Anti-Money Laundering Policy

Samtrade FX is committed to the highest standards of Anti-Money laundering (AML) compliance and requires management and employees to adhere to these standards to prevent use of our products and services for money laundering purposes. Samtrade FX will examine its Anti Money Laundering strategies, goals and objectives on an ongoing basis and maintains an effective Anti-Money Laundering program for the firm's business that reflects the best practices for a global financial brokerage. Adherence to the Samtrade FX's Anti-Money Laundering Program is the responsibility of all employees. The program includes client screening and monitoring requirements, “know your customer” policies (including the requirement to establish the identity of beneficial owners), record keeping requirements, the reporting of suspicious circumstances in accordance with relevant laws, and AML training.

Objectives

The standards set out in this Policy are minimum requirements based on applicable legal and regulatory requirements and apply for Samtrade FX. These requirements are intended to prevent Samtrade FX, our employees and clients from being misused for money laundering, terrorist financing or other financial crime. This Policy establishes the general framework for the fight against money laundering and financing of terrorism.

Applicability

Samtrade FX must ensure that the legal duties resulting from regulations set out are fulfilled by our subordinated subsidiaries and affiliates globally. Wherever local regulations are stricter than the requirements set out in this Policy, the stricter standard has to be applied. If any applicable laws are in conflict with this Policy, Samtrade FX must consult with the local legal department to resolve the conflict. If the minimum requirements set out in this Policy cannot be applied in a certain country because application would be against local law or cannot be enforced due to other than legal reasons, Samtrade FX has to assure that it will not

  • enter into a business relationship,
  • continue a business relationship or
  • carry out any transactions. If business relations already exist in that country, Samtrade FX has to assure that the business relationship is terminated regardless of other contractual or legal obligations.

Definition of the Term Money Laundering

Money Laundering is the introduction of assets derived from illegal and criminal activities (Predicate offences) into the legal financial and business cycle. Offences are for example forgery of money, extortionate robbery, drug crime as well as fraud, corruption, organized crime, or terrorism etc. Predicate offences for money laundering are defined by local law. Generally speaking, the money laundering process consists of three “stages”:

Placement: The introduction of illegally obtained monies or other valuables into financial or nonfinancial institutions.

Layering: Separating the proceeds of criminal activity from their source through the use of layers of complex financial transactions. These layers are designed to hamper the audit trail, disguise the origin of funds and provide anonymity.

Integration: Placing the laundered proceeds back into the economy in such a way that they reenter the financial system as apparently legitimate funds. These “stages” are not static and overlap broadly. Financial institutions may be misused at any point in the money laundering process.

MINIMUM REQUIREMENTS

All Samtrade FX's employees and senior management staffs have to comply with the following basic principles:

Ascertainment of customer identity: - When entering into a lasting business relationship, - When performing a single transaction or deal, - Before accepting cash or physical values worth 100.00 USD (or equivalent) outside an existing business relationship, also when performing a number of smaller payments adding up to this amount (smurfing) - When performing transfer of funds outside an existing business relationship value worth 1.000 - USD (or equivalent)

Establishment of purpose of business relationship: When entering into a lasting business relationship, Samtrade FX must obtain information on kind and purpose thereof, if this is not clear from the business relationship itself.

Identification of Ultimate Beneficial Owner: Whenever Samtrade FX is required to identify a customer, it must establish and verify the identity of the ultimate natural person, - who owns or - controls the customer or its assets or - on whose behalf the transaction is carried out or the business relationship is established

Client account monitoring: A permanent monitoring of clients' accounts must be implemented to detect unusual/suspicious transactions (Withdrawals and Trading). Monitoring must be effected for applicable business areas using adequate processes and systems.

Forbidden business: Payable through accounts and relationships with shell banks are forbidden for Samtrade FX.

Reporting of suspicious circumstances/transactions: Such circumstances/transactions must be reported to the competent authorities according to local law. Group Anti Money Laundering must be informed about all suspicious events, if not explicitly prohibited by local law.

Staff reliability: Samtrade FX must not employ staff who are deemed not reliable.

