Jetvix Africa

Anti-Money Laundering (AML) and Know Your Client (KYC) Policy

Preamble

Money laundering is the processing of criminal proceeds to disguise their illegal origin.

Verte Securities Limited (hereinafter referred to as the “Company”) , operating jetvix.africa, has a comprehensive Anti-Money laundering policy, an outline of which is set out below.

These Policy (hereinafter referred to as the “Policy”) have been developed within the framework of the implementation of the FATF (Financial Action Task Force on Money Laundering) recommendations aimed at combating financial abuse, identifying and preventing violations of the law, as well as for the purpose of complying with the legislation on combating the legalization of funds obtained by criminal means and the financing of terrorism, and establish the procedure for making deposits, withdrawals and other non-trading transactions on the Client’s Account. This Policy apply to the Company and all partners of the Company, including payment agents, and the Clients of the Company.

Obligations and guarantees of the Client

1.1. The Client guarantees the legal origin, legal ownership and right to use and dispose of the funds transferred by him to the Company’s accounts.

1.2. The Client undertakes to:

1.2.1. Comply with legal norms, including international ones, aimed at combating illegal trade, financial fraud, laundering and legalization of funds obtained illegally.

1.2.2. Exclude direct or indirect assistance in illegal financial activities and any other illegal transactions.

1.2.3. Exclude direct or indirect assistance in financial fraud, as well as committing other actions that contradict international legislation and legal norms.

1.2.4. To exclude in their practical activities using the Company’s services any actions that may directly or indirectly harm the fight against money laundering and legalization of illegally obtained funds.

1.3. The Company reserves the right to investigate at any time the nature of suspicious non-trading transactions set out in Section 2 of this Policy, as well as to suspend such transactions until the reasons for their occurrence are clarified and the investigation is completed.

1.4. In the course of the investigation, in accordance with this clause of this Policy,, the Company has the right to request from the Client identification documents (passport, identity card, driver’s license, etc.), as well as documents confirming the place of residence, payment and other documents and bank cards confirming the legal ownership and legal origin of funds, as well as documents confirming the financial status of the Client and any other documents required by the Company by virtue of applicable, including international, legal regulation and legislation.

1.5. Upon detection of suspicious transactions not related to trading, the Company has the right to immediately and unilaterally:

• Refuse to perform such transactions for the Client;

• Set limits on the withdrawal of funds from the Client’s Account by any means and at its own discretion;

• Refund funds previously credited to the Client’s Account through the payment system through which the deposit was made;

• Close the Client’s Account and terminate its servicing;

• Write off from the Client’s Account all commissions and other expenses incurred in connection with a suspicious transaction not related to trading;

• Withhold up to 20% (twenty percent) of any withdrawn amount, including commissions of the Company and (or) the Client’s banks, and (or) payment systems;

• Close the Client’s open positions (transactions) and document the financial result;

• Write off accrued bonuses from the Client’s Account;

• Block any transactions conducted through the trading terminal;

• Terminate the Agreement with the Client;

• Carry out other actions that the Company considers necessary and sufficient to ensure compliance with this Policy,, applicable legal norms and legislation.

The list is not exhaustive and may be expanded at the discretion of the Company.

1.6. Refusal to carry out suspicious non-trading transactions, as well as termination of the Agreement with the Client due to the Company identifying suspicious non-trading transactions, shall not be grounds for the Company to incur civil liability for failure to comply with obligations under the Agreement.

1.8. The Company has the right to close the Client’s Account if the Client does not carry out any transactions on the Client’s Account for 12 (twelve) months in a row and there are no funds in the Account.

1.9. This Policy is open in nature and are an integral part of the Agreement concluded between the Company and the Client. The content of this Policy is disclosed without restrictions upon request of any interested parties. At the same time, the Company does not inform Clients and other persons about the measures taken to combat the legalization (laundering) of proceeds from crime, the financing of terrorism and the financing of the proliferation of weapons of mass destruction, except for cases stipulated by applicable law and this Policy.

1.10. In the event of a discrepancy between individual provisions of this Policy and individual provisions of the Agreement and its integral parts in terms of non-trading transactions, the provisions of this Policy shall apply, unless otherwise follows from the essence of the obligation. This circumstance does not entail the invalidity of the remaining provisions of the listed documents.

Obligations and guarantees of the Company

2.1. Senior management of Verte Securities Limited have a responsibility to ensure that the Company’s control processes and procedures are appropriate and effectively implemented to counter the risk of the firm being used to money laundering and financial crime. Senior management are fully involved in the processes and take ownership of the risk-based approach.

2.2. The firm’s Money Laundering Reporting Officer (MLRO) will provide an annual report to the directors on the operation and effectiveness of the firm’s systems and controls to combat money laundering and financial crime. When the report is received senior management will consider the findings and take any action that is required.

2.3. Our Company’s obligations for conducting Client Due Diligence (CDD) as well as describing those situations and customers where either Simplified Due Diligence (SDD) can be applied or where Enhanced Due Diligence (“EDD”) must be used.

