1. Introduction

Trader Markets (“Company,” “we,” “our”) is committed to preventing money laundering and the financing of terrorism in accordance with all applicable laws and regulations. This Anti-Money Laundering (AML) Policy outlines our procedures and measures for detecting and preventing such activities.

2. Purpose

The purpose of this AML Policy is to ensure that Trader Markets has robust systems and controls in place to:

• Prevent and detect money laundering and terrorist financing.
• Comply with all relevant AML laws and regulations.
• Protect the Company’s integrity and reputation.

3. Legal Framework

Trader Markets operates in compliance with the anti-money laundering laws and regulations applicable in the jurisdictions where we conduct business. This includes, but is not limited to:

• The U.S. PATRIOT Act
• European Union Anti-Money Laundering Directives
• Financial Action Task Force (FATF) Recommendations

4. Customer Due Diligence (CDD)

We perform due diligence on all customers to verify their identity and assess the risks they may pose in terms of money laundering and terrorist financing. CDD measures include:

• Collecting and verifying identification documents (e.g., passport, national ID card).
• Understanding the nature and purpose of the customer’s business or trading activities.
• Evaluating the customer’s risk profile based on factors such as geography, transaction patterns, and the source of funds.

5. Enhanced Due Diligence (EDD)

For customers identified as high risk, we implement Enhanced Due Diligence measures, which may include:

• Obtaining additional information about the customer’s business activities and source of funds.
• Regularly updating and reviewing the customer’s information and transactions.
• Closer monitoring of transactions for unusual or suspicious activity.

6. Reporting Suspicious Activity

Employees are required to report any suspicious activity or transaction to the designated Compliance Officer. Suspicious activities may include:

• Unusual transaction patterns inconsistent with the customer’s known activities.
• Large cash transactions with no clear commercial purpose.
• Attempts to conceal the origin of funds.

All reports are handled confidentially and in accordance with legal requirements.

7. Record Keeping

We maintain comprehensive records of all customer transactions, identification documents, and due diligence measures for at least five years. These records are stored securely and accessible only to authorized personnel.

8. Employee Training

Trader Markets provides regular AML training to all employees to ensure they are aware of the latest regulations, internal policies, and best practices for identifying and preventing money laundering and terrorist financing.

9. Compliance Officer

The Company has appointed a dedicated Compliance Officer responsible for overseeing the implementation and maintenance of the AML Policy. The Compliance Officer ensures that all AML procedures are followed and serves as the primary contact for any AML-related inquiries.

10. Sanctions and PEP Screening

We screen all customers against relevant sanctions lists and Politically Exposed Persons (PEP) databases to identify individuals or entities that may present a higher risk of money laundering or corruption. Customers identified as PEPs or listed on sanctions lists are subject to Enhanced Due Diligence.

11. Risk Assessment

Trader Markets conducts regular risk assessments to evaluate the effectiveness of our AML controls and to identify any emerging risks. These assessments help update our policies and procedures to address new threats.

12. Transaction Monitoring

We use advanced monitoring systems to track and analyze customer transactions in real time. These systems are designed to detect unusual patterns or high-value transactions that may indicate suspicious activity.

13. Internal Controls

The Company has implemented internal controls to ensure compliance with AML regulations. These controls include:

• Segregation of duties to prevent conflicts of interest.
• Regular audits and reviews of AML procedures.
• Clear reporting lines and responsibilities for AML compliance.

14. Consequences of Non-Compliance

Failure to comply with this AML Policy may result in disciplinary action, including termination of employment or business relationships. Furthermore, non-compliance can lead to legal penalties for both the individual and the Company.

15. Policy Review and Updates

This AML Policy is reviewed annually and updated as necessary to reflect changes in laws, regulations, and best practices. All employees are required to be familiar with the latest version of the policy.

16. Contact Information

For any questions or concerns regarding this AML Policy, please contact our Compliance Officer at:

Email: [email protected]
Phone: +44 750 835 2230