1. GENERAL DEFINITIONS

For the purpose of this policy:

  • Beneficial Owner: The individual who ultimately owns or controls a client or transaction.
  • Client: Any person or entity holding an account, conducting transactions, or authorized to act on behalf of another.
  • Business Relationship: An ongoing arrangement between Broking FX and a client for providing financial services.
  • Money Laundering (ML): The process of concealing the origin of illegally obtained funds.
  • Terrorist Financing (TF): The use of funds to support terrorist activities.
  • Policy: This AML & Compliance Policy document.

2. INTRODUCTION

At Broking FX, we are committed to preventing money laundering, terrorist financing, and other financial crimes.

This policy outlines the internal procedures, controls, and systems implemented to ensure compliance with applicable AML/CFT (Anti-Money Laundering and Counter Financing of Terrorism) laws and regulations.

The policy is regularly reviewed and updated to reflect changes in legal requirements and industry standards.

3. PURPOSE

The purpose of this policy is to:

  • Prevent misuse of financial systems for illegal activities
  • Ensure compliance with AML/CFT regulations
  • Establish clear procedures for identifying and reporting suspicious activities
  • Protect the integrity of Broking FX and its clients

4. APPLICATION

This policy applies to:

  • All services offered by Broking FX
  • All employees, officers, and representatives
  • All clients, regardless of account size or transaction volume

It covers all financial activities, including forex trading and other financial instruments.

5. RESPONSIBILITIES

5.1 Board of Directors

The Board is responsible for:

  • Approving AML policies and procedures
  • Ensuring effective compliance systems are in place
  • Appointing a Compliance Officer
  • Providing adequate resources for AML implementation

5.2 Compliance Officer

The Compliance Officer is responsible for:

  • Implementing and maintaining AML procedures
  • Monitoring transactions and client activities
  • Reporting suspicious transactions
  • Ensuring staff training and awareness
  • Maintaining compliance records

5.3 Employees

All employees must:

  • Follow AML policies and procedures
  • Identify and report suspicious activities
  • Participate in AML training programs
  • Maintain confidentiality

6. RISK-BASED APPROACH (RBA)

Broking FX adopts a risk-based approach to identify and manage risks related to money laundering and terrorist financing.

We assess risks based on:

  • Client profiles
  • Geographic locations
  • Products and services
  • Transaction patterns

Appropriate measures are applied based on the level of risk.

7. CUSTOMER DUE DILIGENCE (CDD)

We perform Customer Due Diligence to verify client identity and assess risk.

CDD includes:

  • Verifying identity using official documents
  • Identifying beneficial owners
  • Understanding the nature of business relationships
  • Monitoring transactions for unusual activity

If verification fails, accounts will not be opened or transactions processed.

8. ONGOING MONITORING

We continuously monitor client transactions to ensure consistency with their profile.

This includes:

  • Reviewing transaction patterns
  • Updating client information
  • Identifying unusual or suspicious activities

9. HIGH-RISK & SANCTIONED JURISDICTIONS

We assess risks associated with countries using global standards and sanction lists.

Clients from high-risk jurisdictions may be subject to enhanced due diligence.

10. SUSPICIOUS TRANSACTIONS

A transaction is considered suspicious if it:

  • Is inconsistent with the client’s profile
  • Involves unusual patterns or amounts
  • Raises concerns about legality

All suspicious activities are reviewed and reported to the relevant authorities as required.

11. MONEY LAUNDERING OFFENCES

Money laundering includes:

  • Concealing the origin of illegal funds
  • Transferring or converting illicit money
  • Acquiring or using proceeds of crime

Broking FX strictly prohibits any involvement in such activities.

12. TIPPING-OFF PROHIBITION

Employees must not disclose:

  • That a suspicious transaction report has been filed
  • That an investigation is ongoing

Such disclosures are strictly prohibited and may result in legal consequences.

13. RECORD KEEPING

We maintain records of:

  • Client identification documents
  • Transaction history
  • AML reports and communications

Records are retained for a minimum of 5–7 years, as required by law.

14. DATA STORAGE & ACCESS

All records are securely stored in:

  • Electronic systems
  • Physical documentation (where required)

Data can be retrieved promptly when requested by regulatory authorities.

15. RELIANCE ON THIRD PARTIES

Broking FX may rely on third parties for client verification, provided:

  • Data is accurate and accessible
  • Proper due diligence is conducted
  • Compliance standards are maintained

16. EMPLOYEE TRAINING

We provide regular AML training to employees to ensure:

  • Awareness of legal obligations
  • Ability to identify suspicious activities
  • Understanding of AML procedures

Training is updated based on regulatory changes and industry trends.

17. REVIEW & MONITORING

This policy is:

  • Reviewed regularly
  • Updated when required
  • Monitored for effectiveness

Continuous improvement ensures compliance and risk mitigation.

18. CONTACT US

For any questions, concerns, or reporting matters related to this policy, please contact:

Mail Id: –
support@brokingfx.com 
service@brokingfx.com