AML/CFT Compliance Summary

At FX Master Limited, we are committed to maintaining the highest standards of security, integrity, and regulatory compliance. Our operations are fully aligned with the UK’s legal and regulatory framework, including the Proceeds of Crime Act 2002 (POCA), the Terrorism Act 2000, and the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017). These laws require us to implement comprehensive procedures to prevent the use of our services for illegal activities, such as money laundering (ML) and the financing of terrorism (CFT). 

Our robust Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) policies are designed to protect our clients, our services, and the financial system. This summary outlines how we collect, verify, and protect your information while ensuring compliance with AML/CFT regulations in the UK. 

Why We Collect Your Information 

As part of our dedication to regulatory compliance and risk management, we apply thorough due diligence procedures. These procedures are essential for verifying the legitimacy of our clients and preventing misuse of our services for illegal activities. By collecting and verifying your personal and business information, we can: 

• Confirm your identity and ensure your legitimacy. 

• Prevent and detect financial crimes such as money laundering and terrorism financing. 

• Comply with local and international regulations aimed at safeguarding the financial system. 

• Uphold the highest standards of transparency, integrity, and security in our financial operations. 

What Information Do We Collect? 

FX Master Limited may collect the following personal and business information during the client onboarding process. The specifics vary depending on whether you are an individual or a corporate client: 

For Individual Clients: 

• Full Name, Date of Birth, and Place of Birth. 

• Official Identification Number (e.g., passport, national ID, or residency card). 

• Nationality and any additional citizenships held. 

• Residential Address and proof of address (e.g., utility bills, bank statements). 

• Whether you are a Politically Exposed Person (PEP) or have close associations with a PEP. 

• Source of Funds and Source of Wealth—especially if the client is involved in significant or unusual transactions. 

For Corporate Clients: 

• Full Company Name, Legal Form, and Company Registration Number. 

• Business Address and headquarters. 

• Details of Directors and Legal Representatives. 

• Identification of the Ultimate Beneficial Owners (UBOs), i.e., individuals who control or own the company. 

• Company Structure, including shareholding, management, and operational hierarchy. 

• Nature of the company’s Business Activities and Scope of Operations. 

• Expected Volume of Transactions and any Licenses, Certifications, or Registrations relevant to the business. 

How We Verify Your Information 

We conduct rigorous verification processes to ensure that the information provided is reliable and accurate. This includes the following steps: 

1. Verification of Documents: We validate official documents like passports, IDs, corporate certificates, and proof of address. 

1. Cross-Referencing Registries: For corporate clients, we check public registries, commercial databases, and company filings to verify company legitimacy and confirm the identities of beneficial owners. 

1. Enhanced Due Diligence (EDD): If a client is deemed high-risk—such as being a PEP or engaging in complex or high-value transactions—we apply additional due diligence measures. These may include more detailed financial records, legal agreements, or a deeper investigation into the source of funds. 

When We Apply Enhanced Due Diligence (EDD) 

EDD is triggered in cases where there is an increased risk of money laundering or terrorism financing. Such cases include: 

• High-Risk Sectors: Clients involved in high-risk industries, such as crypto-assets, cash-intensive businesses, or other high-risk sectors. 

• High-Risk Jurisdictions: Clients operating in jurisdictions that are flagged by UK or international regulatory authorities as having inadequate AML/CFT controls. 

• Politically Exposed Persons (PEPs): Clients who are PEPs or have close associations with PEPs, which require additional scrutiny due to the potential for corruption or abuse of power. 

• Complex Transactions: Transactions that appear unusual, lack a clear economic or legal purpose, or involve large sums of money with no obvious source. 

In these cases, we may request additional supporting documentation, such as: 

• Detailed proof of the Source of Funds. 

• Financial Statements or Legal Agreements to clarify business activities. 

Who We Will Not Onboard 

In accordance with our strict AML/CFT compliance policies, FX Master Limited reserves the right to refuse the onboarding of clients under the following circumstances: 

• Identity Verification Failures: If we are unable to verify the identity of a client, beneficial owner, or key individual involved in the business, we will not onboard them. 

• Involvement in High-Risk Activities: Clients associated with high-risk activities, jurisdictions, or industries that pose significant risks for money laundering or terrorism financing will be denied onboarding. 

• Politically Exposed Persons (PEPs): While we may onboard PEPs, these clients will be subject to Enhanced Due Diligence. If we deem the risks too high, we may refuse onboarding. 

• Suspicious or Unlawful Activities: Any client suspected of engaging in illegal activities such as fraud, tax evasion, money laundering, or terrorism financing will not be onboarded. 

• Sanctions Lists: Clients who appear on official sanctions lists or are required by law to have their assets frozen will not be accepted. This includes individuals or entities that are subject to financial sanctions or other restrictive measures. 

• Conflicting Information: If discrepancies are found between the information provided by the client and the data available in official registries or databases, we will not proceed with onboarding until these issues are resolved. 

Why We Need This Process 

The identification and verification of clients are critical not only to comply with the law but also to protect all parties involved. By performing these procedures, we ensure that: 

• Your Interests are Protected: By confirming the identity and legitimacy of our clients, we help safeguard your financial interests and assets. 

• We Ensure Compliance: We comply with both UK and international laws aimed at preventing money laundering, terrorist financing, and other financial crimes. 

• A Secure Environment is Maintained: Our process helps maintain a trustworthy environment for all clients, ensuring that our services are used for legitimate and lawful purposes only. 

By working with FX Master Limited, you help us uphold the highest standards of integrity and compliance, ensuring the safety and security of the financial system and protecting against criminal activities.