Anti Money Laundering Policy

Scope of Policy

This Anti-Money Laundering (AML) Policy is applicable to all officers, employees, agents, appointed producers, and all products and services offered by Ultratrend FX Capital Limited (hereafter referred to as the "Company"). The provisions of this Policy apply uniformly across all business units, branches, subsidiaries, and other locations operated by the Company, without limitation to their specific functions or geographical locations.

The Company recognizes the inherent risks associated with money laundering and terrorist financing and is committed to preventing and detecting such activities through the implementation of a comprehensive risk-based approach. Accordingly, all employees, officers, appointed producers, and affiliates are required to adhere to the policies, procedures, and guidelines set forth herein. This Policy mandates a coordinated, company-wide effort to combat money laundering activities by maintaining appropriate systems and controls aimed at detecting suspicious transactions and mitigating associated risks.

Each business unit, department, and location within the Company has adopted and implemented internal controls and procedures tailored to their specific risks, ensuring compliance with all applicable anti-money laundering and counter-terrorist financing regulations. These procedures must be reasonably expected to prevent, detect, and report any suspicious transactions in accordance with the legal requirements set forth by relevant regulatory authorities.

All efforts to comply with anti-money laundering obligations will be thoroughly documented, and such records will be retained in accordance with the relevant legal retention periods. The Company further ensures that all personnel involved in the AML process will receive adequate training to support the detection, identification, and reporting of suspicious activity.

The Compliance Department is the designated body responsible for overseeing the implementation of the Policy and for taking action in cases where suspicious activity is identified. Specifically, the Committee is empowered to initiate Suspicious Activity Reports (SARs) or other necessary disclosures to appropriate law enforcement or regulatory bodies, as required by applicable law.

In the event that any law enforcement or regulatory agencies seek contact regarding AML matters or investigations, all such inquiries shall be directed exclusively to the Compliance Department. The Committee shall coordinate with legal and regulatory authorities as necessary to ensure full cooperation in the investigation of potential money laundering or related illegal activities.

This Policy is intended to serve as a binding document that ensures the Company’s commitment to preventing money laundering and ensuring compliance with all relevant laws and regulations governing the financial industry.

Responsibilities of the AML Compliance Department

The Compliance Department is entrusted with the critical responsibilities of overseeing and ensuring the effective implementation of the Anti-Money Laundering (AML) policies and procedures of Ultratrend FX Capital Limited (hereafter referred to as the "Company"). In this regard, the Department shall be specifically tasked with the following duties:

