Anti-money-laundering policy

Template document. A structural draft only. Your AML policy must be written against the specific legislation and regulator requirements applying to your licensed entity, approved by your board or senior management, and owned by a named Money Laundering Reporting Officer. Have it prepared and reviewed by a qualified compliance professional.

1. Our commitment

ACSFX Markets is committed to preventing its services being used for money laundering, terrorist financing, sanctions evasion or any other financial crime. We apply a risk-based approach, and we will decline or terminate a relationship where we cannot satisfy ourselves as to a client's identity or the legitimate source of their funds.

2. Regulatory framework

This policy is designed to meet the anti-money-laundering and counter-terrorist-financing obligations applying to us as a regulated entity, and reflects the standards set by the Financial Action Task Force.

A Money Laundering Reporting Officer is appointed with responsibility for the policy, for suspicious activity reporting, and for reporting to senior management.

3. Client due diligence

We verify the identity of every client before permitting live trading or processing any withdrawal. Standard due diligence requires:

  • A current government-issued photo identity document
  • Proof of residential address dated within the last three months
  • Confirmation of date of birth and nationality
  • Information on occupation, source of wealth and source of funds
  • Screening against sanctions, politically exposed person and adverse media lists

Corporate clients must additionally provide incorporation documents, ownership structure, and identification of beneficial owners holding more than the applicable threshold, together with evidence of the authority of those acting for the entity.

4. Enhanced due diligence

Enhanced measures apply where the risk assessment indicates higher risk, including clients who are politically exposed persons or their close associates, clients resident in higher-risk jurisdictions, relationships involving unusually complex structures, and any relationship where the source of funds cannot be readily explained.

Enhanced measures may include additional documentary evidence of source of wealth, senior management approval to establish or continue the relationship, and more frequent review.

5. Ongoing monitoring

Client activity is monitored on a continuing basis against the expected profile established at onboarding. Automated and manual review is applied to identify patterns inconsistent with a genuine trading purpose, including:

  • Deposits followed by withdrawal with minimal or no trading activity
  • Trading patterns producing offsetting positions across related accounts
  • Funding from or withdrawal to jurisdictions unconnected to the client
  • Repeated attempts to use third-party payment methods
  • Transaction values materially inconsistent with declared income or wealth

Client records are periodically refreshed, with frequency determined by risk rating.

6. Payment policy

We accept deposits only from payment instruments held in the client's own name. Third-party deposits are rejected and returned to source. Withdrawals are returned by the original funding method up to the amount deposited, with any surplus paid only to a bank account in the client's own name. Anonymous or unverifiable funding sources are not accepted.

7. Suspicious activity reporting

Where knowledge or suspicion of money laundering or terrorist financing arises, an internal report is made to the MLRO, who determines whether an external report to the relevant financial intelligence unit is required. Reports are made without notifying the client, as disclosure would constitute the criminal offence of tipping off.

8. Record keeping

Identification records, transaction records, internal and external reports and supporting documentation are retained for at least five years from the end of the client relationship or the date of the transaction, or longer where required by law or an ongoing investigation.

9. Staff training

All staff receive anti-money-laundering training at induction and at least annually thereafter, covering recognition of suspicious activity, internal reporting procedures, sanctions obligations, and the personal criminal liability that attaches to failures in this area. Training completion is recorded and monitored.

10. Your obligations as a client

  • Provide accurate, complete and current information, and update it when your circumstances change
  • Fund your account only from payment methods held in your own name
  • Supply requested documentation promptly — delays will suspend trading and withdrawals
  • Not permit any other person to use or fund your account

Failure to meet these obligations may result in restriction, suspension or closure of your account, and where legally required, in a report to the relevant authorities.