC

The Company applies KYC procedures to establish the identity of each client before the client is granted full access to the Company’s services.

The client is required to complete the verification procedure and provide accurate documents and information necessary to confirm their identity, residential address, financial status, source of funds and the nature of the intended activity.

The Company may use electronic verification tools, biometric verification technologies, database checks and other lawful methods to verify the authenticity of information provided by the client.

The Company has the right to request the following documents from the client:

passport or another identity document;
document confirming residential address;
bank statement;
documents confirming the source of funds;
documents confirming the source of wealth;
tax documents;
documents confirming employment or business activity;
corporate documents, if the client acts on behalf of a legal entity;
any other information necessary to conduct proper client due diligence.

The Company may request updated documents periodically or whenever circumstances indicate that previously provided information may no longer be accurate or sufficient.

The client undertakes to provide only accurate, current and complete information. Providing false, forged, incomplete or misleading documents may serve as grounds for refusal of service, restriction of operations, account closure and disclosure of information to competent authorities in cases provided for by law.

4. Client Due Diligence

The Company applies Due Diligence procedures to assess the client, their profile, financial conduct, source of funds and potential risks.

Client due diligence may include:

client identification;
verification of document authenticity;
verification of residential address;
analysis of the source of funds;
assessment of the client’s financial position;
screening the client against sanctions lists;
screening for Politically Exposed Person status — PEP;
checking adverse media and negative public information;
checking related persons, beneficiaries and representatives;
analysis of the purpose of account opening;
assessment of the expected transaction volume;
analysis of whether the client’s transactions correspond to their profile.

The Company may also evaluate the client’s business reputation, expected account activity, ownership structure and historical financial behavior where relevant.

The Company may apply standard, simplified or enhanced due diligence depending on the level of risk.

Enhanced Due Diligence may involve obtaining additional supporting documentation, conducting interviews, requesting independent confirmations from financial institutions or performing deeper analysis of the client’s financial background and business activities.

5. Client Risk Assessment

Each client of the Company is subject to an internal risk assessment.

When assessing risk, the Company may take into account:

the client’s country of residence;
the client’s citizenship;
the jurisdiction of incorporation of a legal entity;
the source of funds;
the client’s profession or business activity;
the expected volume of transactions;
the frequency of transactions;
the payment methods used;
the presence of cryptocurrency transfers;
the client’s connection with high-risk jurisdictions;
the presence of sanctions, political or reputational risks;
inconsistency between the client’s conduct and the declared financial profile.

Additional factors may include the complexity of ownership structures, involvement in cash-intensive industries, use of intermediaries and exposure to sectors historically associated with elevated financial crime risks.

Clients may be classified as low-risk, medium-risk or high-risk clients.

Risk classifications may be reviewed periodically and adjusted based on new information, transaction activity, regulatory developments or changes in the client’s circumstances.

With respect to high-risk clients, the Company has the right to apply additional verification measures, including requesting an extended package of documents, confirming the origin of capital, verifying beneficial owners, analysing banking transactions and conducting additional internal approval procedures.

6. Verification of Source of Funds

The Company has the right to request documents confirming the origin of funds used to fund a trading account, investment account or any other financial relationship with the Company.

Such documents may include:

income statement;
tax return;
bank statement;
property sale and purchase agreement;
documents confirming receipt of dividends;
documents confirming the sale of securities;
documents confirming business activity;
loan agreement;
inheritance documents;
documents confirming the sale of cryptocurrency;
other documents confirming the lawful origin of capital.

The Company may request additional explanations regarding the movement of funds, the economic rationale behind transactions and the relationship between the client’s declared income and actual financial activity.

Verification of source of funds is intended to ensure that assets used within the Company’s services originate from lawful and transparent sources and are consistent with the client’s profile.

The Company has the right to refuse to accept funds if the client cannot confirm their lawful origin or if the documents provided raise reasonable doubts.

7. Transaction Monitoring

The Company conducts ongoing monitoring of client transactions in order to identify suspicious, unusual or economically unjustified activity.

Monitoring may include:

analysis of transaction amounts;
analysis of transaction frequency;
analysis of the direction of funds movement;
analysis of payment methods;
comparison of transactions with the client’s profile;
monitoring of sudden changes in financial behaviour;
identification of payment splitting;
identification of transactions without an obvious economic purpose;
monitoring of transactions involving high-risk countries;
monitoring of transactions involving third parties;
monitoring of transactions involving cryptocurrency wallets;
identification of attempts to circumvent limits, verification procedures or the Company’s internal rules.

The Company may use automated monitoring systems, risk-scoring models and manual compliance reviews to identify potentially suspicious activity.

Monitoring is conducted on an ongoing basis throughout the duration of the business relationship and may include retrospective reviews of historical transactions where necessary.

The Company reserves the right to suspend, reject or additionally review any transaction if it shows signs of suspicious activity.

