This Policy must be read in combination with Company's KYC Policy, ensuring full
compliance with the applicable laws related to Money Laundering and Terrorism
Financing activities.
The term "money laundering" is used to describe all procedures that aim to conceal
the criminal origins of funds and in doing so make the origin of funds appear as of a
legitimate source.
The Forex Market involves a high risk in relation to clients willing to use services for
illegal purposes, which can be attributed to money laundering. Although, it does not
constitute as a crime for the Company if such cases occur without the Company's
knowledge of illegal assets, property, transactions and etc., the Company must
ensure and do everything in its competence to avoid the transactions/ relationships
involving any illegal, criminal or terrorist involvement or elements. Therefore, the
Company closely and seriously has reviewed the anti-money laundering (hereinafter
referred to as "AML") as well as relevant practices to it and has developed its internal
AML Policy in order to avoid and prevent any money laundering, illegal or criminal
activities. Through that, the Company will ensure that employees are not involved in
money laundering and terrorism financing.

1. POLICY STATEMENT
The policy of the Company - the Company is taking security arrangements and has
developed policies and procedures that promote high ethical and professional
standards and prevent the Company from being used, intentionally or unintentionally,
by criminal elements.
The directors, officers and staff of the Company shall at all times make every effort to
maintain the highest standards of ethics, unity and discretion in the Company's
management and administration so as to ensure that the Company creates and
maintains a positive reputation.
The directors, officers and staff shall at all times act in such a manner as to maintain
the reputation of 81,212)&202526 as a major international financial center and
to impede the use of the jurisdiction for illegal, criminal and terrorist purposes.

2. CUSTOMER DUE DILIGENCE
Effective Customer Due Diligence measures are essential to the management of
money laundering and terrorist financing risk. Customer Due Diligence means
identifying the customer and verifying their true identity on the basis of documents,
data or information both at the moment of starting a business relationship with
customer and on an ongoing basis. The customer identification and verification
procedures require, first, the collection of data and, second, attempts to verify that
data.

The Company required to get all necessary information in order to identify each new
customer and intended nature of the business relationship. The extent and nature of
the information depends on the type of applicant (personal, corporate, etc.) and the
expected size of the account.
In case, when an account has been opened, but problems of verification arise and
cannot be resolved, the Company can close the account and return the money to the
source from which it was received. While the transfer of an opening balance from an
account in the customer's name in another organization subject to the same KYC
standard will be considered, the Company follow its own KYC procedures. The
Company can consider the possibility that the previous account manager may have
asked for the account to be removed because of a concern about dubious activities.
As no single form of identification can be fully guaranteed as genuine, or
representing correct identity, the identification process will need to be cumulative,
and no single document or source of data must therefore be used to verify both
name and permanent address. The company will take all measures to establish the
identity of its clients.
Due Diligence
As part of its obligation to exercise due diligence in customer identification, the
Company must confirm that the identity information which it holds for its customers
remains fully updated with all necessary identification and information throughout the
business relationship. The Company reviews and monitors on a regular basis the
validity and adequacy of customer identification information in its possession. The
Company has determined identification information and confirmation documents for
Individual and Corporate customers.

Individual customers
The identity will be established to the Company's satisfaction by reference to official
identity papers or such other evidence as may be appropriate under the
circumstances. Information on identity will include, without limitation: full name, date
of birth, nationality, complete residential address.
Names should be verified by reference obtained from a reputable source that bears
a photograph, such as:
• Current valid full passport
• Government issued photo identification card
Identification documents must be valid at the time of the opening.
In addition to the customer's name verification, the current permanent address
should be verified by obtaining any one of the following documents in certified
document's form:
• Copy of a recent (no older than 3 months) utility bilil
• Bank statement
• Local tax authority bill
• Credit card monthly statement
Corporate customers
Where the applicant company is listed on a recognized or approved stock exchange
or where there is independent evidence to show that the applicant is a wholly owned
subsidiary or subsidiary under the control of such a company, no further steps to
verify identity over and above the usual commercial checks and due diligence will
normally be required.


