Anti-Money Laundering Policy

1. General Background : Money laundering is the process by which people try to conceal illicit funds or otherwise enter into transactions to make these funds appear legitimate.

• Money laundering liability can arise through knowing of, or willfully blinding oneself to, transactions involving the proceeds of a wide-range of criminal activity. In addition, the UAE money laundering laws make it a serious offense to transmit money into or out of the UAE with the intent of promoting criminal activity, including criminal activity that violates the laws of a the land.
• Violation of UAE or foreign country money laundering laws can result in serious criminal penalties for entities and individuals; forfeiture of funds or assets, including funds received or assets acquired for actual services rendered. Even an allegation of money laundering would associate company, or an individual associated with a company having serious criminal activity and cause significant harm to company’s reputation and damage to company’s business.

2. Policy Details

In order to avoid money laundering and terrorist financing risks, all company personnel must at all times be sensitive to anything that suggests that any of company’s customers or counterparties: (1) may not be legitimate businesses or otherwise not engaged in legitimate business activity; (2) may be paying company, or others with funds from illegitimate sources; and (3) are evidencing irregular or unusual activities that might suggest illegal conduct is taking place.

The level of scrutiny for any particular customer or counterparty will turn on a number of factors, including the size and complexity of the transaction where it will take place.

We understand that we often have limited visibility into any given transaction. We also understand that in many cases, the legitimacy of the customer or counterparty will be clear. Nevertheless, employees are expected to always be alert for warning signs, including the Red Flags described in herein.

If any of these red flags – or anything else that calls into question the legitimacy of the customer or counterparty – are present, raise the matter with the Legal counsel responsible for your business, management or to the HR department.

Red flags must be evaluated with common sense and in the context in which they arise. What may be unusual in one part of company’s business in a particular region or with a particular asset, may be perfectly normal in a different part of the business or region. The key is to notice signs of irregular activity that lack commercial justification or rationale. We must also be particularly sensitive to transactions in which funds originate from or are destined for high-risk regions or countries (embargo countries), particular those known for drug-trafficking, public corruption, and other unlawful activity.

Regardless of any assumed innocent explanation, the potential concern must be addressed before company enters into or facilitates the relationship with the customer or counterparty. In many cases, further diligence can address the concerns and the relationship can proceed.

Failure to comply with this policy, or any other company policy relating to the subject matter addressed herein, may be grounds for termination or other disciplinary action.

Red Flags:

• Cash transactions in high risk markets
• Cash transactions in multiple currencies
• A series of complicated transfers of funds from one person to another as a means to hide the source and intended use of the funds.
• Transactions which are inconsistent with the account’s normal activity.
• Deposits were structured below the reporting requirements to avoid detection.
• No business rationale or economic justification for the transaction.
• Unusual cash activity in foreign bank accounts.
• Use of multiple, foreign bank accounts.

Behavioural Indicators:

• The parties to the transaction (owner, beneficiary, etc.) are from countries known to support terrorist activities and organizations or other illicit activities.
• Use of false corporations, including shell-companies.
• Inclusion of the individual in the United Nations 1267 Sanctions list. https://www.un.org/sc/suborg/en/sanctions/1267/aq_sanctions_list
• Media reports that the account holder is linked to known terrorist organizations or is engaged in terrorist activities.
• Beneficial owner of the account not properly identified.
• Use of nominees, trusts, family member or third party accounts.
• Use of false identification.
• Abuse of non-profit organization.

Objective

This Policy sets out the standards and procedures that the Company shall adopt in order to comply with the Mwali International Services Authority (MISA) regulatory framework, UAE applicable laws (if operational linkages exist), and Financial Action Task Force (FATF) Recommendations.

The purpose is to:

• Protect the Company against misuse for money laundering, terrorist financing, fraud, or sanctions evasion.
• Ensure transparent, fair, and compliant operations through the payment gateway mode.
• Safeguard the integrity of the global financial system.

Scope

This Policy applies to:

• All forex trading clients of the Company.
• All transactions processed through payment gateways, including deposits, withdrawals, and transfers.
• All employees, directors, and third-party partners (agents, payment processors, introducers).

