Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy

Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy

Saint Lucia

1. Purpose

This policy establishes the internal framework of YES THE BROKER, hereinafter referred to as the Company, for the prevention, detection, and reporting of activities related to money laundering and terrorism financing, in compliance with:
– Anti-Money Laundering Act (Cap. 12.20, Revised Laws of Saint Lucia).
– Counter-Terrorism Act (Cap. 3.16, Revised Laws of Saint Lucia).
– Guidelines issued by the Financial Intelligence Authority (FIA) of Saint Lucia.
– International recommendations of the Financial Action Task Force (FATF).

2. Scope

This policy applies to:
– All employees, agents, and directors of YES THE BROKER.
– All clients, whether introduced directly or indirectly.
– All products and services offered by the Company, including Contracts for Difference (CFDs), leverage, and copy trading services.

3. Guiding Principles
4. Regulatory Compliance: Strict adherence to applicable local and international laws and regulations.
   2. Risk-Based Approach (RBA): Identification, assessment, and mitigation of risks based on the client’s profile and the nature of operations.
   3. Transparency and Traceability: Implementation of KYC (Know Your Customer) and CDD (Customer Due Diligence) prior to account opening.
   4. Timely Reporting: Full cooperation with the FIA through the filing of Suspicious Transaction Reports (STRs) when required.
5. Customer Due Diligence (CDD/KYC) Procedures

– Identification and Verification: Collection of official identification documents, proof of address, source of funds, and risk profiling.
– Ultimate Beneficial Owner (UBO): Verification of the beneficial ownership structure for corporate or trust clients.
– Risk Classification: Categorization of clients (low, medium, high risk) considering jurisdiction, business activity, transaction amounts, leverage usage, and political exposure (PEPs).
– Enhanced Due Diligence (EDD): Applied to high-risk clients, including deeper scrutiny of funds’ origin, enhanced monitoring, and senior management approval.

5. Transaction Monitoring

– Thresholds: Registration and monitoring of all transactions above USD 10,000 or equivalent.
– Suspicious Patterns Detection: Including but not limited to:
   • Recurrent transactions without economic justification.
   • Structured deposits (smurfing).
   • Transfers to or from high-risk jurisdictions.
   • Use of multiple accounts without legitimate purpose.
– Immediate Reporting: Internal reporting to the MLRO (Money Laundering Reporting Officer) and, if validated, filing with the FIA.

6. Responsibilities

– Board of Directors: Ensure adequate resources and oversight of the AML/CFT program.
– MLRO (Money Laundering Reporting Officer): Appointed individual responsible for policy enforcement, liaison with the FIA, and staff training.
– Employees and Agents: Must comply with this policy and report unusual activities to the MLRO without delay.

7. Training

YES THE BROKER will provide mandatory and continuous training for its staff, focused on:
– Identification of red flags in CFD trading.
– Proper use of monitoring and reporting systems.
– Legal and regulatory responsibilities of each employee.

8. Record Keeping

The Company will retain, for a minimum period of 7 years:
– Client identification documents.
– Transaction records.
– Internal reports and filings made to the FIA.

9. Audit and Review

– This AML/CFT policy will be reviewed annually or upon any regulatory change.
– Independent internal and external audits will be conducted to ensure effectiveness and compliance.

10. Internal Sanctions

Failure to comply with this policy by directors, employees, or agents shall be considered a serious breach, subject to:
– Termination of contract.
– Disciplinary action.
– Immediate reporting to competent authorities.

Signed by:
YES THE BROKER
Saint Lucia