AML Policy

Anti Money Laundry Policy

The identification of a Politically Exposed Person (PEP)

You should under any circumstance declare your PEP (politically exposed person, hereinafter referred to as “PEP”) status by marking the field in the verification section of your profile in the “my profile” section of your trading account with us and provide copies of documents which can confirm your status. Additionally, you are obligated to declare your source of funds under any circumstance.

A PEP is or can be a natural person who is, was or has been entrusted with or related to public functions and shall include but not be limited to one of the following options:

a) Heads of a State, individuals with a governmental oriented role, (prime) ministers, deputy and / or assistant ministers;

b) Members of a parliament or of a similar legislative body;

c) Members of governing bodies or of political parties;

d) Members of (supreme) courts or of other high-level judicial organizations.

e) Members or employees of a court or of boards of central banks;

f) Ambassadors or other significantly ranked officers in armed forces;

g) Members of a administrative, management related or supervisory body of companies or enterprises which are state-owned;

h) Mayors or high ranked position holders within municipalities.

Family members include the following:

a) A spouse / the equivalent or a close family member of a PEP (including siblings or parents)

Persons which are known to be close to a PEP can mean:

a) An individual which is known for to have a joint beneficial ownership of a legal entity or any other significantly close business relation with a PEP;

b) An individual which holds the sole beneficiary ownership of a legal entity. An individual which is holding a position in the benefit of a PEP.

FX Capital – Go4rex is obliged by nature to refuse services to a PEP and shall return the deposited funds in case the PEP or close associate cannot explain the origin of deposit funds in a satisfying manner.

3 risk categories which are considered during a risk evaluation:

  • Your location / city / country of residence
  • One or several parameters which recognize a person who is related to a transaction
  • Your business activities of the person performing or related to the transaction

*Countries which, according to FATF, fail to comply with requirements in the prevention of money laundering / terrorism financing. The list of such can be found at:  http://www.fatf-gafi.org/countries/#high-risk

Once we evaluated the previously mentioned risks we will evaluate every risk category (on a scale of 1 to 3:

Low Exposure

No relevant risk factors in every category. The transaction is transparent and nothing has been detected compared to a regular transaction. There is no reason to suspect any form of money laundering or the treat of such.

Middle Exposure

Presence of one or more risk factors which differ from average transactions of a person conducting affairs in the sector but the transactions are still considered as regular. There is no real reason to suspect risk factors could or may, generally, lead to a threat of laundering money or financing of terrorism.

High Exposure

The presence of one significant or multiple significant threats in the category that provide no clear explanation of the source of funds. Significant presence risk of money laundering suspicion or terrorism financing suspicion is relevant. The Company hold the right to request additional documentation for the purpose of AML/KYC screening.

 

The maintenance and preservation of transaction records for a period of 5 years from termination of the contractual obligation towards the client

The constant training of our staff in order to recognize suspicious transactions related to money laundering or terrorism financing.