3. Regulatory Framework Reference

The Policy is anchored on:

• MISA Regulations on international services and financial institutions.
• FATF 40 Recommendations, particularly regarding customer due diligence (CDD), record-keeping, suspicious transaction reporting, and beneficial ownership transparency.
• Payment gateway regulations of relevant jurisdictions where the Company integrates services.
• Clients are screened against, UN Sanctions List, OFAC (US Treasury), EU and UK Sanctions Lists and Other watchlists (Interpol, PEPs, high-risk jurisdictions. Accounts matching any restricted list are blocked and reported.

Key Compliance Obligations

4.1. Customer Due Diligence (CDD) / Know Your Customer (KYC)

• Before onboarding:
  • Obtain and verify official identification (passport/national ID).
  • Verify residential address (utility bill/bank statement not older than 3 months).
  • Confirm source of funds and source of wealth (salary slips, bank statements, tax returns, or business ownership documents).
  • Screen against international sanctions lists (UN, EU, OFAC).
• Enhanced Due Diligence (EDD) applies to:
  • Politically Exposed Persons (PEPs).
  • Clients from high-risk jurisdictions (per FATF & MISA advisories).
  • Clients making unusually large or complex transactions.

4.2. Payment Gateway Transactions

• All client payments shall be routed exclusively through licensed, MISA-approved, or equivalent international payment gateways.
• No cash transactions shall be accepted.
• Third-party deposits/withdrawals (where payer ≠ trading account holder) are prohibited unless approved under strict compliance review.
• Gateways must provide transaction monitoring APIs that allow screening of suspicious flows in real time.

4.3. Record-Keeping

• Maintain client identification, payment gateway transaction logs, and trading activity records for minimum 5 years after the end of the business relationship.
• Records must be readily accessible to regulators, auditors, and law enforcement.

4.4. Transaction Monitoring & Reporting

• Monitor transactions using risk-based parameters (amount thresholds, frequency, geographical origin, mismatch between profile and activity).
• Flag and review transactions that:
  • Exceed USD 10,000 in a single transaction or cumulatively in 24 hours.
  • Originate from high-risk or sanctioned jurisdictions.
  • Show unusual trading/withdrawal activity inconsistent with client profile.
• File Suspicious Transaction Reports (STRs) to the competent Financial Intelligence Unit (FIU) in the jurisdiction where reporting is required (MISA, UAE FIU, or equivalent).

4.5. Beneficial Ownership Transparency

• Require disclosure of ultimate beneficial owners (UBOs) where accounts are opened by legal persons.
• Maintain updated registers accessible to MISA and relevant regulators.

4.6. Employee & Third-Party Obligations

• Require disclosure of ultimate beneficial owners (UBOs) where accounts are opened by legal persons.
• Appoint a Compliance Officer responsible for AML/CFT reporting and implementation.
• Conduct annual AML training for staff, especially onboarding and payments teams.
• Ensure third-party payment providers/partners are regulated entities with adequate AML controls.

5. Prohibited Activities

The Company strictly prohibits:

• Use of accounts for money laundering or layering transactions.
• Acceptance of anonymous/prepaid cards, cryptocurrency, or non-traceable instruments through the payment gateway (unless expressly regulated).
• Structuring/smurfing transactions to avoid thresholds.
• Trading accounts used for transfers unrelated to genuine forex activities.

6. Data Protection & Confidentiality

• All client data shall be handled under strict data protection standards (ISO 27001 principles).
• Confidentiality is maintained, except where disclosures are legally required to regulators or FIUs.

7. Sanctions & Enforcement

• Non-compliance by employees will result in disciplinary action, termination, or referral to authorities.
• Counterparties or payment partners failing compliance checks will have agreements terminated.
• The Company may freeze accounts and suspend withdrawals pending regulatory clearance in case of suspected violations.

8. Review & Audit

• This Policy will be reviewed annually by management and compliance teams in line with updates to MISA regulations, FATF standards, and payment gateway rules.
• Independent compliance audits will be carried out at least once every two years.
• Regular audits of AML procedures, Internal policy reviews at least annually, AMLCO reports directly to senior management
• All relevant staff must complete, AML/CTF training during onboarding. Ad-hoc training in response to new threats or regulations

9. Acknowledgement

All employees and contractors must sign anAcknowledgement of Policy Compliance confirming they understand and will adhere to this Policy.

Signed:

Compliance Officer – Wongaa FX

Date: 01-09-2025