Anti-Money Laundering (AML) Policy

Document Control

Document Owner: ActivBrokers
Approval Date: 01/01/2018
Revisions/Changes: Initial version

Introduction
Money Laundering
Terrorist Financing
Policies and Procedures
Company Rights and Reporting
Additional Documentation and Termination

1. Introduction

ActivBrokers (hereinafter “the Company”) is a regulated financial services provider under the Financial Services Commission (FSC) of Mauritius. The Company is committed to implementing robust Anti-Money Laundering (AML) and Anti-Terrorist Financing measures by adhering to international standards and regulatory requirements.

2. Money Laundering

Money laundering refers to the process of disguising the origins of illicit funds, making them appear legitimate. It generally involves three stages:

Placement – Introducing illegally obtained funds into the financial system.
Layering – Creating complex layers of financial transactions to obscure the source of the funds.
Integration – Reintroducing the laundered funds into the economy, presenting them as legitimate assets.

3. Terrorist Financing

Terrorist financing involves providing funds to individuals or groups to support terrorist activities. ActivBrokers is vigilant against such activity and adheres to strict procedures to prevent the misuse of its services for these purposes.

4. Policies and Procedures

ActivBrokers has implemented several policies and procedures to prevent money laundering and terrorist financing, which include:

Client Identification and Due Diligence:
- Verifying the identity of clients through reliable documents, data, or information.
- Identifying the ultimate beneficial owner for legal entities, and taking reasonable steps to understand the client’s ownership and control structure.
- Assessing the purpose and nature of the business relationship to gauge potential risk levels.
Record Keeping:
- Maintaining records of client identity, transaction history, and ongoing monitoring of client activities. This includes keeping information up-to-date and verifying the consistency of transactions with the client’s risk profile.
Internal Reporting Procedures:
- Appointing an Anti-Money Laundering Compliance Officer (AMLCO) to receive and review reports of suspicious activity.
Internal Controls and Risk Management:
- Implementing robust internal controls and risk management practices to mitigate money laundering and terrorist financing risks.
Transaction Monitoring:
- Scrutinizing complex or unusually large transactions that may indicate money laundering or other illegal activities, especially transactions lacking an obvious financial or legal purpose.
Employee Awareness and Training:
- Training employees to identify and report potential money laundering activities and comply with AML regulations.

5. Company Rights and Reporting

ActivBrokers reserves the following rights:

Client Verification:
- The Company may require proof of identity from clients before opening accounts or processing transactions.
Information Sharing with Authorities:
- ActivBrokers may disclose client information to regulatory authorities in Mauritius or other relevant jurisdictions as part of its AML obligations.
Transaction Refusal and Account Termination:
- The Company reserves the right to reject fund transfers or terminate accounts if it suspects connections to illegal activity.
Suspicious Transaction Reporting:
- ActivBrokers is legally obligated to report any suspicious transactions and is prohibited from informing clients if they have been reported.

The Company will not conduct business with clients whose funds are suspected to be derived from criminal activity.

6. Additional Documentation and Termination

ActivBrokers may require clients to submit additional documentation as part of its ongoing AML compliance process. If a client fails to provide requested information or is found in breach of AML standards, the Company reserves the right to terminate the business relationship. The Company also reserves the right to amend this policy to meet regulatory requirements or address evolving risks.

This Anti-Money Laundering Policy is designed to ensure that ActivBrokers remains compliant with regulatory standards and upholds a safe, transparent trading environment. For any questions or further information, clients may contact the ActivBrokers support team.

AML Policy