The following policy has been derived from the general principles, laws, regulations and directives for combating money laundering.
trader-cap takes security measures and has adopted policies, practices and procedures that promote high ethical and professional standards and prevent trader-cap from being used, intentionally or unintentionally, by criminal elements.
trader-cap has put in place Know-Your-Customer (KYC) programs as an essential element for service, risk management and control procedures.
Such programs include:
trader-cap is obliged not only to establish the identity of its customers, but also to monitor account activity to determine those transactions that do not conform with the normal or expected transactions for that customer or type of account. KYC constitutes a core feature of services’ risk management and control procedures. The intensity of KYC programs beyond these essential elements is tailored to the degree of risk.
CUSTOMER ACCEPTANCE POLICY
trader-cap maintains clear customer acceptance policies and procedures, including a description of the types of customers that are likely to pose a higher-than-average risk. Before accepting a potential client, KYC and due diligence procedures are followed, by examining factors such as customers’ background, country of origin, public or high-profile position, linked accounts, business activities or other risk indicators.
Extensive due diligence is essential for an individual with high net worth but whose source of funds is unclear. New clients’ money is transferred through a reputable bank. Banks have their own anti-money laundering procedures. A decision to enter into business relationships with higher risk customers, such as politically exposed persons, is taken exclusively at senior management level.
Please note that we do not accept US Citizens.
CUSTOMER IDENTIFICATION
Customer identification is an essential element of KYC standards. For the purposes of this document, a customer includes:
trader-cap maintains a systematic procedure for identifying new customers and cannot enter a service relationship until the identity of a new customer is satisfactorily verified.
Procedures for identification of customers and those acting on their behalf are implemented and executed with due diligence. The best documents for verifying the identity of customers are those most difficult to obtain illicitly and to counterfeit. trader-cap pays special attention in the case of non-resident customers and in no case are short-circuit identity procedures followed just because the new customer is unable to present the relevant documentation and information to satisfy the KYC and due diligence procedures.
The customer identification process applies naturally at the outset of the relationship. To ensure that records remain up-to-date and relevant, trader-cap undertakes regular reviews of existing records. An appropriate time to do so is when a transaction of significance takes place, when customer documentation standards change substantially, or when there is a material change in the way that the account is operated.
However, if the AML/CFT (anti-money laundering and countering the financing of terrorism) Supervisor for trader-cap (AML/CFT Supervisor) becomes aware at any time, through compliance and/or AML/CFT Supervisor reviews, that it lacks sufficient information about an existing customer, immediate steps are taken to ensure that all relevant information is obtained as quickly as possible.
trader-cap can be exposed to reputational risk and should therefore apply enhanced due diligence to such operations. Private accounts, which by nature involve a large measure of confidentiality, can be opened in the name of an individual, a commercial business, a trust, an intermediary or a personalized investment trader-cap.
In each case reputational risk may arise if trader-cap does not diligently follow established KYC procedures. All new clients and new accounts are approved by at least one person the Company’s Customer Financial Officer or its own AML/CFT Officer. In case of a new high-risk customer, the final decision is taken by the Company’s managing director.
Particular safeguards have been put in place internally to protect confidentiality of customers and their business. trader-cap ensures that equivalent scrutiny and monitoring of these customers and their business is conducted, e.g. it is available to be reviewed by the AML/CFT Supervisor and auditors.
trader-cap maintains clear standards and policies, on what records must be kept for customer identification and individual transactions. Such practice is essential to permit trader-cap to monitor its relationship with the customer, to understand the customer’s on-going business and, if necessary, to provide evidence in the event of disputes, legal action, or a financial investigation that could lead to criminal prosecution.
As the starting point and follow-up of the identification process, trader-cap obtains customer identification papers and retain copies of them for at least five years after an account is closed. trader-cap also retains all financial transaction records for at least five years from the date when trader-cap’s relationship with the client was terminated or a transaction was completed.
GENERAL IDENTIFICATION REQUIREMENTS
trader-cap obtains all information necessary to establish to its full satisfaction the identity of each new customer and the purpose and intended nature of the business relationship. The extent and nature of the information depends on the type of applicant (personal, corporate, etc.) and the expected size of the account.
When an account has been opened, but problems of verification arise in the service relationship which cannot be resolved, trader-cap can close the account and return the money to the source from which it was received.
While the transfer of an opening balance from an account in the customer’s name in another organization subject to the same KYC standard will be considered, trader-cap follow its own KYC procedures. trader-cap can consider the possibility that the previous account manager may have asked for the account to be removed because of a concern about dubious activities.
