AML Policy

Introduction

Prop FinTech is committed to preventing money laundering, terrorist financing, and all forms of illicit financial activity. This Anti-Money Laundering (AML) Policy outlines the framework through which Prop FinTech ensures compliance with applicable AML laws, regulations, and industry standards relevant to proprietary trading and financial technology operations.

Scope

This policy applies to all Prop FinTech employees, directors, contractors, funded traders, clients, technology partners, and any third parties interacting with the firm’s platforms or services. Prop FinTech is dedicated to preventing the misuse of its systems, including payment channels, trader onboarding, data services, and trading technology, for money laundering or the financing of criminal activities.

AML Compliance Officer

Prop FinTech has appointed an AML Compliance Officer (AMLCO) responsible for developing, supervising, and enforcing the AML Program. Responsibilities include:

• Ensuring Prop FinTech complies with all applicable AML regulations.
• Conducting and updating periodic AML and business-wide risk assessments.
• Filing Suspicious Activity Reports (SARs) with the relevant authorities, when required.
• Providing AML and KYC training across the organization.
• Overseeing record-keeping of client identification documents, transaction data, and internal compliance reports.
• Acting as the primary contact point for regulators and law enforcement agencies.

Client Due Diligence (CDD)

Prop FinTech implements risk-based Client Due Diligence procedures for all users, traders, and business partners. These include:

Know Your Customer (KYC)

• Verifying the identity of clients and prospective traders.
• Collecting and validating documentation such as government-issued IDs, proof of address, and, when applicable, business registration records.
• Using approved identity-verification technologies and third-party KYC providers.

Enhanced Due Diligence (EDD)

EDD is applied to higher-risk users, including:

• Politically Exposed Persons (PEPs).
• Individuals or entities from high-risk jurisdictions identified by FATF or national authorities.
• Clients with complex ownership structures or unclear sources of funds.
• Any user displaying elevated AML risk indicators.

Ongoing Monitoring

Prop FinTech performs continuous monitoring of user activity, including:

• Tracking trading behavior and payment flows for unusual patterns.
• Reviewing inconsistencies between a client’s profile and their financial activity.
• Conducting periodic refreshes of KYC information, depending on risk level.

Risk Assessment

Prop FinTech conducts regular assessments to identify and address AML risks across its operations. This includes:

• Evaluating the risk profile of individual clients and funded traders.
• Assessing geographic, product, service, and platform-specific risks.
• Reviewing transaction size, frequency, and purpose.
• Monitoring emerging risks and typologies relevant to fintech, proprietary trading, and online payments.

Restricted Countries List

To comply with international sanctions and AML regulations, Prop FinTech does not onboard or engage with clients (residents or nationals), entities, or counterparties from the following restricted jurisdictions:

Fully Restricted Countries:

Afghanistan, Belarus, Cuba, Iran, North Korea (DPRK), Russia (including Crimea, Donetsk, and Luhansk regions), Syria, Venezuela (Certain sanctioned parties and government officials), Myanmar (Burma), Yemen, Sudan, South Sudan, Central African Republic, Democratic Republic of Congo, Eritrea, Ethiopia (specific regions), Iraq, Lebanon, Libya, Mali, Nicaragua, Somalia, Zimbabwe.

Suspicious Activity Reporting (SAR)

Prop FinTech requires immediate escalation of potential suspicious activity. All employees must:

• Identify transactions or behavior lacking an apparent legitimate purpose.
• Report concerns to the AML Compliance Officer without delay.
• Refrain from informing the client or any unauthorized party (no “tipping off”).
• Assist the AMLCO in gathering relevant data for SAR filings.

Record Keeping

Prop FinTech maintains AML-related records for at least five years or longer if legally required. These records include:

• KYC and identity verification documents.
• Trading activity logs and payment histories.
• Internal suspicious activity reports and investigations.
• Compliance training records and audit results.
• Risk assessments and AML policy updates.

Employee Training and Awareness

All Prop FinTech employees must complete AML training appropriate to their job function. Training covers:

• Recognizing red flags associated with money laundering and terrorist financing.
• Understanding obligations under AML laws and company policies.
• Correct procedures for escalating suspicious activity.
• Updates on regulatory and typology changes.

Training is conducted upon hiring and periodically thereafter.

Removal of links from our website

If you find any link on our Website that is offensive for any reason, you are free to contact and inform us at any moment. We will consider requests to remove links, but we are not obligated to do so or to respond to you directly.

We do not ensure that the information on this website is correct; we do not warrant its completeness or accuracy; nor do we promise to ensure that the website remains available or that the material on the website is kept up to date.

Compliance Audits

Prop FinTech conducts regular internal and external audits to assess the effectiveness of its AML program. Audits evaluate:

• Adequacy of policies and procedures.
• Compliance with regulatory obligations.
• Accuracy of record-keeping and reporting mechanisms.
• Employee understanding and application of AML controls.

Sanctions and Penalties

Non-compliance with this policy may result in:

• Disciplinary measures up to and including termination.
• Restriction or termination of client or trader relationships.
• Civil or criminal penalties imposed by regulatory authorities.
• Reporting of involved individuals or entities to relevant agencies.

Policy Review

This policy is reviewed annually, or sooner if required due to:

• Regulatory or legal changes.
• Emerging AML threats.
• Changes in Prop FinTech’s business model, technology, or risk profile.