AML/KYC Policy

1. Introduction

MarketsNova is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. This policy outlines our Know Your Customer (KYC) procedures and AML obligations in accordance with applicable laws and regulations.

We are required by law to verify the identity of our clients and to monitor transactions for suspicious activity. This policy explains what information we need from you and how we use it to prevent financial crime.

2. Regulatory Framework

Our AML/KYC policy is designed to comply with:

• The Financial Conduct Authority (FCA) regulations
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• The Proceeds of Crime Act 2002
• The Terrorism Act 2000
• Financial Action Task Force (FATF) recommendations
• International sanctions regimes
• Other applicable local and international AML/CTF legislation

3. Know Your Customer (KYC) Requirements

3.1 Identity Verification

Before you can trade with MarketsNova, we must verify your identity. You will be required to provide:

For Individual Clients:

• Government-issued photo ID: Valid passport, driver's license, or national ID card
• Proof of Address: Recent utility bill, bank statement, or government document (dated within the last 3 months)
• Personal Information: Full legal name, date of birth, nationality, residential address
• Contact Details: Email address, phone number
• Tax Information: Tax identification number (TIN) and country of tax residence

For Corporate Clients:

• Certificate of Incorporation or equivalent business registration document
• Memorandum and Articles of Association or equivalent constitutional documents
• Shareholder Register: Information about beneficial owners (individuals owning 25% or more)
• Director Information: ID and proof of address for all directors
• Beneficial Owner Information: Full KYC for individuals with significant control
• Business Address: Registered office address and principal place of business
• Business License: Proof of legitimate business activity

3.2 Enhanced Due Diligence

Additional verification may be required if you are classified as higher risk, including if you:

• Are a Politically Exposed Person (PEP) or a close associate/family member of a PEP
• Reside in or have connections to high-risk jurisdictions
• Intend to make large deposits or high-volume transactions
• Are a business involved in high-risk industries (e.g., money service businesses, cryptocurrency exchanges)
• Have complex ownership structures
• Present inconsistent or unusual documentation

Enhanced due diligence may include:

• Additional documentation requests
• Source of funds verification
• Source of wealth documentation
• Video verification interview
• More frequent monitoring and reviews

4. Source of Funds and Wealth Verification

4.1 Source of Funds

We may require you to provide evidence of the source of funds you deposit with us. Acceptable documentation includes:

• Recent payslips or employment contract showing salary
• Business income statements or tax returns
• Sale of property documentation
• Investment statements showing liquidation of assets
• Inheritance documentation
• Gift letters with supporting documentation
• Bank statements showing the origin of funds

4.2 Source of Wealth

For higher-value relationships or enhanced due diligence cases, we may request information about your overall wealth, including:

• Employment history and income sources
• Business ownership and profitability
• Investments and asset portfolio
• Property ownership
• Inheritance or family wealth

5. Ongoing Monitoring and Review

5.1 Transaction Monitoring

We continuously monitor all client transactions for unusual or suspicious activity, including:

• Deposits or withdrawals that are inconsistent with your profile
• Patterns of activity that may indicate money laundering
• Rapid movement of funds in and out of accounts
• Transactions with no apparent economic purpose
• Activity inconsistent with your stated trading strategy
• Use of multiple accounts to obscure activity

5.2 Periodic Reviews

We conduct periodic reviews of client accounts based on risk classification:

• Low Risk Clients: Reviewed every 3 years
• Medium Risk Clients: Reviewed annually
• High Risk Clients: Reviewed every 6 months or more frequently

During reviews, we may request updated documentation and information to ensure our records remain current and accurate.

5.3 Information Updates

You are required to notify us promptly if there are any changes to:

• Your personal or contact information
• Your employment or financial circumstances
• Your PEP status
• Beneficial ownership of corporate accounts
• Any information previously provided during onboarding

6. Politically Exposed Persons (PEPs)

6.1 PEP Definition

A Politically Exposed Person is an individual who holds or has held a prominent public function, including:

• Heads of state, government, or ministers
• Senior government officials
• Senior judicial or military officials
• Senior executives of state-owned enterprises
• Important political party officials
• Members of parliament or similar legislative bodies

The definition also extends to immediate family members and known close associates of PEPs.

6.2 PEP Treatment

If you are identified as a PEP, we will:

• Conduct enhanced due diligence
• Obtain senior management approval to establish the business relationship
• Request additional documentation regarding source of funds and wealth
• Apply enhanced ongoing monitoring
• Conduct more frequent periodic reviews

7. Sanctions Screening

We screen all clients against international sanctions lists, including:

• United Nations Security Council sanctions lists
• EU sanctions lists
• UK HM Treasury sanctions lists
• US OFAC sanctions lists
• Other relevant international and national sanctions regimes

We also screen transactions for connections to sanctioned countries, entities, or individuals. Any matches result in immediate review and potential account restrictions or closure.