1. Receiving and Reviewing Internal Reports of Suspicious Activities: The AML Compliance Department shall receive and review all internal reports submitted by employees, officers, appointed producers, or any other personnel within the Company regarding suspicions of money laundering or any related illicit financial activities. These reports may pertain to any suspicious transactions, actions, or patterns that are believed to be indicative of money laundering, terrorist financing, or other financial crimes.
2. Investigating Reports of Suspicious Activity: Upon receipt of a report detailing suspected money laundering activities, the AML Compliance Department shall investigate the matter thoroughly and promptly. The investigation shall include a detailed review of relevant transactions, customer profiles, and any other pertinent information in order to determine whether the activity in question constitutes money laundering or any other illegal financial activity as defined under applicable laws and regulations.
3. Reporting Suspicious Activity to Relevant Authorities: If the AML Compliance Department’s investigation concludes that there is reasonable suspicion of money laundering, the Department is responsible for reporting the suspected activity to the relevant regulatory authorities or law enforcement agencies. This shall be done in compliance with all applicable legal requirements, including the submission of Suspicious Activity Reports (SARs) or other mandated disclosures. The Department shall ensure that these reports are submitted in a t imely manner and contain all necessary information to aid law enforcement or regulatory authorities in their investigations.
4. Ensuring Adequacy of Training and Awareness Programs: The AML Compliance Department shall ensure that appropriate arrangements are in place for the awareness and training of all employees, officers, appointed producers, and advisers. The Department will ensure that these individuals are sufficiently informed of the Company’s policies and procedures related to anti-money laundering, and that they are equipped to identify and report suspicious activities. The training programs must be designed to meet the needs of different levels within the organization and should be regularly updated to reflect changes in legal requirements, emerging risks, and best practices in the industry.
5. Annual Reporting to the Governing Body: The AML Compliance Department shall, at a minimum, report annually to the Company's governing body on the operation, effectiveness, and ongoing compliance of the Company’s anti-money laundering systems and controls. This report shall include an evaluation of the effectiveness of the Company’s existing AML procedures, identify any areas of concern or improvement, and propose any necessary changes to strengthen the Company’s AML framework. The report will also address the overall compliance posture of the Company, ensuring the governing body is fully informed of any significant developments.
6. Ongoing Monitoring of AML Policies: The AML Compliance Department shall continuously monitor the implementation and day-to-day operations of the Company’s anti-money laundering policies, ensuring that they remain effective and aligned with the evolving risk profile of the business. Specifically, the Department shall oversee the application of AML controls in relation to the following areas:
   • Development of New Products: The Department will review new products or services introduced by the Company to assess whether they pose any new money laundering risks, and ensure appropriate due diligence procedures are in place.
   • Onboarding of New Customers: The Department will oversee the customer due diligence (CDD) and enhanced due diligence (EDD) processes to ensure that appropriate AML screening and checks are conducted before establishing any new customer relationships.
   • Changes in the Company’s Business Profile: The Department shall continuously evaluate any significant changes in the Company’s business operations, market focus, or geographical footprint to determine whether such changes introduce any additional risks or require adjustments to the existing AML procedures.

In fulfilling these responsibilities, the AML Compliance Department shall act in accordance with the principles of diligence, integrity, and transparency, ensuring that the Company maintains the highest standards of compliance with anti-money laundering laws and regulations.

What is Money Laundering?

Money laundering refers to the process by which criminally obtained money or assets (referred to as “criminal property”) are exchanged for legitimate or "clean" money or assets, with no obvious link to their criminal origins. Criminal property can take many forms, including but not limited to cash, securities, tangible property, intangible property, and real estate. Additionally, money laundering also encompasses the use of money, regardless of its source, for the purposes of financing terrorism.

Money laundering activities include, but are not limited to, the following actions:

1. Acquiring, Using, or Possessing Criminal Property: Engaging in transactions or holding property derived from criminal conduct or illicit activities.
2. Handling the Proceeds of Crimes: Involvement in the management, movement, or handling of proceeds resulting from criminal offenses such as theft, fraud, or tax evasion.
3. Knowingly Involved with Criminal or Terrorist Property: Being complicit or knowingly involved in activities related to criminal or terrorist property.
4. Facilitating the Laundering of Criminal or Terrorist Property: Entering into arrangements or agreements that facilitate the laundering of criminal or terrorist funds or property.
5. Investing the Proceeds of Crimes in Financial Products: Using illicit funds to acquire or invest in legitimate financial products in order to obscure their illicit origin.
6. Investing Criminal Proceeds through the Acquisition of Property/Assets: Using criminal funds to acquire property or assets, thereby laundering the illicit funds.
7. Transferring Criminal Property: Facilitating or carrying out transfers of criminal property with the intention of removing it from the source of the criminal activity.

It is important to understand that money laundering can occur in various stages and forms, ranging from relatively simple actions such as the purchase and resale of luxury items (e.g., cars or jewellery) to more complex methods involving the movement of funds through a web of legitimate business operations. While cash transactions are often involved, the process of money laundering can extend to property of any form—whether money, rights, real estate, or any other benefit.

If an individual knows or suspects that property has been obtained, either directly or indirectly, through criminal activity, and fails to report such suspicions, they may themselves be implicated in the money laundering process.

The Stages of Money Laundering:

Money laundering typically follows a three-stage process:

1. Placement: The initial stage involves the introduction of criminally derived funds into the f inancial system. This may involve depositing illicit funds in
2. Layering: The funds are moved or transferred through a series of complex financial transactions designed to obscure the original source or ownership of the illicit funds. This stage seeks to make it difficult for authorities to trace the true origin of the funds.
3. Integration: At this stage, the illicit funds have been effectively "washed" and are integrated into the legitimate financial system. The criminals are then free to use the funds for legal or personal purposes, as the money appears to have been derived from legitimate sources.