Accounts for Corporate Customers:
• Company searches and other commercial enquiries to ensure that the
applicant has not been or is not in the process of being dissolved, struck off, wound
up or terminated.
• If changes to company structure occur or ownership occurs subsequent to
opening of an account with the company, further checks should be made.
• Identity verification should aim to identify:
• the company,
• the directors,
• all persons duly authorized to operate the account,
• in case of private companies - the major beneficial shareholders,
• the company's business profile in terms of nat ure and scale of activities.

Where the applicant is an unquoted company, it will be subject to a procedure aimed
to identify it, confirm its existence, good standing and authority of persons acting on
its behalf. Documentation required for such purposes may change depending on
each particular jurisdiction and will typically include:
1 Certificate of incorporation/certificate of trade or the equivalent, evidencing
the company is indeed incorporated in a particular jurisdiction under the respective
legislation;
2 Certificate of Incumbency or an equivalent document, listing current
directors of the company;
3 Statutes, Memorandum and Articles of Association or equivalent
documents confirming the authority of the respective officers of the company to
legally bind it and the manner in which this may be done;
4 Extract from the Commercial Register of the country of incorporation may
also be used to confirm the aforementioned information, if such information is
provided in the extract.

Additional documents required:
• Where appropriate a search of the file at the Companies' Registry
• Identity of individuals who are connected with the company
In addition to identification information, it is necessary to collect and record
information covering the following:
1 Source of wealth (activity, which generated the net worth)
2 Source of funds to be invested
3 References or other documentation (reputation information where
available)
4 Independent background checks through a screening system
Notwithstanding the above and taking into account the degree of risk, if it becomes
apparent at any time during the business relationship that the Company lacks
sufficient or reliable evidence (data) and information on the identity and financial
profile of an existing customer, the Company will immediately take all necessary
actions using the identification procedures and measures to provide due diligence, in
order to collect the missing data and information as quickly as possible and in order
to determine the identity and create a comprehensive financial profile of the
customer.

Furthermore, the Company monitors the adequacy of the information held and
identity and economic portrait of its customers when and where one of the following
events occurrences: conduct of a suspicious transaction that appears to be unusual
and/or significant compared to the usual type of trade and economic profile of the
customer.

A significant change in the situation and legal status of the customer such as:
• Change of corporate name and/or trade name;
• Change of registered shareholders and/or actual beneficiaries;
• Change of directors/secretary;
• Change of registered office;
• Change of trustees;
• Change of main trading partners and/or significant new business;
• A significant change in the operating rules of the customer's account, such
as:
• Change of persons authorized to handle its account;
• Request for opening a new account in order to provide new investment
services and/or financial instruments.

Where the customer refuses or fails to provide the Company with the required
documents and information for identification and creation of a financial portrait,
before entering into the business relationship, or during the execution of an individual
transaction without adequate justification, the Company will not proceed in a
contractual relationship or will not execute the transaction. If during the business
relationship the customer refuses or fails to submit all required documents and
information, within reasonable time, the Company has the right to terminate the
business relationship and close the accounts of the customer.

3. PERSONNEL
AML Compliance Officer
The Company shall appoint a qualified compliance Officer who will be fully
responsible for the Company's Anti-Money Laundering program and report to the

Board of Directors of the Company about any breaches of the internal AMLpolicy
and procedures and of the regulations and standards of good practice.
AML Compliance Officer's responsibilities include:
1 Ensuring the Company's compliance with the requirements of the
Regulations;
2 Establishing and maintaining internal AML program;
3 Training employees to recognize suspicious transactions;
4 Receiving and investigating internal suspicious activity and t ransaction
reports from staff;
5 Ensuring that proper AML records are kept;
6 Obtaining and updating international findings concerning countries with
inadequate AML systems, laws or measures.

Employees
All Company employees, managers and directors must be aware of this policy.
Employees, managers and directors who are engaged in AML related duties must be
suitably vetted. This includes a criminal check done at the time of employment and
monitoring during employment. Any violation of this policy or an AML program must
be reported in confidence to the AML Compliance Officer, unless the violation
implicates the AML Compliance Officer, in which case the employee must report the
violation to the Chief Executive Officer.
Employees who work in areas that are susceptible to money laundering or financing
terrorism schemes must be trained in how to comply with this policy or the AML
program. This includes knowing how to be alert to money laundering and terrorism
financing risks and what to do once the risks are identified