ANTI-MONEY LAUNDERING (AML) POLICY

1. INTRODUCTION

Money laundering is the process of disguising the origins of illegally obtained funds to make them appear legitimate. It poses a significant risk to financial institutions and businesses, enabling criminal activities such as fraud, corruption, tax evasion, drug trafficking, and terrorism financing.

This Anti-Money Laundering (AML) Policy outlines our commitment to compliance with Saint Lucia’s legal framework, including:

• The Money Laundering (Prevention) Act (MLPA)
• The Proceeds of Crime Act (POCA)
• The Financial Intelligence Authority Act (FIA)
• Guidelines issued by the Financial Services Regulatory Authority (FSRA)

This policy ensures that our institution takes appropriate measures to prevent, detect, and report money laundering and terrorist financing activities in compliance with Saint Lucia’s AML/CFT regulations.

2. LEGAL & REGULATORY FRAMEWORK

This AML Policy aligns with Saint Lucia’s regulatory requirements, including:

• Money Laundering (Prevention) Act (MLPA): Establishes AML obligations for financial and non-financial institutions, including reporting, due diligence, and compliance requirements.
• Proceeds of Crime Act (POCA): Outlines asset confiscation measures and criminalizes money laundering offenses.
• Financial Intelligence Authority Act (FIA): Establishes the Financial Intelligence Authority (FIA), responsible for receiving and analyzing suspicious transaction reports (STRs).
• Financial Services Regulatory Authority (FSRA) Guidelines: Mandates compliance with KYC, record-keeping, and AML/CFT risk assessment procedures.

3. KEY PRINCIPLES OF AML COMPLIANCE

Our company follows a risk-based approach (RBA) in detecting and preventing financial crimes. The following principles guide our AML framework:

3.1. Know Your Customer (KYC) & Customer Due Diligence (CDD)

• Mandatory verification of customer identity before initiating transactions.
• Collection of official identification, proof of address, and source of funds.
• Risk classification of clients as low, medium, or high-risk.

3.2. Enhanced Due Diligence (EDD) for High-Risk Clients

• Additional verification for Politically Exposed Persons (PEPs), offshore entities, and high-value transactions.
• Ongoing monitoring of customer accounts and transaction patterns.

3.3. Transaction Monitoring & Suspicious Activity Reporting

• Continuous tracking of transactions to detect unusual activity, structuring, or layering techniques.
• Filing of Suspicious Transaction Reports (STRs) to the Financial Intelligence Authority (FIA) within 14 days as per MLPA Section 16.

3.4. Record-Keeping Requirements

• Maintenance of transaction records, KYC documentation, and compliance reports for at least 7 years, as required by MLPA Section 15.

3.5. Sanctions Compliance & PEP Screening

• Screening of clients against global sanctions lists, including UN, OFAC, and EU restrictive measures.
• Identification of Politically Exposed Persons (PEPs) and their associated risk levels.

4. CUSTOMER DUE DILIGENCE (CDD) REQUIREMENTS

A. Standard Due Diligence (SDD) – Required for all clients:

• Full name and date of birth
• Government-issued ID (passport, driver’s license)
• Proof of address (utility bill, bank statement)
• Source of funds verification

B. Enhanced Due Diligence (EDD) – Required for high-risk clients:

• Additional supporting documents on financial background
• Justification for transactions exceeding EC$50,000
• Continuous transaction monitoring and periodic review

C. Third-Party Reliance

• When relying on third-party institutions for KYC compliance, we ensure they are regulated and approved under FSRA guidelines.
• A formal Third-Party Agreement is required, ensuring adherence to MLPA requirements.

5. REPORTING REQUIREMENTS

As per Saint Lucia’s AML framework, we are required to report:

• Suspicious Transaction Reports (STRs): Must be filed within 14 days to the Financial Intelligence Authority (FIA) if any activity suggests money laundering or terrorism financing.
• Threshold Transaction Reports (TTRs): Mandatory reporting of transactions exceeding EC$50,000 to regulatory authorities.
• Cross-Border Cash Reporting: Clients conducting cross-border transfers exceeding EC$20,000 must declare the funds and provide supporting documentation.

6. AML COMPLIANCE PROGRAM

To ensure compliance, we maintain a robust AML program that includes:

• Appointment of an AML Compliance Officer – A designated individual responsible for monitoring compliance, conducting internal audits, and reporting STRs.
• Employee Training & Awareness – All staff members undergo annual AML training on regulatory obligations and risk identification.
• Independent AML Audits – Periodic third-party audits are conducted to evaluate the effectiveness of the AML program.
• Internal Controls & Risk Assessments – Ongoing assessment of financial crime risks and implementation of mitigation strategies.

7. PENALTIES FOR NON-COMPLIANCE

Failure to comply with Saint Lucia’s AML laws may result in:

• Criminal Penalties: Fines up to EC$1,000,000 or imprisonment under MLPA Section 23.
• Regulatory Sanctions: License suspension, revocation, or administrative fines imposed by FSRA.
• Reputational Damage: Loss of business credibility and potential regulatory blacklisting.

8. CONCLUSION & POLICY REVIEW

This AML Policy is reviewed annually to ensure compliance with:

• Legislative updates
• Regulatory guidance from FSRA
• Evolving AML/CFT risk factors

All employees, agents, and stakeholders must acknowledge and comply with the provisions outlined in this policy.

Effective Date: 15th March 2024
Last Reviewed: 15th March 2024

Authorized Representative:
IOANNIS A. ANGELI
AML Compliance Officer
Tradona Markets Ltd.