FXDD, operated by Triton Capital Markets Ltd (FXDD or the “Company”) is licensed to conduct investment services business in terms of the Investment Services Act (Chapter 370 of the Laws of Malta) and has a Class 2 Investment Services license issued by the Malta Financial Services Authority (“MFSA”). Accordingly, the Company falls within the scope of the Prevention of Money Laundering Act (Cap. 373) (hereafter referred to as the PMLA), the Prevention of Money Laundering and Funding of Terrorism Regulations (LN 180/2008) (hereafter referred to as the PMLFTR), the Criminal Code (Chapter 9 of the Laws of Malta) and the Financial Intelligence Analysis Unit (hereafter referred to as the FIAU) Implementing Procedures Part 1 first issued on 20 May 2011, last amended 25 September 2020.

FXDD recognizes the importance of adopting and applying adequate measures to prevent and suppress Money Laundering & Terrorist Financing. Accordingly, the Company is committed to the prevention of financial crime such as money laundering and the funding of terrorist activity.

Scope

This policy aims to establish the general framework for the fight against money laundering and terrorism financing. FXDD is committed to high standards of anti-money laundering/terrorism financing (AML/TF) compliance and requires its employees to adhere to these standards to prevent the use of its products and services for money laundering terrorism financing purposes.

Know your customer Policy

According to the Prevention of Money Laundering Act (Cap. 373) (hereafter referred to as the PMLA), FXDD is required to:

• determine who the customer and, where applicable, any beneficial owner;
• verify whether that person is the person he/she purports to be;
• determine whether a person is acting on his/her behalf or behalf of another person (e.g., an agent, signatory, attorney, etc.);
• establish the purpose and intended nature of the business relationship, and the customer’s business and risk profile;
• obtain and verify the source of wealth and source of funds of the Customer and any beneficial owner;
• monitor the customer relationship on an ongoing basis.

In pursuance of adhering to the above regulations, FXDD collects the aforementioned information at the onboarding stage via the online registration form and throughout the course of the business relationship via the KYC form.

As part of the due diligence process and in accordance with the PLMFTR, FXDD will identify and verify the identity and residential address of all its customers, among the other requirements stipulated above.

The customer identification and verification process is completed via the online registration form at onboarding and throughout the business relationship. Subsequently, in order to verify that the information declared by the customer is accurate, FXDD will request the customer as a minimum to provide the following:

• a government-issued photo document;
• a proof of address document issued within the last six months by a regulated utility company (telephone bills not accepted).

The documents are also uploaded to a 3rd party verification service provider prior to the customer making a deposit. Corporate accounts are subject to compliance approval before onboarding. As such, the level of documentation requested is assessed on a case-by-case basis according to the Company’s internal policies and procedures.

The level of due diligence that will be applied to each natural customer is determined by the Company’s internal policies and procedures. As such, some customer might be asked to provide additional documents than the ones stipulated above.

Periodically, FXDD will request the client to provide updates to the personal information provided at the onboarding stage and throughout the course of the relationship. This ensures that the customer data and information are kept up to date to reflect an accurate customer profile.

Prohibitions

FXDD has a number of internal prohibitions in place, including but not limited to:

• FXDD does not accept cash deposits;
• FXDD does not accept third party payments or transfers of funds sent or received into an account by a third party (or another person). This method of payment is generally not allowed by the Company. In certain restricted circumstances, a third party payment request may only be approved by the MLRO;FXDD does not accept clients residing or born in Iran;
• FXDD does not accept clients residing or born in North Korea;
• FXDD does not accept clients residing in the USA;
• FXDD does not accept clients residing in USA overseas territories;
• FXDD does not accept clients residing in Japan;
• FXDD does not allow clients who are employees of exchanges and regulatory bodies to open an account unless they provide a letter from their Compliance Officer permitting them to open the account;
• FXDD does not accept clients who fail or refuse to provide the necessary information to open an account;
• FXDD does not accept anonymous accounts or accounts in fictitious names;
• FXDD will not onboard a customer whose wealth was derived from criminal activities or whose occupation is not legal;
• FXDD will not accept clients who have been sanctioned by the UN, OFAC, or the EU or are related persons to individuals who have been sanctioned;
• FXDD will not accept corporate customers who make use of bearer share;
• FXDD will not accept corporate customers who have a legal structure that makes identifying the ultimate beneficial owner impossible.

The above list is subject to periodic reviews and updates.

Training of employees

FXDD conducts extensive due diligence on its employees before recruitment. In addition, FXDD’S employees are provided with regular training in order to create and maintain a satisfying AML/CTF awareness.

Record Keeping

Records of personal data obtained for the purposes of the prevention of money laundering and terrorist financing are processed and kept in accordance with the EU General Data Protection Regulation (GDPR) for at least five (5) years past the date of the account termination.

More information on the Company’s privacy policy can be found here.

Regular audits and reviews

Reputable audit firms carry out regular audits in order to ensure that the policies and procedures are being complied with. In addition, the FXDD’s policies and procedures are regularly reviewed to ascertain that these reflect the current regulations and external environment.

Should you have any questions or queries regarding the contents of this policy please do not hesitate to contact us at [email protected]