AML/CFT and KYC Policy

1. General

Xtrade Ltd (hereafter referred to as “Xtrade,” “we,” “us,” or “our”) acknowledges the harm caused by financial crimes and is dedicated to carrying out its operations with integrity while abiding by its legal, ethical, and social obligations to:

• Safeguard our clients, employees (both permanent and contract), and other business partners; and
• Support the efforts of authorities, regulators, and governments to prevent economic crime more broadly.

Any intentional violation of the laws and rules pertaining to financial crime (such as bribery, corruption, money laundering, terrorist financing, sanctions, tax evasion, or market abuse) that apply to our business activity is not tolerated by us.

We have a specific division within compliance called financial crime. By giving the company in its operating jurisdictions expert support and supervision, the financial crime function facilitates effective and efficient financial crime risk management.

2. Governance

The Chief Compliance Officer (CCO) is in charge of ensuring that the entire organization complies with all obligations and laws related to AML and financial crime in the countries where operations are conducted. Additionally, the CCO is in charge of developing and maintaining an AML program to identify, evaluate, track, and manage risks associated with money laundering, terrorist financing, and other related financial crime-related issues.

The relevant jurisdictions’ MLROs, who are in charge of setting up and maintaining efficient financial crime controls and carrying out day-to-day AML-related tasks, provide support to CCO.

3. Policies and Procedures

Our financial crime compliance policy framework addresses the following six important risk areas:

• Anti-money laundering & counter-terrorist financing (AML and CTF);
• Sanctions
• Anti-bribery & corruption (ABC);
• Anti-tax evasion (ATEF);
• Fraud; and
• Market abuse.

Our comprehensive approach to financial crime enables us to recognize and oversee pertinent connections and synergies among the major risk domains.

All staff members always have access to all policies and procedures. All regulations are also:

• Designed to make sure that every employee, company, and legal entity complies with extraterritorial obligations and pertinent laws that are applicable in the jurisdictions where we operate
• Approved by the board of directors
• Are put through an annual review cycle to make sure they’re effective, giving senior executive management the confidence they need in the framework for controlling financial crime.

4. Managing and Attenuating the Risks of Financial Crime

To reduce, recognize, and manage the risks of financial crime, we have created and put into place a comprehensive set of measures. These actions consist of:

• BWRA and AML risk evaluation
• A robust KYC procedure
• Staff training and awareness
• Controls over PEP and sanctions
• Preventing corruption and bribery
• Anti-fraud.

BWRA and AML Risk Evaluation

To determine the degree of risk exposure, we have implemented an ongoing Business Wide and AML Risk Analysis that takes into account all aspects of our business operations, including customers, goods, transactions, delivery methods, organizational structure, and the regions in which we conduct business. The findings of the analyses are used to create financial crime safeguards.

KYC Procedure

We have established and maintain risk-based identification, verification, and know your customer procedures for customers, including enhanced due diligence for those customers who present higher risk, such as:

• Politically exposed persons (PEPs)
• Clients from high-risk markets or industries.

The KYC process entails stringent identification requirements, name screening processes, ongoing relationship monitoring, and routine reviews of all current business relationships.

The KYC procedure entails not only knowing the clients and entities we work with or provide services to, but also the Ultimate Beneficial Owners, Legal Representatives, and Authorized Signatories as necessary.

Regular PEP and sanctions screening, in addition to periodic and trigger reviews, are all part of the ongoing monitoring process. Customers with high risk indicators are subject to annual periodic reviews, while those with medium risk are reviewed every three years. Material changes in a customer’s profile may start a trigger review.

Transaction Monitoring

Data analysis is a key component of our risk assessment and suspicious activity detection processes. A number of compliance-related tasks are carried out by these tools, including data collection, filtering, record-keeping, investigation management, and reporting.

With regard to AML/CTF risk, we:

• Monitor all transactions and reserve the right to report any suspicious transactions to the appropriate law enforcement
• In the case of suspicious transactions, ask customers to provide additional information and documents to prove the Source of Funds (SoF) and Source of Wealth (SoW)
• When there is a plausible suspicion that a customer is engaging in illegal activity, we suspend or terminate the customer’s account.

The aforementioned list is not all-inclusive, and the compliance function regularly examines customer transactions to determine whether they should be reported and handled as suspicious.

Staff Training and Awareness

We have put in place a thorough Financial Crime Compliance training program to make sure that every member of staff receives AML awareness training, especially those who are in charge of processing transactions, initiating, or establishing business relationships.

To ensure that employees are aware of the various patterns and techniques of money laundering that may occur in their daily work, the training is customized to the business. Additionally, training includes typologies to identify money laundering or financial crime activities as well as general duties resulting from applicable external (legal and regulatory), internal requirements and the resulting individual duties that must be adhered to in day-to-day business.

Sanctions Controls

We cross-reference all of our customers with the OFAC, EU, US, and UN sanction lists. The company’s sanctions controls are applied to both new and current clients, as well as to employees and outside service providers.

Anti-Bribery and Corruption (ABC) and Anti-Fraud

Any form of corruption, including paying bribes, is not acceptable. Any involvement in bribery or corruption on the part of our employees or third parties working on our behalf is strictly forbidden.

All employees go through ABC training, which is a component of financial crime compliance training and covers the standards for dealing with PEPs, laws governing gifts and entertainment, as well as charitable giving and professional courtesy.

Staff training on the topic of external fraud risk mitigation is one of the anti-fraud measures. Additionally, employees must take a set amount of time off from work each year to reduce the risk of internal fraud.

5. Country of Residence

Our risk tolerance with regard to onboarding clients is outlined in our AML/CTF Policy. Residents of nations considered to have a higher level of risk appetite are not eligible to become our clients. These consist of:

Afghanistan

Albania

Algeria

Angola

Bahamas

Bangladesh

Barbados

Belize

Bolivia

Bosnia and Herzegovina

Burkina Faso

Burundi

Cambodia

Cayman Islands

Central African Republic

Chad

Congo

Côte d’Ivoire

Crimea (Ukraine region)

Cuba

Democratic People’s Republic of Korea (DPRK)

Democratic Republic of the Congo

Ecuador

Egypt

Equatorial Guinea

Eritrea

Ethiopia

Ghana

Guinea

Guinea Bissau

Guyana

Haiti

Iceland

Iran

Iraq

Jamaica

Jordan

Kenya

Laos

Lebanon

Libya

Malaysia

Mali

Malta

Mauritius

Morocco

Mozambique

Myanmar

Nepal

Nicaragua

North Macedonia

Pakistan

Palestine State

Panama

Qatar

Seychelles

Saudi Arabia

Senegal

Somalia

South Africa

South Sudan

Sri Lanka

Sudan

Syria

Trinidad and Tobago

Tunisia

Uganda

Vanuatu

Venezuela

Yemen

Zimbabwe

Additionally, we do not accept any customers from disputed territories as they cannot provide official documents that are recognized by our company, such as:

Donetsk People’s Republic (DPR) 

Luhansk People’s Republic (LPR)

Pridnestrovian Moldavian Republic

Republic of Abkhazia

Republic of Somaliland

Republic of South Ossetia

Turkish Republic of Northern Cyprus

Republic of China (Taiwan)

Republic of Kosovo

Sahrawi Arab Democratic Republic

Republic of Artsakh