(AML & CFT) Policy

1. Purpose

This Anti-Money Laundering and Counter Financing of Terrorism Policy (“AML/CFT Policy”) establishes the framework adopted by VelmoraTrade (“Company”, “we”, “us”, or “our”) to prevent, detect, and report money laundering, terrorist financing, and other illicit financial activities.

The Company is committed to complying with international AML/CFT standards and regulatory principles aligned with the Financial Services Commission Mauritius.

2. Scope

This Policy applies to:

• All clients of the Company
• All transactions conducted through the Platform
• All employees, contractors, and associated partners

3. Risk-Based Approach

VelmoraTrade applies a risk-based approach (RBA) to identify, assess, and mitigate risks related to money laundering and terrorist financing.

Risk factors include:

• Client profile and jurisdiction
• Transaction patterns
• Payment methods (fiat or cryptocurrency)
• Trading behavior

4. Customer Due Diligence (CDD)

The Company conducts Customer Due Diligence (CDD) before establishing a business relationship.

4.1 Standard CDD Requirements

Clients must provide:

• Full legal name
• Date of birth
• Nationality
• Residential address
• Government-issued identification
• Proof of address

4.2 Verification

• Identity documents must be valid and verifiable
• The Company may use third-party verification providers

4.3 Ongoing CDD

CDD is not a one-time process. The Company will:

• Periodically review client information
• Update records when necessary
• Monitor account activity

5. Enhanced Due Diligence (EDD)

Enhanced Due Diligence (EDD) is applied in higher-risk situations.

EDD applies to:

• High-risk jurisdictions
• Politically Exposed Persons (PEPs)
• Unusual or large transactions
• Clients with complex ownership structures

EDD Measures include:

• Additional identity verification
• Source of funds and source of wealth verification
• Increased transaction monitoring
• Senior management approval before onboarding

6. Simplified Due Diligence (SDD)

Where permitted, simplified due diligence may be applied to low-risk clients.

However, VelmoraTrade reserves the right to apply full CDD or EDD at its discretion.

7. Ongoing Monitoring and Transaction Surveillance

The Company continuously monitors client activity to detect suspicious behavior.

Monitoring includes:

• Unusual deposit or withdrawal patterns
• Rapid movement of funds without trading activity
• Abnormal trading behavior inconsistent with client profile
• Multiple accounts or linked accounts

8. Deposits and Withdrawals Policy (AML Control)

To prevent financial crime, VelmoraTrade enforces strict deposit and withdrawal controls:

8.1 Source of Funds

• Clients must use payment methods registered in their own name
• The Company may request proof of source of funds at any time

8.2 Same Method Principle

• Withdrawals should be processed via the same method used for deposits, where feasible
• If not possible, alternative methods may be used subject to additional verification

8.3 Third-Party Transactions

• Third-party deposits or withdrawals are strictly prohibited
• Funds will not be accepted from or transferred to accounts not belonging to the Client

8.4 Crypto Transactions (if applicable)

• Wallet ownership may be verified
• Blockchain tracing tools may be used to assess risk

9. Suspicious Activity Reporting (SAR)

The Company shall report suspicious activities to relevant authorities where required.

Suspicious activities may include:

• Attempts to conceal identity
• Unusual transaction patterns
• Structuring or layering of funds
• Use of multiple accounts

The Company reserves the right to:

• Delay transactions
• Freeze accounts
• Terminate relationships

10. Record Keeping

The Company maintains records of:

• Client identification documents
• Transaction history
• AML investigations

Records are retained for a minimum period as required by applicable laws (typically 5–7 years).

11. Sanctions Compliance

The Company complies with international sanctions lists, including but not limited to:

• UN sanctions
• EU sanctions
• OFAC lists

Clients appearing on sanctions lists will be denied access and reported where necessary.

12. Employee Training and Internal Controls

• Staff are trained in AML/CFT procedures
• Internal controls are implemented to detect risks
• Compliance oversight is maintained

13. Refusal and Termination

The Company reserves the right to:

• Refuse onboarding of any Client
• Suspend or terminate accounts
• Reject or reverse transactions

If AML/CFT concerns arise.

14. Data Protection and Confidentiality

All AML-related data is handled in accordance with the Company’s Privacy Policy.

Information may be shared with authorities where legally required.

15. Policy Updates

VelmoraTrade reserves the right to amend this AML/CFT Policy at any time.

Continued use of the Platform constitutes acceptance of any updates.