Risks and Vulnerabilities in the Financial Sector:

No financial sector business, including the Company, is immune from the threat of money laundering. Firms must conduct thorough risk assessments to evaluate the money laundering risks posed by the products and services they offer. Such assessments help identify areas where the Company may be susceptible to criminal exploitation and ensure that appropriate safeguards are in place to mitigate these risks.

What is Counter-Terrorist Financing (CTF)?

Terrorist financing refers to the process through which legitimate businesses or individuals may provide funding to support terrorist organizations or activities, often for ideological, political, or other reasons. Unlike money laundering, terrorist financing may not always involve the proceeds of criminal conduct. Rather, it often centers on concealing the intended use or origin of funds, which will ultimately be used for criminal purposes such as terrorism.

The Company is committed to ensuring that:

• Its customers are not terrorist organizations or linked to terrorist activities.
• It does not provide the means or channels through which terrorist organizations may receive funding.

While terrorist financing may not necessarily involve the proceeds of crime, it is still illegal and presents a significant risk to national and international security. Thus, the Company must ensure it has appropriate measures in place to prevent its services from being used in any manner that could support or facilitate terrorism.

Definition of Money Laundering:

For the purposes of this Policy, money laundering is defined as any act or series of acts designed to conceal, disguise, or misrepresent the true origins of criminally obtained property (also referred to as criminal property), thereby making such property appear to be derived from legitimate sources or constituting legitimate assets. Money laundering involves the process of transforming illicit funds into assets that appear to have been acquired through legal means.

Policy Statement:

It is the policy of Ultratrend FX Capital Limited (hereinafter referred to as the "Company") to actively and diligently pursue the prevention of money laundering (ML) and any activities that facilitate money laundering or the financing of terrorist or other criminal activities. The Company is firmly committed to ensuring full compliance with all relevant Anti-Money Laundering (AML) laws and regulations and requires that all officers, employees, appointed producers, and associated individuals strictly adhere to the standards and procedures set forth in this Policy. This is to prevent the use of the Company’s products, services, or resources in connection with money laundering, the financing of terrorism, or any related illegal activities.

In line with its commitment to preventing money laundering and terrorist financing, Ultratrend FX Capital Limited has implemented comprehensive policies and procedures designed to detect, prevent, and report suspicious activities. All employees, officers, appointed producers, and agents must strictly adhere to these policies and actively cooperate in the identification and reporting of money laundering or terrorist financing activities. The Company will take all necessary steps to comply with the legal and regulatory requirements aimed at combating money laundering and the financing of terrorism.

Risk-Based Approach to Anti-Money Laundering (AML) Procedures

The Risk-Based Approach (RBA) is an integral aspect of the anti-money laundering (AML) framework at Ultratrend FX Capital Limited (the "Company"). Under this approach, the level of due diligence conducted on any individual customer or transaction is proportionate to the perceived risk that the relationship or activity presents in terms of potential money laundering or terrorist financing. This approach allows for the allocation of appropriate resources, ensuring that heightened due diligence is applied to higher-risk clients, products, services, or geographic locations, while minimizing unnecessary burdens on lower-risk relationships.

To effectively apply the Risk-Based Approach, the Company will assess various factors that may influence the level of risk associated with a customer, product, or business activity. These factors include, but are not limited to, customer risk, product risk, and country risk. The following outlines how these risk areas are evaluated and how they inform the due diligence process:

1. Customer Risk

The level of risk associated with a customer is determined by assessing their profile and the specific characteristics of the customer relationship. Customers who present higher levels of risk due to their behaviour, background, or source of funds will be subject to more stringent due diligence processes. Key factors to consider when evaluating customer risk include:

