1. Introduction

1.1. Monzaee Capital Limited (hereinafter referred to as the ‘’Company’’), is registered by Registrar of Companies for Saint Lucia, with registration number 2023-00587, having its registered office at Ground floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia.

1.2. The objects of the Company are all subject matters not forbidden by National Futures Association (NFA) Saint Lucia, in particular but not exclusively all commercial, financial, lending, borrowing, trading, service activities and the participation in other enterprises as well as to provide brokerage, training and managed account services in currencies, commodities, indexes, CFDs and leveraged financial instruments

1.3. The Company is committed to combating money laundering and for this reason it has appointed a dedicated Anti-Money Laundering Compliance Officer (the “AMLCO”) who is accountable to the Board of Directors and Senior Management of the Company. The AMLCO is further responsible for the training of employees with respect to the Anti-Money Laundering Law and any amendments thereof as well as for the preparation of the internal procedures of the Company.

2. Key Principle

2.1. All of the Company’s employees are required to read and acknowledge the Anti- Money Laundering Manual of the Company and shall at all times act under the ‘Key Principles’ set out therein

(a) Take appropriate steps to protect the Company and its domain from any activities which involve money laundering and terrorist financing.

(b) The Company must maintain and implement written policies and procedures with respect to combating money laundering, a system of internal controls to ensure ongoing compliance with applicable laws which shall be reviewed and monitor by a designated person and to take appropriate action, once suspicious activity is detected, through the reporting of such transactions in line with the guidelines set out by Global Anti- Money Laundering regulations.

(c) Comply with applicable anti-money laundering and terrorist financing laws and regulations as established by the Global Anti- Money Laundering guidelines. (d) All business units of the Company shall follow the AML policies and procedures.

(e) Report all identified suspicious activities to the extent that it can do so under all applicable foreign and domestic laws.

(f) Compliance with the Company’s AML policies will be monitored through a combination of internal audit and regulatory reviews of compliance with relevant anti-money laundering legislation and/or regulations.

(g) Retaining all the customer related documents for a period specified as per the National Futures Association (NFA) United States.

(h) The Company does not offer services of opening anonymous accounts.

(i) Full cooperation with law enforcement and regulatory agencies to the extent that it can do so under all applicable laws.

(j) Train staff on Know Your Customer and Anti-Money Laundering policies and new AML laws and regulations.

(k) The AML Compliance Committee is responsible for initiating Suspicious Activity Reports ("SARs") or other required reporting to the appropriate law enforcement or regulatory agencies. Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Compliance Committee

The committee shall:

• Receive internal reports of (suspicions of) money laundering.
• Investigate reports of suspicious events.
• Make reports of relevant suspicious events to the relevant authorities.
• Ensure the adequacy of arrangements made for the awareness and training of staff and advisers.
• Report at least annually to the firm’s governing body on the operation and effectiveness of the firm’s systems and controls
• Monitor the day-to-day operation of anti-money laundering policies in relation to: the development of new products; the taking on of new customers; and changes in the firm’s business profile.

3. Policy

It is the policy of Monzaee Capital Limited to actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Monzaee Capital Limited is committed to AML compliance in accordance with applicable law and requires its officers, employees and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

4. What is Money Laundering?

Money laundering is the process by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins. Criminal property may take any form, including money or money’s worth, securities, tangible property and intangible property. It also covers money, however come by, which is used to fund terrorism.

Money laundering activity includes:

• Acquiring, using or possessing criminal property.
• Handling the proceeds of crimes such as theft, fraud and tax evasion.
• Being knowingly involved in any way with criminal or terrorist property.
• Entering arrangements to facilitate laundering criminal or terrorist property.
• Investing the proceeds of crimes in other financial products.
• Investing the proceeds of crimes through the acquisition of property/assets.
• Transferring criminal property.

The money laundering process follows three stages:

1. Placement Disposal of the initial proceeds derived from illegal activity e.g., into a bank account.

2. Layering The money is moved through the system in a series of financial transactions in order to disguise the origin of the cash with the purpose of giving it the appearance of legitimacy.

3. Integration Criminals are free to use the money as they choose once it has been removed from the system as apparently “clean” funds. No financial sector business is immune from the activities of criminals and Firms should consider the money laundering risks posed by the products and services they offer.

5. What is Counter Terrorist Financing (CTF)?

Terrorist financing is the process of legitimate businesses and individuals that may choose to provide funding to resource terrorist activities or organizations for ideological, political or other reasons. Firms must therefore ensure that:

• (i) customers are not terrorist organizations themselves: and
• (ii) they are not providing the means through which terrorist organizations are being funded.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

6. Risk Based Approach

The level of due diligence required when considering anti-money laundering procedures within the firm, it should take a risk-based approach. This means the amount of resources spent in conducting due diligence in any one relationship that is subject risk should be in proportion to the magnitude of the risk that is posed by that relationship

These can be broken down into the following areas

Customer Risk

Different customer profiles have different levels of risks attached to them, a basic Know Your Customer (KYC) check can establish the risk posed by a customer.

