Anti-Money Laundering (AML) Policy
1. Introduction
1.1 Genesis FX Markets Ltd (referred to as “the Brokerage,” “we,” or “us”) is committed to preventing money laundering and complying with applicable laws and regulations related to anti-money laundering efforts. This Anti-Money Laundering (AML) Policy outlines our measures to detect, prevent, and report suspicious activities, as well as the client identification and verification procedures we implement.
2. Legal and Regulatory Framework
2.1 The Brokerage operates in accordance with the anti-money laundering laws, regulations, and guidelines of the jurisdictions in which we operate. We are committed to upholding the highest standards of integrity and complying with all relevant AML and counter-terrorism financing requirements.
3. Customer Due Diligence (CDD)
3.1 The Brokerage implements a risk-based approach to customer due diligence, which includes identifying and verifying the identity of our clients before establishing a business relationship or conducting transactions. The level of due diligence may vary based on the risk assessment of the client, transaction, and jurisdiction involved.
3.2 Client identification information may include, but is not limited to, full legal name, residential address, date of birth, nationality, government-issued identification documents, and contact details. We may also collect additional information and supporting documents as necessary to meet our AML obligations.
3.3 The Brokerage conducts ongoing monitoring of client accounts and transactions to detect and report any suspicious activities or unusual patterns that may indicate potential money laundering or terrorist financing.
4. Enhanced Due Diligence (EDD)
4.1 Enhanced due diligence measures are implemented for high-risk clients, countries, or transactions, as determined by our risk assessment processes. These measures may include obtaining additional information, conducting additional verification steps, and performing enhanced monitoring of the client relationship.
4.2 Politically Exposed Persons (PEPs) and individuals or entities associated with high-risk jurisdictions are subject to enhanced due diligence procedures to mitigate the increased risk of money laundering or corruption.
5. Suspicious Activity Monitoring and Reporting
5.1 The Brokerage maintains robust systems and controls to monitor client transactions, account activities, and other relevant data for the purpose of identifying and investigating suspicious activities.
5.2 If we identify any transactions or activities that raise suspicions of money laundering, terrorist financing, or other illegal activities, we will promptly report such activities to the appropriate regulatory authorities as required by law.
6. Record-Keeping
6.1 The Brokerage maintains comprehensive records of client identification information, transaction details, and relevant supporting documents in accordance with applicable AML laws and regulations. These records are securely stored and maintained for the required retention period as determined by the applicable jurisdiction.
7. Staff Training and Awareness
7.1 The Brokerage provides regular training and awareness programs to our employees to ensure they understand their AML obligations and are equipped to detect, prevent, and report suspicious activities. Staff members are trained on customer due diligence procedures, recognizing red flags, and the importance of maintaining confidentiality and reporting obligations.
8. Compliance Officer
8.1 The Brokerage appoints a designated compliance officer responsible for overseeing the implementation of the AML program, ensuring compliance with relevant laws and regulations, and addressing any AML-related concerns or issues.
9. Cooperation with Regulatory Authorities
9.1 The Brokerage cooperates fully with regulatory authorities, law enforcement agencies, and other competent authorities in their efforts to combat money laundering and terrorist financing. We provide necessary information and assistance in response to lawful requests and inquiries from these authorities.
10. AML Policy Updates
10.1 The Brokerage regularly reviews and updates its AML Policy to reflect changes in laws, regulations, and best practices. Any updates will be communicated to our employees, clients, and relevant stakeholders.
11. Risk Assessment
11.1 The Brokerage conducts regular risk assessments to identify, assess, and mitigate the money laundering and terrorist financing risks associated with our business activities. These assessments consider factors such as client types, geographical locations, transaction volumes, and emerging money laundering trends.
12. Know Your Customer (KYC) Procedures
12.1 The Brokerage has implemented robust Know Your Customer (KYC) procedures to ensure the identification and verification of clients’ identities and assess their suitability for the services offered.
13. Transaction Monitoring Systems
13.1 The Brokerage utilizes advanced transaction monitoring systems to detect and analyze patterns of suspicious activities and unusual transactions. These systems employ algorithms and filters to identify potentially high-risk transactions for further investigation.
14. Politically Exposed Persons (PEPs)
14.1 The Brokerage has implemented specific procedures to identify and conduct enhanced due diligence on Politically Exposed Persons (PEPs), as defined by relevant AML regulations.
15. Training and Awareness Programs
15.1 The Brokerage provides comprehensive and ongoing training programs to employees to ensure a high level of awareness and understanding of AML regulations, policies, procedures, and their individual responsibilities.
16. Compliance Monitoring and Independent Audit
16.1 The Brokerage maintains an internal compliance monitoring program to assess the effectiveness of our AML policies, procedures, and controls. Regular internal reviews and audits are conducted to ensure compliance with applicable AML regulations and identify areas for improvement.
17. Reporting Channels and Whistleblower Protection
17.1 The Brokerage provides secure and confidential channels for employees and other stakeholders to report any concerns, suspicions, or potential breaches of the AML Policy.
18. Sanctions Compliance
18.1 The Brokerage is committed to complying with applicable economic and trade sanctions laws and regulations.
19. Cooperation with Financial Intelligence Units (FIUs)
19.1 The Brokerage cooperates with Financial Intelligence Units (FIUs) and other regulatory authorities by promptly and effectively reporting any suspicious transactions or activities as required by law.
20. Third-Party Relationships
20.1 The Brokerage maintains a risk-based approach to managing relationships with third-party service providers.
21. Compliance with Customer Sanctions
21.1 The Brokerage maintains procedures to ensure compliance with customer sanctions.
22. Suspicious Activity Reporting (SAR)
22.1 The Brokerage has procedures in place to identify and report suspicious activities to the appropriate authorities in a timely manner.
23. AML Governance and Oversight
23.1 The Brokerage maintains a governance framework that includes senior management oversight of AML policies, procedures, and controls.
24. Periodic Review and Updating of the AML Policy
24.1 The Brokerage conducts periodic reviews of the AML Policy to ensure its continued effectiveness and relevance.
25. AML Policy Acknowledgment
25.1 Clients are required to acknowledge and accept the terms and requirements of the AML Policy as part of the onboarding process.
26. Contact Information
26.1 If you have any questions, concerns, or require further information regarding our AML Policy or related matters, please contact our designated compliance officer at support@genesisfxmarkets.com