• Customer Profile: The risk level associated with a customer can vary depending on their personal or business background, the complexity of their financial activities, and their transaction patterns. A basic Know Your Customer (KYC) check helps establish a baseline risk level. For instance, a customer who is nearing retirement and regularly contributes small, predictable amounts to a savings account, consistent with their financial history, is considered to present a lower risk of money laundering. Conversely, a middle-aged customer making irregular, large, and variable payments that do not align with their documented financial standing is deemed to present a higher risk.
• Business and Corporate Structures: Corporate customers, especially those with complex ownership structures or international operations, may carry a higher risk. These structures can potentially be used by criminals to introduce layers within financial transactions, thus obscuring the true origin of illicit funds. The Company must assess the risk posed by such corporate entities by considering the transparency of their ownership structure, business activities, and the jurisdictions in which they operate.
• Categorization into Risk Bands: Based on the assessment of customer profiles, individuals or entities are categorized into different risk bands—low, medium, or high. Higher-risk customers are subject to enhanced due diligence (EDD), which may involve obtaining additional documentation, verifying the source of funds, or conducting more frequent monitoring of their transactions.

2. Product Risk

Product Risk refers to the inherent risk posed by the nature of the product or service itself in terms of its potential for facilitating money laundering activities. Certain financial products are more susceptible to misuse due to their characteristics, and these products carry higher risks.

Risk Categorization by Product Type: Financial products are categorized into three risk bands based on their vulnerability to money laundering or terrorist financing as follows.

• Reduced Risk Products These are simple, transparent products with low likelihood of misuse. Examples include:
  • Pure Protection Contracts: Life or health insurance without investment components.
  • Basic Savings Accounts: Regular deposits matching the customer’s financial profile. Due diligence: Basic identification and routine monitoring.
• Intermediate Risk Products These have moderate potential for misuse and allow some flexibility in transactions. Examples include:
  • Investment Products: Bonds or mutual funds.
  • Long-Term Savings Plans: Accounts with occasional large deposits. Due diligence: Enhanced verification, checks on the source of funds, and closer monitoring.
• Increased Risk Products These products carry high risks due to complexity, liquidity, or anonymity. Examples include:
  • Unit Trusts/Investment Funds: Pooled investments.
  • Cryptocurrencies: Digital currencies with anonymous transactions.
  • High Liquidity Assets: Precious metals, high-value art. Due diligence: Enhanced Due Diligence (EDD) with rigorous checks, background verification, and continuous monitoring.
• Sales Process: The risk level of a product is also influenced by the manner in which it is sold. For example, a transaction initiated following a KYC process, where the customer’s identity and financial background are thoroughly vetted, is generally considered lower risk. In contrast, execution-only transactions, where no advisory services are provided and the firm knows less about the customer’s financial situation, are considered higher risk.
• Ongoing Monitoring: The Company will continue to monitor transactions related to products throughout their life cycle. This ensures that any potential red flags or suspicious activities are identified and investigated promptly. Products with a high-risk classification will be subject to increased scrutiny to detect any unusual or suspicious transactions that may indicate money laundering or other illicit activities.

3. Country Risk

Country Risk refers to the geographical location of the customer or the origin of the business activity. Different countries and regions have varying levels of risk associated with them, based on factors such as political stability, regulatory frameworks, and the prevalence of money laundering or terrorist f inancing activities.

• Geopolitical and Economic Factors: Certain countries or jurisdictions may be considered high risk due to their history of weak regulatory controls, high levels of corruption, or association with terrorist activities. The Company will assess the risks associated with customers or transactions originating from such jurisdictions. This includes reviewing factors such as whether the country is subject to international sanctions, whether it is listed as a high-risk jurisdiction by the Financial Action Task Force (FATF), and the country’s compliance with anti money laundering and counter-terrorist financing standards.
• Enhanced Due Diligence (EDD): Customers from high-risk jurisdictions will be subject to enhanced due diligence (EDD) measures. This may include verifying the source of funds more rigorously, obtaining additional supporting documentation, and performing more frequent monitoring of transactions. High-risk countries are also monitored for changes in political or economic conditions that may affect the risk profile of the customer or the business activities conducted in that jurisdiction.