8. Suspicious Transactions

A transaction may be considered suspicious if it does not correspond to the client’s profile, has no obvious economic purpose, is associated with increased risk or raises reasonable doubts among the Company’s employees.

Signs of suspicious transactions may include:

the client’s refusal to provide documents;
provision of contradictory information;
use of third-party payment instruments;
attempt to fund an account from a third-party source;
attempt to withdraw funds to a third-party account;
splitting large payments into several smaller payments;
frequent deposits and withdrawals without trading activity;
unusually large transactions for the client’s profile;
use of high-risk jurisdictions;
use of cryptocurrency transfers without confirmation of the source of funds;
attempt to conceal the actual owner of the funds;
aggressive pressure on employees demanding that a transaction be processed without verification.

Additional indicators may include unusual transaction timing, rapid movement of funds through multiple accounts, inconsistent explanations regarding transaction purposes or attempts to avoid compliance procedures.

If a suspicious transaction is identified, the Company has the right to:

request additional documents;
suspend the transaction;
refuse to process the transaction;
restrict access to services;
close the trading account;
terminate the business relationship with the client;
transfer information to competent authorities if required by applicable law.

The Company may continue monitoring the client’s activity after a suspicious event has been identified and may apply enhanced controls where appropriate.

9. Prohibition of Third-Party Transactions

The Company does not accept funds from third parties unless otherwise previously approved and properly documented.

Account funding must be made only from a bank account, payment instrument, cryptocurrency wallet or other source belonging to the client.

This requirement is intended to reduce the risk of money laundering, fraud, identity misuse and unauthorized financial activity.

As a rule, withdrawals are made only to the same source from which the deposit was made, or to another verified account of the client after additional verification.

The Company may require documentary evidence confirming ownership of payment instruments before processing deposits or withdrawals.

The Company has the right to refuse withdrawal of funds to a third-party account if such a transaction contradicts the Company’s AML/KYC Policy or creates an increased risk.

10. Sanctions Screening

The Company does not provide services to persons, companies, organisations or jurisdictions subject to international sanctions if such service is prohibited by applicable legal requirements or the Company’s internal policy.

The Company has the right to screen clients, beneficial owners, representatives, counterparties and related persons against international sanctions lists.

Screening may be conducted before onboarding, during the business relationship and whenever new information becomes available.

The Company may rely on sanctions databases, regulatory publications and third-party compliance providers to identify sanctions-related risks.

If sanctions risk is identified, the Company has the right to refuse registration, suspend service, block transactions, close the account or take other measures in accordance with applicable requirements.

11. Politically Exposed Persons — PEP

The Company applies additional verification measures in relation to Politically Exposed Persons, members of their families and persons closely associated with them.

Politically Exposed Persons may include individuals who hold or have previously held important state, political, military, judicial or administrative positions.

PEP status does not automatically prevent a person from becoming a client; however, it may require enhanced scrutiny due to the increased risk of corruption, bribery or misuse of public office.

In relation to such clients, the Company has the right to request additional documents confirming the source of funds, source of wealth, nature of the business relationship and purpose of using the Company’s services.

The Company may also require senior management approval before establishing or continuing a business relationship with certain PEP clients.

12. Corporate Clients

If the client is a legal entity, the Company has the right to request documents necessary to establish the ownership structure, authority of representatives and ultimate beneficial owners.

Such documents may include:

constitutional documents;
certificate of incorporation;
documents relating to directors;
documents relating to shareholders;
register of beneficial owners;
powers of attorney;
corporate structure chart;
financial statements;
bank statements;
documents confirming the source of the company’s funds.

The Company may conduct additional verification of affiliated entities, parent companies, subsidiaries and controlling persons where necessary.

Particular attention may be given to complex ownership structures, offshore arrangements and entities operating in high-risk sectors or jurisdictions.

The Company has the right to refuse service to a legal entity if the ownership structure is not transparent, the beneficial owners are not disclosed or the company’s activity creates an increased AML risk.

13. Additional Financing Services, Capital Provision and Credit Obligations

In addition to standard brokerage services, the Company may provide clients with additional services related to the provision of trading capital, co-financing programs, credit financing, use of internal liquidity funds and other financial instruments governed by separate contracts, appendices or agreements.

The use of such services is carried out exclusively on the basis of a separate agreement between the Company and the client. The terms of such agreements are considered separately from the terms of brokerage services and may contain special provisions regarding the procedure for providing capital, allocation of risks, deadlines for fulfilment of obligations and mechanisms for termination of cooperation.

Such financing arrangements may involve additional compliance checks, financial assessments and suitability reviews before approval.

The Company is not entitled to arbitrarily debit the client’s funds, carry out transactions on the client’s balance unilaterally or dispose of the client’s own funds outside the scope of valid contracts, agreed procedures and applicable regulatory requirements.