2.4. Core CDD obligations on the Company are:

The prescribed CDD measures must be carried out for all Clients not covered by exemptions; Systems must be in place for dealing with those who are unable to produce ‘standard evidence’ EDD must be applied in higher risk cases where the customer is not present and also in relation to Politically Exposed Persons (PEPs); Awareness that some persons/entities must not be dealt with and systems are in place for keeping information up to date. CDD measures that must be carried out involve:

• identifying the investor and verifying their identity;

• identifying the beneficial owner where relevant and verifying their identity; and

• obtaining information on the purpose and intended nature of the business relationship the Company monitors and adapts this process as required.

2.5. One of the key components of CDD is a conscientious KYC procedure.

2.5.1. In order to ensure the legality and security of the provision of services, the Company conducts Know Your Customer procedure for verifying the identity of the Client and the information indicated by them. In pursuance this procedure, the Company has the right to request the Client to provide the documents (information) that may include but not limited to:

• completed KYC Application Form;

• passport or ID card;

• second ID document with photo (driver license or another document issued by a government authority);

• utility bill with the Client’s full name and address;

• bank reference of the Сlient’s personal account not older than 3 months / bank statement for the last 3 months

• copy of the Client’s bank card.

2.5.2. In order to establish whether the documents provided belong to a specific person, the Company also has the right to conduct liveness check – identification of the person using video communication means.

2.5.3. In case of replenishment of the Account by credit or debit card, the Company will request a scanned copy of the front and back sides of the card. The Client must ensure that only the first 6 and last 4 digits of the card number are visible. All other digits and the CVV code on the back side must be hidden for the Client’s protection.

2.5.4. Depending on the method of making Deposits and/or amount of a Deposit, the Company reserves the right at any moment to request supporting documentation to verify the actual owner of the account from which the funds were sent and/or documents confirming the legal source of funds, if such information is required either due to legal and/or regulatory obligations of the Company, or if such information is necessary for the Company to effectively offer its services to the Client.

2.5.5.The Company also has the right to request other documents if the documents provided earlier do not allow the Client to be fully identified and/or verify his payment details and confirm the information specified by them.

2.5.6. KYC procedure is carried out within seven (7) days from the moment the Client provides the full set of documents requested by the Company. In some cases, the Company has the right to extend this period to fourteen (14) calendar days.

2.5.7. If the Client unjustifiably refuses to provide the documents and/or information requested for KYC procedure, the Company has the right to refuse to provide its services to the Client.

Money Transfer and Suspicious Non-Trading Operations Overview

3.1. Verte Securities Limited will not, under any circumstances, accept funds from a remitter where the ordering party is not also the beneficiary i.e. No Third Party transfers are accepted, and funds are either returned as unapplied or dependent on determination of the firm’s Compliance Officer.

3.2. Likewise Verte Securities Limited will never disburse funds to a Third Party, and will always “return to sender” i.e. Client Account at Jetvix Africa to Client account at correspondent bank where the original transfer was made.

3.3. The Company makes every effort to prevent, identify and suppress non-trading operations.

3.4. Criteria for identifying and signs of suspicious non-trading operations:

3.4.1. The Company may consider an operation not related to trading to be suspicious in the following cases:
• Abuse of transfers (replenishment of the Client’s Account, withdrawal of funds from the Client’s Account) without performing trading operations on trading accounts or with insignificant volumes of such operations;
• Unusual nature of the operation, which does not have an obvious economic sense or an obvious legal purpose;
• Circumstances due to which the Company suspects that the said operation is carried out for the purpose of legalization (laundering) of funds or financing terrorism;
• Failure by the Client to provide identification information requested by the Company, provision of false information and (or) impossibility of contacting the Client at the addresses and telephone numbers indicated by him;
• Failure by the Client to provide information to identify the beneficial owner, i.e. the person in whose interests the Client acts (in particular, on the basis of an agency agreement, assignment agreement, commission and trust management for the performance of operations not related to trading);
• Provision of counterfeit or invalid documents and documents of inadequate quality (e.g. black and white or illegible copies);
• Failure by the Client to provide, at the request of the Company, information to identify the beneficiary represented by the Client;
• Failure by the Client to provide information requested by the Company, including information on its financial position;
• Inclusion of the Client in an international and (or) other list of wanted persons or receipt by the Company, in the process of verification, of data on the Client and (or) sources of payments of the Client, which indicate that the Client does not own the sources of funds on a legal basis or that the sources of funds are used for illegal purposes;
• The Client performing operations that are not related to trading and are of an unfair or illegal nature.

3.4.2. The criteria for identifying and signs of suspicious operations specified in this section of the Policy are not exhaustive. A non-trading operation may be recognized by the Company as suspicious based on an analysis of the nature of the operation, its components, accompanying circumstances and interaction with the Client or his representative, even in the formal absence of the criteria and signs specified in this section of the Policy.

3.4.3. When suspicious non-trading operation are identified, the Company independently makes a decision on further actions with respect to the Client, his Account, trading and non-trading operations.

If you have any general questions about KYC&AML Policy, please contact us by email at [email protected].

Effective as of September 01, 2024