4. Implementation of the Risk-Based Approach

Based on the assessment of the customer risk, product risk, and country risk, the Company will determine the appropriate level of due diligence required for each customer relationship or transaction. The due diligence process will be proportionate to the level of risk posed, ensuring that higher-risk relationships are subject to enhanced scrutiny while maintaining efficiency and proportionality for lower-risk relationships.

• Initial Due Diligence: At the outset of a customer relationship, the Company will conduct thorough KYC checks to establish the baseline risk level and ensure that the customer is not involved in money laundering or terrorist financing activities. This includes verifying the customer's identity, assessing the source of funds, and categorizing the customer according to their risk profile.
• Ongoing Monitoring: Following the initiation of the customer relationship, the Company will engage in ongoing monitoring of the customer’s transactions and activities. This monitoring will help detect suspicious behaviour or transactions that deviate from the customer’s typical activity or financial profile. Enhanced monitoring will be applied to higher-risk customers, products, or jurisdictions.
• Adjustments Based on Risk Factors: The Company’s risk assessment will be continuously updated based on any changes in the customer's profile, the products they use, or the jurisdictions they operate in. As risks evolve, so too will the due diligence measures applied to mitigate them.

By adopting this Risk-Based Approach, Ultratrend FX Capital Limited ensures that its AML efforts are both effective and efficient, directing resources where they are most needed while maintaining a streamlined process for low-risk relationships. This approach enables the Company to comply with legal obligations and contribute to the global fight against money laundering and terrorist financing.

Customer Identification Program (CIP) of Ultratrend FX Capital Limited

Ultratrend FX Capital Limited (hereafter referred to as "the Company") has implemented a robust Customer Identification Program (CIP) as part of its compliance with applicable anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. This program is designed to ensure that all customers are properly identified and that all transactions are consistently monitored for potential illicit activity, in accordance with the relevant legal and regulatory requirements.

1. Notice to Customers

Ultratrend FX Capital Limited is committed to ensuring compliance with the Customer Identification Program and will provide explicit notice to customers regarding the collection of identification information. This notice will inform customers that their identity will be verified in accordance with the requirements stipulated by applicable laws and regulations. The Company will seek to obtain specific customer identification information and will notify customers of this requirement prior to engaging in any business transactions.

2. Know Your Customer (KYC) Procedures

In accordance with its legal obligations, Ultratrend FX Capital Limited shall establish and maintain an effective KYC framework. Upon the commencement of any business relationship, the Company will take the necessary steps to ascertain and document the nature and purpose of the customer's anticipated activities. This process includes obtaining detailed personal and financial information to establish what constitutes normal business behaviour for the client.

Once the business relationship is established, the Company will continuously assess the customer's transactions against their expected activity pattern. Any unexplained or irregular transactions will be subject to scrutiny to determine whether there are grounds for suspicion of money laundering or terrorist financing activities. The Company shall gather relevant information regarding the customer's income, occupation, source of wealth, and trading habits, along with the economic purpose of any transactions, to facilitate the provision of advisory services.

Personal information such as nationality, date of birth, and residential address will be collected at the outset of the relationship, ensuring that the Company can assess the risk of financial crime, including money laundering (ML) and terrorist financing (TF). For high-risk transactions or customers, further verification of the provided information may be necessary.

3. Source of Funds

The identification requirements for customers of Ultratrend FX Capital Limited are dependent on the risk level associated with the product or service being provided. Products are classified into three categories based on their risk profiles: reduced risk, intermediate risk, and increased risk. For reduced and intermediate risk products, the following information is required as a standard for identification purposes:

• Full Name
• Residential Address

This information is collected to establish the identity of the customer and to facilitate the verification process.

5. Verification of Customer Information

Documents used for verification purposes must meet stringent criteria to ensure their authenticity and reliability. Where applicable, the Company will rely on documents issued by government authorities, as these are generally considered to provide a higher level of confidence regarding the identity of the customer.