For example, near-retired individuals making small, regular contributions to a savings account in line with their financial details poses less of a risk than middle-aged individuals making ad-hoc payments of ever-changing sizes into a savings account that does not fit into the profile of the customers’ standing financial data.

The intensity of the due diligence conducted on the latter would be higher than that carried out on the former as the potential threat of money laundering in the second case would be perceived as being greater. Corporate structures can be used as examples of customers that could carry a higher risk profile than the one just seen, as these can be used by criminals to introduce layers within transactions to hide the source of the funds, and like that, clients can be categorized into different risk bands.

Product Risk

This is the risk posed by the product or service itself. The product risk is driven by its functionality as a money laundering tool. The Joint Money Laundering Steering Group has categorized the products with which Firms typically deal into three risk bands – reduced, intermediate and increased. Typically, pure protection contracts are categorized as reduced risk and investments in unit trusts as increased risk. Additionally, a factor that will contribute to the classification of the risk category is the sales process associated with the product. If the transaction in the product takes place on an advisory basis as a result of a KYC, this will carry less risk than an execution only transaction, whereby you know significantly less about the customer.

Country Risk

The geographic location of the client or origin of the business activity has a risk associated with it, this stems from the fact that countries around the globe have different levels of risk attached to them. A firm would determine the extent of their due diligence measure required initially and on an ongoing basis using the above four risk areas.

7. Customer Identification Program

Monzaee Capital Limited has adopted a Customer Identification Program (CIP). We will provide notice that they will seek identification information; collect certain minimum customer identification information from each customer, record such information and the verification methods and results.

8. Notice to Customers

Monzaee Capital Limited will provide notice to customers that it is requesting information from them to verify their identities, as required by applicable law.

9. Know Your Customers

When a business relationship is formed, in order to establish what might constitute normal activity later in the relationship, it is necessary for the company to ascertain the nature of the business a client expects to conduct. Once an on-going business relationship has been established, any regular business undertaken for that customer can be assessed against the expected pattern of activity of the customer. Any unexplained activity can then be examined to determine whether there is a suspicion of money laundering or terrorist financing. Information regarding a client’s income, occupation, source of wealth, trading habits and the economic purpose of any transaction is typically gathered as part of the provision of advice. At the start of the relationship personal information is also obtained, such as, nationality, date of birth, and residential address. These pieces of information should also be considered in respect to the risk of financial crime (including AML and CTF). For high-risk transactions, it might be appropriate to seek verification of the information the client has provided.

10. Source of Funds

When a transaction takes place, the source of funds, i.e., how the payment is to be made, from where and by who, must always be ascertained and recorded in the client file (this would usually be achieved through retaining a copy of the cheque or direct debit mandate).

11. Identification

The standard identification requirement for customers who are private individuals are generally governed by the circumstances relating to the customer and the product type that is being dealt in, i.e., the level of risk attributed to the product whether it is a reduced risk, intermediate risk or an increased risk product. Taking that into account for reduced risk and intermediate risk products the following pieces of information are required as a standard for identification purposes:

12. Verification

Verification of the information obtained must be based on reliable and independent sources – which might either be documents produced by the customer, or electronically by the firm, or by a combination of both. Where business is conducted face-to-face, firms should see originals of any documents involved in the verification.

If documentary evidence of an individual’s identity is to provide a high level of confidence, it will typically have been issued by a government department or agency, or by a court, because there is a greater likelihood that the authorities will have checked the existence and characteristics of the persons concerned. In cases where such documentary evidence of identity may not be available to an individual, other evidence of identity may give the firm reasonable confidence in the customer’s identity, although the firm should weigh these against the risks involved.

If the identity is to be verified from documents, this should be based on: Either a government issued document which incorporates:

• The customer’s full name, and
• Their residential address
• Photographic Government issued documents or valid passport
• National identity card alternatively, this can be done by a non-photographic government issued document which incorporates the customer’s full name, supported by a second document, which incorporates:
• The customer’s full name, and
• Their residential address

13. Evidence of Address

Current bank statements, or credit/debit card statements, issued by a regulated financial sector firm (but not ones printed off the internet and not less than 3 months old)

Utility bills (not including mobile phone bills, not ones printed off the internet and not less than 3 months old)

For increased risk level products, in addition to obtaining the standard information detailed above, the following know your customer information should be obtained and recorded:

• Employment and income details
• Source of wealth (i.e. source of the funds being used in the transaction)

14. Monitoring and Reporting

Transaction based monitoring will occur within the appropriate business units of Monzaee Capital Limited. Monitoring of specific transactions will include but is not limited to transactions aggregating $5,000 or more and those with respect to which Monzaee Capital Limited has a reason to suspect suspicious activity. All reports will be documented.

15. Suspicious Activity

There are signs of suspicious activity that suggest money laundering. These are commonly referred to as "red flags." If a red flag is detected, additional due diligence will be performed before proceeding with the transaction. If a reasonable explanation is not determined, the suspicious activity shall be reported to the AML Compliance Committee.