If the client uses credit financing programs, co-financing programs or other forms of capital provision by the Company, termination of the respective obligations shall be carried out in the manner provided for by the separate agreement. As a rule, fulfilment of the client’s obligations under such agreements requires full coverage of the provided capital on a one-to-one basis through the deposit of the client’s own funds or by another method expressly provided for in the agreement.

Replacement of the provided capital means the client’s execution of a deposit transaction or a series of transactions sufficient to fully fulfil the obligations under the relevant agreement. After confirmation of fulfilment of the obligations, the Company has the right to consider the agreement fully performed and to prepare additional documents confirming completion of the relevant relationship between the parties.

Where provided for by a separate agreement and applicable internal procedures, after full fulfilment of obligations, an additional agreement may be executed regulating the procedure for withdrawal, return or write-off of previously provided credit capital from the brokerage account or other client records.

If the client initiates early termination of a credit agreement or requests its unilateral termination, the Company has the right to recalculate transactions carried out using the provided capital in accordance with the terms of the relevant agreement. In such cases, the procedure for allocating profit, losses, commissions, expenses and other financial results shall be determined exclusively by the terms of the separate agreement between the parties.

If a separate agreement provides for the transfer of profit obtained as a result of the use of the provided capital in favour of the Company’s credit fund or other internal financing funds, the client agrees to the application of such mechanism in the scope and manner established by the relevant agreement.

The parties separately acknowledge that mechanisms for fulfilling obligations through full replacement of credit capital and mechanisms for automatic completion of financing programs upon expiry of their term are independent methods of terminating obligations. Each of these mechanisms is governed by separate terms and applies depending on the nature of the financial product used.

Within the framework of separate financing programs, the Company may have the right to recover previously provided capital upon expiry of the agreement term or upon occurrence of other circumstances expressly provided for by the agreement. Such actions shall not be considered unilateral disposal of the client’s funds and shall be carried out exclusively within the limits of the obligations agreed by the parties.

The Company may maintain internal records, audits and compliance reviews relating to financing programs to ensure transparency, contractual compliance and proper risk management.

14. Client Obligations

The client undertakes to:

provide accurate and current information;
complete the verification procedure in a timely manner;
provide additional documents upon the Company’s request;
not use the Company’s services for unlawful purposes;
not transfer access to their account to third parties;
not use the account for transactions on behalf of other persons;
not attempt to circumvent the Company’s AML/KYC procedures;
immediately notify the Company of any change in personal data, address, status, source of income or other material circumstances.

The client is responsible for maintaining the security of account credentials and ensuring that unauthorized persons do not gain access to the account.

The client understands and agrees that refusal to provide documents or information may result in restriction of transactions, suspension of service or account closure.

15. Obligations of the Company’s Employees

All employees of the Company are required to comply with this AML/CTF Policy.

Employees are required to:

verify client documents within the scope of their authority;
record suspicious indicators;
report suspicious activity to the responsible officer;
not process transactions that raise reasonable doubts;
not assist clients in circumventing verification procedures;
maintain confidentiality of internal investigations;
complete training on AML/KYC procedures;
act in accordance with the Company’s internal instructions.

Employees may be required to participate in periodic compliance training, testing and certification programs designed to maintain awareness of financial crime risks.

Violation of the AML/CTF Policy by an employee may result in disciplinary measures, termination of cooperation, as well as transfer of information to competent authorities if required by law.

16. Data Retention

The Company stores client documents, information and transaction history for the period required by applicable law and the Company’s internal rules.

Such data may include:

identity documents;
documents confirming address;
documents confirming the source of funds;
deposit and withdrawal history;
trading transaction history;
correspondence with the client;
results of internal verification;
records and reports on suspicious transactions.

The Company may retain records in electronic, digital or physical form, provided that appropriate security measures are maintained.

The Company takes reasonable technical and organisational measures to protect client data against unauthorised access, loss, alteration or unlawful disclosure.

Regular security reviews, access controls and data protection procedures may be implemented to safeguard confidential information.

17. Right to Refuse Service

The Company reserves the right to refuse a client account opening, transaction processing or further service if:

the client has not completed the KYC procedure;
the client refuses to provide documents;
the client’s documents raise doubts;
the source of funds has not been confirmed;
the transaction shows signs of suspicious activity;
the client is associated with sanctions risks;
the client attempts to use the Company’s services for unlawful purposes;
the Company cannot complete the Due Diligence procedure;
servicing the client contradicts the Company’s internal policy or applicable law.

The Company may exercise this right at any stage of the relationship, including before onboarding, during account operation or during transaction processing.

The Company is not obliged to disclose all details of its internal review to the client if such disclosure may violate legal requirements, internal security procedures or create a risk of circumvention of AML/CTF controls.

18. Updating Client Information

The Company has the right to periodically request updated documents and information from the client.

Data updating may be required in the following cases:

expiry of documents;
change of residential address;
change of citizenship or tax status;
change of source of.