Verification of the information provided by the customer must be based on reliable and independent sources. These sources may include documents presented by the customer, or electronic verification conducted by the Company, or a combination of both. In cases where face-to-face business is conducted, the Company will ensure that originals of the documents are inspected and verified.

Verification can be achieved using:

• Photographic Government-Issued Identity Documents, which must include the customer’s full name and residential address. Acceptable documents include:
  • Valid passport
  • National identity card
• Non-Photographic Government-Issued Documents that incorporate the customer’s full name, supported by a second document that includes both the customer’s full name and residential address.

In situations where government-issued documents may not be available, other forms of evidence may be considered, but they will be weighed against the risks associated with the customer and the business relationship.

6. Verification Process and Timeframe

Ultratrend FX Capital Limited is committed to processing verification documents in a timely and efficient manner. The Company undertakes to review all submitted documents within 24 hours from the date of receipt. While there is no specific deadline for clients to submit their verification documents, the submission of such documents is a mandatory requirement for clients to withdraw funds from their accounts. Failure to submit the required verification documents will result in a delay in the client’s ability to access or withdraw funds. Ultratrend FX Capital Limited will retain the right to withhold funds or suspend transactions if the required verification procedures are not completed in compliance with the CIP and applicable legal requirements.

7. Legal Compliance and Ongoing Monitoring

Ultratrend FX Capital Limited is fully committed to adhering to all relevant legal and regulatory standards in the implementation of its Customer Identification Program. This includes compliance with local and international AML and CTF laws, as well as the ongoing monitoring of customer activity to detect and prevent financial crimes. The Company will continually review and update its policies and procedures to ensure that they reflect changes in applicable law and best practices.

By implementing this robust CIP, Ultratrend FX Capital Limited ensures that it operates in full compliance with its regulatory obligations and mitigates the risk of financial crimes, including money laundering and terrorist financing, across all business activities.

Monitoring and Reporting Policy of Ultratrend FX Capital Limited

1. Transaction-Based Monitoring:

Ultratrend FX Capital Limited (hereafter referred to as "the Company") has implemented a comprehensive transaction-based monitoring system to detect and report suspicious activities in compliance with applicable anti-money laundering (AML) and counter terrorist financing (CTF) laws and regulations. The Company’s monitoring system will focus on transactions that aggregate to $5,000 or more, or any transactions where there is a reason to suspect suspicious activity.

All transactions subject to this monitoring process will be documented in detail for compliance purposes. The Company will ensure that transactions that fall under these thresholds or exhibit any characteristics indicative of suspicious behaviour are carefully reviewed and scrutinized.

2. Suspicious Activity and Red Flags:

Suspicious activity, commonly referred to as "red flags," may indicate potential money laundering or terrorist financing. The identification of such red flags triggers an immediate review and additional due diligence before proceeding with the transaction. If the initial review does not resolve the suspicions, the matter will be escalated to the Compliance Department for further action.

Examples of red flags include, but are not limited to, the following:

• The customer demonstrates undue concern regarding the Company’s compliance with government reporting requirements, particularly concerning their identity, type of business, assets, or refuses to provide necessary information regarding their business activities or furnishes unusual or suspicious identification documents.
• The customer wishes to engage in transactions that lack a legitimate business rationale or investment strategy, or the transaction is inconsistent with the customer’s stated business objectives.
• The customer provides false, misleading, or substantially incorrect information regarding the legitimate source of their funds.
• The customer refuses or fails to disclose a legitimate source for their funds or other assets.
• The customer, or an individual publicly associated with the customer, has a questionable background or is featured in news reports related to criminal, civil, or regulatory violations.
• The customer expresses indifference towards transaction risks, commissions, or other costs associated with the transaction.
• The customer appears to act on behalf of an undisclosed principal, but is reluctant or evasive in providing information about that person or entity.
• The customer struggles to explain the nature of their business or lacks general knowledge about their industry.
• The customer attempts frequent or large cash deposits, insists on dealing exclusively in cash equivalents, or seeks exemptions from the Company’s cash-related policies.
• The customer maintains multiple accounts under a single or multiple names, with a large volume of inter-account or third-party transfers.
• The customer’s account exhibits unexplained or sudden extensive activity, particularly in accounts with no prior significant activity.
• The customer’s account has an unusual number of wire transfers to unrelated third parties that do not align with the customer’s legitimate business purpose.
• Wire transfers are made to or from jurisdictions associated with high money laundering risks or bank secrecy havens without a legitimate business explanation.
• The customer deposits funds, then immediately requests that the money be transferred out to a third party or another financial institution without any legitimate business justification.
• The customer makes a deposit for purchasing long-term investments, only to request the liquidation of the position and transfer of the proceeds shortly thereafter.
• The customer requests that a transaction be processed in a manner that avoids the normal documentation and regulatory requirements.