8. Suspicious Activity Reporting

8.1 Reporting Obligations

We are legally required to report suspicious activity to the appropriate authorities, including:

• The National Crime Agency (NCA) in the UK
• Financial Intelligence Units in other relevant jurisdictions
• Law enforcement agencies when required

8.2 What We Consider Suspicious

Activity that may be reported includes:

• Transactions with no apparent legitimate purpose
• Attempts to avoid reporting or identification requirements
• Unusual patterns of deposits and withdrawals
• Transactions involving high-risk jurisdictions
• Client reluctance to provide requested information
• Use of accounts in ways inconsistent with the account purpose
• Activity potentially linked to terrorist financing
• Structuring transactions to avoid thresholds

8.3 Tipping Off Prohibition

By law, we cannot inform you if we have made a suspicious activity report about your account or transactions. Doing so would constitute "tipping off," which is a criminal offense.

9. Restrictions and Prohibitions

9.1 Third-Party Payments

We do not accept third-party payments. All deposits must come from an account in your own name. Similarly, withdrawals will only be made to accounts in your name.

9.2 Restricted Jurisdictions

We do not accept clients from certain high-risk jurisdictions or sanctioned countries. A list of restricted countries is available on our website and is subject to change.

9.3 Prohibited Business Types

We may decline to provide services to businesses in certain high-risk categories, including but not limited to:

• Money service businesses (MSBs) without appropriate licenses
• Shell banks
• Unlicensed gambling or gaming operations
• Certain cryptocurrency-related businesses
• Businesses with anonymous ownership structures

9.4 Anonymous Accounts

We do not permit anonymous or pseudonymous accounts. All clients must be fully identified and verified.

10. Account Restrictions and Closures

We reserve the right to restrict or close your account if:

• You fail to provide required KYC documentation
• You provide false or misleading information
• You refuse to cooperate with verification procedures
• We identify suspicious activity in your account
• You are matched against sanctions lists
• Your risk profile changes in a way we cannot accommodate
• We are required to do so by law or regulation
• We cannot adequately assess the risk associated with your account

In some cases, we may be prohibited from providing you with specific reasons for account restrictions or closure.

11. Record Keeping

We are required to maintain records of:

• All identity verification documentation for at least 7 years after the end of the business relationship
• All transaction records for at least 7 years
• Copies of all correspondence and communications
• Records of internal analysis and decision-making
• Suspicious activity reports and related documentation

These records may be provided to regulators and law enforcement agencies upon request.

12. Staff Training and Compliance

All MarketsNova staff receive regular AML/KYC training to ensure they can:

• Recognize potential money laundering activity
• Properly implement KYC procedures
• Understand their legal obligations
• Know how to escalate concerns appropriately

We maintain a dedicated compliance function responsible for AML/KYC oversight, including a Money Laundering Reporting Officer (MLRO).

13. Data Privacy and Security

All information collected as part of our KYC process is handled in accordance with our Privacy Policy and applicable data protection laws. We implement robust security measures to protect your personal information from unauthorized access, use, or disclosure.

Your KYC information is only shared with:

• Authorized MarketsNova personnel who need it to perform their duties
• Third-party verification services (subject to confidentiality agreements)
• Regulators and law enforcement when legally required
• Service providers who assist with AML/KYC compliance

14. Client Cooperation

Your cooperation with our AML/KYC procedures is a condition of using our services. By opening an account, you agree to:

• Provide all requested documentation promptly and completely
• Update your information when changes occur
• Respond to periodic review requests
• Provide additional information or documentation if requested
• Accept that we may restrict or close your account if you do not cooperate

Failure to cooperate may result in account restrictions, inability to withdraw funds until verification is complete, or account closure.

15. Policy Updates

This AML/KYC policy is reviewed regularly and updated as necessary to reflect changes in:

• Applicable laws and regulations
• Industry best practices
• Our risk assessment
• Regulatory guidance

We will notify you of material changes to this policy. Continued use of our services after such changes constitutes acceptance of the updated policy.

16. Contact Information

If you have questions about our AML/KYC procedures or need assistance with verification, please contact our Compliance Department:

Email: compliance@marketsnova.com
Address: MarketsNova Compliance Department
123 Financial District, Suite 500
London, EC2V 7WS, United Kingdom

Money Laundering Reporting Officer (MLRO): mlro@marketsnova.com