AML/KYC Policy

LuxoraFX is committed to maintaining the highest standards of compliance with anti-money laundering (AML) and know your customer (KYC) regulations. As a proprietary trading firm operating in the financial services sector, we have implemented comprehensive policies and procedures to prevent money laundering, terrorist financing, and other financial crimes.

This policy outlines our commitment to compliance with applicable AML/KYC laws and regulations, including but not limited to the UAE Anti-Money Laundering Law, international FATF recommendations, and other relevant regulatory requirements in jurisdictions where we operate.

All employees, contractors, and business partners of LuxoraFX are required to comply with this policy and report any suspicious activities or potential violations to our compliance team.

2.1 Applicable Laws and Regulations: Our AML/KYC program complies with:

• UAE Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism
• Financial Action Task Force (FATF) recommendations
• Central Bank of UAE regulations and guidelines
• International sanctions and embargo requirements
• Relevant regulations in client jurisdictions

2.2 Regulatory Reporting: We maintain regular communication with relevant regulatory authorities and provide required reports on:

• Suspicious transaction reports (STRs)
• Large transaction reports
• Client due diligence updates
• Compliance monitoring results
• Policy and procedure updates

2.3 Sanctions Compliance: We screen all clients and transactions against international sanctions lists, including but not limited to UN, EU, US OFAC, and UAE sanctions programs.

3.1 Identity Verification: All clients must provide the following documentation for identity verification:

• Government-issued photo identification (passport, national ID, or driver's license)
• Proof of address (utility bill, bank statement, or government correspondence)
• Additional documentation as required based on risk assessment
• Biometric verification where technically feasible
• Video verification for high-risk clients

3.2 Source of Funds Verification: Clients must provide evidence of the legitimate source of funds, including:

• Employment verification and salary certificates
• Bank statements showing fund sources
• Business registration and financial statements (for business clients)
• Investment portfolio statements
• Other relevant financial documentation

3.3 Enhanced Due Diligence (EDD): Additional verification measures apply to:

• Politically Exposed Persons (PEPs) and their associates
• Clients from high-risk jurisdictions
• High-value transactions or account balances
• Complex corporate structures
• Clients with unusual transaction patterns

4.1 Risk Factors: We assess client risk based on multiple factors including:

• Geographic risk (client residence and transaction locations)
• Product and service risk (evaluation programs and funding levels)
• Client risk (occupation, source of funds, transaction patterns)
• Delivery channel risk (online platforms, payment methods)
• Political exposure and sanctions screening results

4.2 Risk Categories: Clients are classified into risk categories:

• Low Risk: Standard CDD procedures and annual reviews
• Medium Risk: Enhanced monitoring and semi-annual reviews
• High Risk: Enhanced due diligence and quarterly reviews
• Prohibited: Clients who cannot be onboarded due to compliance concerns

4.3 Ongoing Monitoring: Risk assessments are reviewed and updated based on:

• Changes in client circumstances or behavior
• New regulatory requirements or sanctions
• Unusual transaction patterns or activities
• Periodic risk assessment reviews
• External intelligence and adverse media

5.1 Automated Monitoring: We employ sophisticated monitoring systems to detect:

• Unusual trading patterns or volumes
• Rapid deposit and withdrawal cycles
• Transactions inconsistent with client profiles
• Potential structuring or layering activities
• Connections to sanctioned entities or jurisdictions

5.2 Manual Review Process: Suspicious activities trigger manual review procedures including:

• Detailed transaction analysis and investigation
• Client contact and additional documentation requests
• Enhanced monitoring and account restrictions
• Escalation to senior compliance officers
• Potential suspicious transaction reporting

5.3 Reporting Thresholds: We report transactions that meet regulatory thresholds or exhibit suspicious characteristics, regardless of amount.

6.1 Prohibited Activities: The following activities are strictly prohibited:

• Money laundering and terrorist financing
• Transactions involving sanctioned entities or jurisdictions
• Structuring transactions to avoid reporting requirements
• Using false or fraudulent identification documents
• Facilitating illegal activities through our platforms
• Providing services to shell companies without legitimate business purpose

6.2 Red Flag Indicators: We monitor for suspicious activities including:

• Reluctance to provide required documentation
• Inconsistent or contradictory information
• Unusual payment methods or funding sources
• Rapid movement of funds without apparent trading purpose
• Requests for excessive privacy or anonymity
• Connections to high-risk jurisdictions or entities

6.3 Immediate Actions: Upon detecting prohibited activities, we will:

• Immediately suspend the account and freeze assets
• Conduct thorough investigation and documentation
• File suspicious transaction reports with authorities
• Cooperate fully with law enforcement investigations
• Terminate the business relationship if necessary

7.1 Documentation Requirements: We maintain comprehensive records including:

• Client identification and verification documents
• Transaction records and supporting documentation
• Risk assessment and due diligence reports
• Suspicious transaction reports and investigations
• Training records and compliance monitoring results
• Correspondence with regulatory authorities

7.2 Retention Periods: Records are retained for minimum periods as required by law:

• Client identification records: 5 years after account closure
• Transaction records: 5 years after transaction completion
• Suspicious transaction reports: 5 years after filing
• Training and compliance records: 5 years after creation
• Regulatory correspondence: 7 years after communication

7.3 Data Security: All records are maintained with appropriate security measures including encryption, access controls, and backup procedures to ensure confidentiality and integrity.

8.1 Employee Training: All employees receive comprehensive AML/KYC training covering:

• Applicable laws and regulations
• Company policies and procedures
• Red flag identification and reporting
• Customer due diligence requirements
• Sanctions screening and compliance
• Record keeping and documentation standards

8.2 Ongoing Education: Training programs include:

• Initial onboarding training for new employees
• Annual refresher training for all staff
• Specialized training for compliance and risk management teams
• Updates on regulatory changes and new requirements
• Case studies and practical exercises

8.3 Performance Monitoring: We monitor training effectiveness through testing, assessments, and performance evaluations to ensure compliance competency.

9.1 Compliance Structure: Our AML/KYC program is overseen by:

• Chief Compliance Officer responsible for program oversight
• AML/KYC specialists handling day-to-day operations
• Senior management providing strategic direction
• Board-level oversight and approval of policies
• Independent audit and review functions

9.2 Regular Reviews: We conduct periodic reviews of:

• Policy effectiveness and regulatory compliance
• Risk assessment methodologies and results
• Transaction monitoring system performance
• Training program effectiveness
• Regulatory developments and industry best practices

9.3 Continuous Improvement: We regularly update our AML/KYC program based on regulatory changes, industry developments, and internal assessments.

For questions about our AML/KYC policies or to report suspicious activities, please contact:

Confidential Reporting: All reports of suspicious activities are treated with strict confidentiality and in accordance with applicable whistleblower protection laws.