Anti-Money Laundering Policy

 

1 Introduction

1.1 The purpose of this document is to describe the Company’s policies and commitment
to the detection and prevention of any Money Laundering or Terrorist Financing
activity within the products and services it offers

2 Terms

“Money Laundering” is the participation in any transaction that seeks to conceal or
disguise the nature or origin of funds derived from illegal activities such as, but no limited
to, fraud, corruption, organized crime or terrorism. Predicate offences for Money
Laundering are defined by national law. The Money Laundering process consists of three
stages:
Stage 1: Placement. This stage refers to infusing cash delivered from any unlawful
activity to the financial system. This can be done by
a) Physically depositing cash into banks and non-bank financial institutions such as
currency exchanges;
b) Converting cash into other financial instruments such as by purchasing monetary
instruments (travelers’ checks, payment orders) or
c) Using cash to purchase high-value goods that can be resold. Launderers often
seek to deposit cash into banks in countries with fewer financial market
regulation demands and then transfer these funds to banks in regulated
environments, converting them “clean”. A frequent example of Placement is
Smurfing – a form of Placement where the launderer makes many small cash
deposits instead of a large one to evade local regulatory reporting requirements
applicable to cash transactions.
Stage 2: Layering: This stage refers to separating the proceeds of criminal activity from
their source through the use of layers of financial transactions such as multiple transfers
of funds among financial institutions, early surrender of an annuity without regard to
penalties, cash collateralized loans, etc. The layering aims to disguise the origin of the
funds, disrupt any audit trail, and provide anonymity. Launderers want to move funds
around, changing both the form of the funds and their location in order to make it more
complicated for law enforcement authorities to trace “dirty” money
Stage 3: Integration: This stage refers to placing the laundered proceeds back into the
economy in such a way that they re- enter and appear in the financial system as
legitimate funds. This Policy is supported by a set of programs covering the
implementation of the following areas:
d) The adoption of a risk-based approach;
e) Know Your Customer (KYC) Policy and Customer Due Diligence;
f) Customer activity monitoring;
g) Record Keeping.

3 Measures

3.1 The Company shall abide to the principles of Anti-Money Laundering and shall
enforce any measures to prevent any actions that aim or facilitate the process of
legalizing of illegally gained funds.
3.2 The Customer acknowledges that prevent of Money Laundering, the Company
neither accepts nor performs any payments in cash under any circumstances
3.3 In cases of an attempt to execute transactions which the Company suspects that
are related to Money Laundering or other criminal activity, it will proceed in
accordance with the applicable law and report suspicious activity to regulating
authority.
3.4 The Company reserves the right to suspend any Customer’s operation, which can
be regarded as illegal or may be related to Money Laundering in the opinion of its
employees. The Company has the right, in its discretion, to temporarily block the
suspicious Customer account or terminate an existing business relationship with a
customer.

4 Risk-based Approach

The identification of Money Laundering risks involving of Customers and transactions
allow the Company to determine and implement proportionate measures to control
and mitigate these risks. The Company separates risk based on three categories:
a) Country: In conjunction with other risk factors, it provides useful information as to
potential money laundering risks. Factors that may result in a determination that
a country poses a heightened risk include:
• Countries subject to sanctions, embargoes, or similar measures.
• Countries identified by the Financial Action Task Force (“FATF”) as
noncooperative in the fight against money laundering or identified by credible
sources as lacking appropriate money laundering laws and regulations.
• Countries identified by credible sources as providing funding or support for
terrorist activities.
b) Customer: There is no universal consensus as to which Customers pose a high risk,
but the below listed characteristics of Customers have been identified with
potentially heightened money laundering risks:
• Armament manufacturers.
• Cash intensive business.
• Unregulated charities and other unregulated “non-profit” organizations.
c) Services: Determining the money laundering risks of services should include a
consideration of such factors as services identified by regulators, governmental
authorities or other credible sources as being potentially high risk for money
laundering.

5 Know your Customer and Customer due diligence

5.1 The Company is an online operating brokerage company and therefore business
relationships between the company and its customers are not established on a
face-to-face basis. For Customer identification purposes the Company uses
electronic data brokers (linked with other in-house checks e.g., identifying duplicate
accounts, confirming ownership of bank accounts etc.) to verify the Customer’s
identity. This will be used to determine and document the true identity of Customers
to obtain background information the intended nature of their business with the
Company.
5.2 Upon the commencement of a business relationship between the two parties, the
Company shall request certain valid identification documentation from the
Customer such as Passport details, Driving license details and proof of residence
such as recent Utility bills (not older than six months). During the course of the
business relationship between the two parties, the Company can request additional
documentation or information from Customer to verify for additional verification or
updating existing verification.
5.3 The Company shall obtain and document any additional Customer information,
commensurate with the assessment of the money laundering risk using a Risk Based
Approach.
5.4 The Company shall identify whether the Customer is acting on behalf of another
natural person or legal entity as trustee, nominee, or professional intermediary. In
such case it is obligatory for the Customer to provide satisfactory evidence of the
identity of any intermediaries and of the persons upon whose behalf they are
acting, as well as the nature of the trust arrangements in place.
5.5 In all cases the Company shall apply due diligence measures in the following cases,
in order to comply with the applicable laws/regulations.

6 Customer activity monitoring

6.1 The Company, in addition to conducting initial Customer due diligence, continues
to monitor Customer activity to identify and prevent any suspicious (or fraudulent)
behavior. The monitoring system that was implemented relies on both automated
monitoring and, where appropriate, manual monitoring of transactions by the
Company’s employees and outsourced service providers. A series Anti-Money
Laundering Policy COREX FINANCING BROKER LLC (www.corexmarket.com) is incorporated in
the UAE with Business Identification Number 1182426  and has been
registered as Financial Services Provider on the 13/03/2023, with the Ministry of
Economy. Page 4 of status fields has been applied to Customer accounts indicating
their profile within the system, which assists automated monitoring.
6.2 The Company has implemented a regulatory and legally compliant suspicious
activity reporting process and procedure that will enable all employees to a report
to the Money Laundering Reporting Officer (MLRO) where they have reasonable
grounds to suspect that a person is engaged in money laundering or terrorist
financing. This process includes the following requirements:
a) All employees shall be diligent in monitoring for any unusual or suspicious
transactions/activity
b) The reporting of suspicious transactions/activity must comply with the
laws/regulations of the respective jurisdiction
c) The MLRO must be informed about all suspicious transaction/activity on a
monthly basis at least.

7 Record keeping

7.1 The Customer acknowledges that the Company shall keep records of:
a) All documents obtained for the purpose of Customer identification (KYC policy
requirements);
b) All transaction data and information;
c) Other information related to money laundering matters in accordance with the
applicable antimony Laundering laws/regulations. That includes files on
suspicious activity reports, documentation of AML account monitoring, etc.
7.2 The Company shall keep all Customer records and/or trading and non-trading
activity, current and/or past and/or archived for a minimum period of five years after
the termination of the business relationship with the Customer and as per applicable
legislative requirements