Anti Money Laundering controls: The responsible Anti Money Laundering Officer must ensure by adequate customer- and business related controls that all applicable AML requirements are being adhered to and security measures are properly functioning.

Anti Money Laundering Training: All employees (including trainees and temporary personnel) responsible for carrying out transactions (Initial Depositing, Withdrawals and actual trading) and/or for initiating and/or establishing business must undergo anti money laundering training. Initial training must be attended within one month after an employee has joined Samtrade FX and subsequently every year. Minimum content training requirements defined by the firm have to be adhered to.

Anti Money Laundering Risk Analysis: Samtrade FX has set up a system to assess the level of risk exposure considering product and client risk and derive appropriate security measures from this analysis.

RECORD RETENTION

Records must be kept of all transaction data and data obtained for the purpose of identification, as well as of all documents related to money laundering topics (e.g. files on suspicious activity reports, documentation of AML account monitoring, etc.). Those records must be kept for a minimum of 10 years.

PROHIBITED BUSINESS RELATIONSHIPS

Samtrade FX must refuse to open an account/enter into a relationship or has to close an existing account/terminate a relationship, if the firm cannot form a reasonable belief that it knows the true identity of the client and/or UBOs and/or the nature of business or formal requirements concerning the identification of the client and/or UBOs are not met. In particular, the firm will not

  • Accept monies that are known or suspected to be the proceeds of criminal activity
  • Enter into/maintain business relationships with individuals or entities known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists
  • Enter into relationships with clients from Special Risk Countries or
  • Enter into relationships with clients operating in prohibited industries

RESEARCH AND FILLING OF SUSPICIOUS ACTIVITY & TRANSACTION REPORTS

Suspicious activities must be properly handled and escalated within Samtrade FX. Regular AML training ensures that staff are reminded of their duty to timely report any suspicious activity, where allowed under local regulations.

MANAGEMENT AND CONTROLS OF AML RISKS

Samtrade FX has developed and implemented a comprehensive set of measures to identify, manage and control its AML risk. These measures are:

  • A Global-wide AML Risk Analysis
  • Controls
  • A robust and strict KYC program
  • A training and awareness program for Samtrade FX's staff
  • Processes to ensure staff reliability

Risk Analysis

Samtrade FX has implemented an ongoing AML Risk Analysis to assess the level of risk exposure considering the firm's customers, products, services, entities and geographic locations risk and to derive appropriate security measures from this analysis. AML safeguards are derived from the results of the AML Risk Analysis.

Controls

Adherence to the global-wide AML program needs to be reviewed regularly to ensure that the firm's efforts are successful. The AML Officer in Samtrade FX is therefore obliged to conduct appropriate controls. The responsible AML Officer must ensure, by implementing adequate customer- and business related controls, that all applicable AML requirements are being adhered to and security measures are properly functioning.

KYC Program

Samtrade FX has implemented a strict KYC program to ensure all kinds of customers (natural or legal persons or legal structures) are subject to adequate identification, risk rating and monitoring measures. This program has been implemented globally. KYC includes not only knowing the clients and entities the firm deals with, or renders services to, but also the Ultimate Beneficial Owners (UBOs), Legal Representatives and Authorised Signatories as appropriate. The program includes strict identification requirements, name screening procedures and the ongoing monitoring and regular review of all existing business relationships. Special safeguards are implemented for business relationships with politically exposed persons (PEPs) and clients from countries or industries deemed high risk.

Training Program

Samtrade FX has implemented a comprehensive AML training program to ensure that all staff, in particular individuals responsible for transaction processing and/or initiating and/or establishing business relationships, undergo AML awareness training. Samtrade FX's training is tailored to the business to ensure that staff are aware of different possible patterns and techniques of money laundering which may occur in their everyday business. Training also covers the general duties arising from applicable external (legal and regulatory), internal requirements and the resulting individual duties which must be adhered to in everyday business as well as typologies to recognize money laundering or financial crime activities.

Reliability of Staff

Samtrade FX has implemented processes to ensure that only reliable individuals are employed.

INDEPENDENT TESTING

Adherence to the requirements of Samtrade FX's AML program is subject to independent testing by Samtrade FX's Internal Audit function and the Semi - Annual External Auditor.


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