3. Know Your Customer (KYC)

– The Basis for Recognizing Suspicious Transactions A suspicious transaction often deviates from a customer's normal, legitimate business or personal activities or from the expected pattern of activity for their customer type. To detect such transactions, it is essential for the Company to have an in-depth understanding of the customer's business and transaction patterns.

When determining whether a transaction may be suspicious, the following questions must be considered:

• Is the transaction size consistent with the customer’s typical activities?
• Is the transaction rational given the context of the customer’s business or personal activities?
• Has the pattern of transactions changed, suggesting potentially suspicious activity?

4. Suspicious Scenarios:

Several scenarios may raise suspicions regarding the legitimacy of a transaction or the customer's business activities. These scenarios include:

• Customers who are reluctant to provide proof of identity or documentation related to their business.
• Clients who excessively rely on an introducer, potentially to conceal their true identity or business intentions.
• Requests for cash-related transactions, such as inquiries about whether investments can be made in cash or suggestions that large amounts of cash may be available for investment.
• The source of funds for investment is unclear or unverifiable.
• The customer’s financial situation appears inconsistent with the available funds (e.g., young individuals or students with large investment amounts).
• The transaction does not make sense in relation to the customer’s stated business or personal activities, especially if the client has changed their transaction behaviour without a rational explanation.
• Significant changes in the customer’s transaction pattern or an increase in the frequency of unusual activity.
• Clients involved in international transactions without a clear business or personal reason for such activity, particularly when dealing with high-risk countries.
• Reluctance or refusal to provide normal personal or financial information without a reasonable explanation.

5. Reporting Suspicious Activity:

Ultratrend FX Capital Limited (the “Company”) is committed to strict compliance with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) regulations. As part of this commitment, when suspicious activity is identified, it must be reported to the relevant authorities without undue delay, in accordance with legal requirements.

Any suspicion that a customer or client is involved in, or is attempting to engage in, a transaction that may be related to the proceeds of crime, including but not limited to money laundering or terrorist f inancing, must be immediately reported to the Compliance Department. This report should be made as soon as practicable, ensuring that it is filed within the prescribed timeframe established by regulatory authorities.

To ensure comprehensive monitoring and ongoing regulatory compliance, internal reports must be f iled even if the transaction was not completed or is not expected to be completed. This requirement guarantees that the Company maintains a full and continuous record of suspicious activities for ongoing surveillance, audit, and reporting purposes, in compliance with applicable financial crime prevention laws. Additionally, this ensures that any potential trends or patterns in suspicious activity are effectively identified and monitored over time.

The Company will document each report thoroughly, including the rationale behind the suspicion, the relevant facts, and any actions taken in response to the concern. Such documentation will be retained for the period required under applicable laws, to allow for transparency and accountability in all compliance-related processes.

6. Investigation of Suspicious Activity:

Upon receipt of a Suspicious Activity Report (SAR) or any internal report indicating suspicious activity, the Compliance Department will initiate a comprehensive and thorough investigation to assess the necessity of filing a formal SAR with the appropriate law enforcement agencies or regulatory authorities.

The investigation process will involve a detailed review of all relevant data associated with the suspicious transaction. This includes, but is not limited to:

• Payment history,
• Customer identification information (such as full name, date of birth, address, and other personally identifiable information),
• Transaction history and patterns,
• Documentation of funds and sources of wealth,
• Correspondence and communications related to the transaction,
• Any other relevant information or supporting documentation.

The investigation will also take into account the broader context of the customer’s activity, including the nature of the business relationship, the type of products or services involved, and any red flags or indicators of potential money laundering or terrorist financing.

If, after the investigation, the Compliance Department determines that the suspicious activity constitutes a reportable offense, a Suspicious Activity Report (SAR) will be filed with the relevant law enforcement or regulatory agencies as per the requirements outlined in AML and CTF regulations. The Committee will ensure that all necessary filings are made in accordance with the law, and that appropriate notice is given to law enforcement or regulatory authorities in a timely manner.

In cases where further information is required to support the investigation, the Compliance Department may request additional documentation from the customer or other third parties to substantiate the findings. These efforts will be carried out within the boundaries of applicable confidentiality and legal constraints, ensuring compliance with data protection laws.

7. Confidentiality and Non-Disclosure of Investigation Results:

The Company will handle all information pertaining to suspicious activity reports, investigations, and related matters with the highest degree of confidentiality and security. Only individuals who are directly involved in the investigation or compliance processes will be granted access to the relevant details of the investigation. This is to protect the integrity of the investigative process and to ensure that any ongoing inquiries are not compromised.

Under no circumstances shall any officer, employee, or agent of the Company disclose or discuss any details relating to an AML concern, ongoing investigation, or Suspicious Activity Report (SAR) filing with the customer or any third party. This includes, but is not limited to, the subject of the investigation, their associates, family members, or any other individuals associated with the customer.

The Company will ensure that all employees and agents are made aware of the legal requirements regarding confidentiality, and are instructed on the importance of non-disclosure throughout the investigative process. This policy extends to prevent any leakage of information that could jeopardize the investigation or the subsequent legal proceedings, and is in full alignment with data protection laws and regulatory compliance obligations.

Any breach of confidentiality by an employee, officer, or agent of the Company may result in disciplinary action, up to and including termination of employment, as well as potential legal action depending on the nature of the breach.

8. Freezing of Accounts:

In situations where it is known or suspected that funds in an account are derived from criminal activities or fraudulent actions, or when there are concerns that the transaction or funds may be linked to illegal activities such as money laundering or terrorist financing, the Company will immediately freeze the account to prevent any further illicit transactions. This action is necessary to ensure compliance with AML and CTF regulations and to protect the integrity of the financial system.

The freezing of an account will be executed immediately and without delay, following the identification of suspicious activity. The purpose of freezing the account is to prevent the further movement or dissipation of funds that may be illicit in nature. If it is determined that the account holder is involved in fraudulent or illegal activity, the account will remain frozen until the Compliance Department completes its investigation or until the Company receives direction from law enforcement or relevant regulatory authorities.

The Company will ensure that any funds held in frozen accounts are safeguarded and not subject to further manipulation or access by the account holder. The Compliance Department will maintain a record of all frozen accounts and the reasoning behind such actions, in accordance with legal and regulatory obligations.

In cases where law enforcement authorities or regulatory bodies require further action, the Company will cooperate fully with all investigations and provide any necessary documentation to support criminal or civil legal proceedings. The Company will also monitor the account for any subsequent activity and ensure compliance with all applicable laws throughout the duration of the freezing period.

Ultratrend FX Capital Limited is fully committed to adhering to the highest standards of compliance with AML and CTF regulations. The processes outlined in the areas of monitoring, reporting, investigating, and freezing accounts are integral to the Company’s commitment to preventing financial crime, ensuring regulatory compliance, and maintaining the integrity of the financial system.

By maintaining rigorous procedures for the identification and reporting of suspicious activity, conducting thorough investigations, ensuring strict confidentiality, and taking appropriate actions such as freezing accounts, the Company reinforces its dedication to upholding the law and safeguarding against money laundering and terrorist financing risks. The Company’s comprehensive AML and CTF policies reflect a proactive approach to managing financial crime risks and promoting a secure, transparent, and compliant business environment.