Naturally, customers have the right to move their business from one organization to another. However, if trader-cap has any reason to believe that an applicant is being refused service facilities by another organization, trader-cap is duty-bound to engage in enhanced due diligence procedures to the customer.
trader-cap will not agree to open an account or conduct on-going business with a customer who insists on anonymity or who gives a fictitious name. Nor should confidential numbered accounts function as anonymous accounts but they should be subject to exactly the same KYC procedures as all other customer accounts, even if the test is carried out by selected staff. Whereas a numbered account can offer additional protection for the identity of the account-holder, the identity must be known to a sufficient number of staff to operate proper due diligence.
SPECIFIC CUSTOMER DUE DILIGENCE AND IDENTITY PROCEDURES
Client identification must be carried out as soon as reasonably practicable after first contact is made. As part of its obligation to exercise due diligence in customer identification, trader-cap must confirm that the identity information which it holds for its customers remains fully updated with all necessary identification and information throughout the business relationship. trader-cap reviews and monitors on a regular basis the validity and adequacy of customer identification information in its possession.
Notwithstanding the above and taking into account the degree of risk, if it becomes apparent at any time during the business relationship that trader-cap lacks sufficient or reliable evidence (data) and information on the identity and financial profile of an existing customer, trader-cap will immediately takes all necessary actions using the identification procedures and measures to provide due diligence, in order to collect the missing data and information as quickly as possible and in order to determine the identity and create a comprehensive financial profile of the customer.
Furthermore, trader-cap monitors the adequacy of the information held and identity and economic portrait of its customers when and where one of the following events occurrences:
Conduct of a significant transaction that appears to be unusual and/or significant as against the usual type of trade and economic profile of the customer;
A significant change in the situation and legal status of the customer such as:
A significant change in the operating rules of the customer’s account, such as:
In case of customer transaction via internet, phone, fax or other electronic means where the customer is not present to verify the authenticity of his/her signature, or that is the person who actually owns the account, or is authorized to handle the account, trader-cap has established reliable methods, procedures and practices to control access to electronic means to ensure that deals with the actual owner or authorized signatory of the account.
Where the customer refuses or fails to provide trader-cap with the required documents and information for identification and creation of a financial portrait, before entering into the business relationship, or during the execution of an individual transaction without adequate justification, trader-cap will not proceed in a contractual relationship or will not execute the transaction and may also report it to the AML/CFT Supervisor. This can lead to a suspicion that the customer is engaged in money laundering and terrorist financing.
If during the business relationship the customer refuses or fails to submit all required documents and information, within reasonable time, trader-cap has the right to terminate the business relationship and close the accounts of the customer. The compliance department also examines whether to report the case to the AML/CFT Supervisor.
Personal Customer’s details required
Names should be verified by reference obtained from a reputable source which bears a photograph, such as:
In addition to the customer’s name verification, the current permanent address should be verified by obtaining any one of the following documents in original form:
In addition to the above, an introduction from a respected customer personally known to the Manager of trader-cap or from a trusted member of staff can assist the verification procedure. Details of the introduction should be recorded on the customer’s file.
In addition:
Where customer contact is not face-to-face;
Accounts for Corporate Customers:
The following documents are required:
Creation of financial portrait
All data and information must be collected before entering into business relationship with the customer. In order to create a financial portrait of the customer and, as a minimum, trader-cap must establish the following from the information provided by the customer:
The data and information that assist in establishing a financial portrait of the client (legal entity) include:
All above data and information will be recorded on a separate form which is filed in the customer’s file along with all other documents, and internal memos from the minutes of the meetings with the client. This form is updated on a regular basis or whenever new information on any changes or additions occur which affect the financial profile of the customer.
SIMPLIFIED CUSTOMER DUE DILIGENCE AND IDENTIFICATION PROCEDURES
trader-cap may apply simplified customer due diligence and identification procedures, provided that trader-cap has sufficient information to establish that the client qualifies for the simplified customer due diligence.
A simplified procedure is applied to the following customers:
Enhanced due diligence measures
trader-cap applies increased due diligence measures and customer identification procedures in the following cases:
trader-cap must conduct enhanced customer due diligence if:
trader-cap must conduct enhanced due diligence in accordance with if—
Enhanced customer due diligence measures is taken in all other instances which due to their nature entail a higher risk of money laundering or terrorist financing.
Performance by third parties
trader-cap may rely on third parties for applying the requirements in respect of customer’s identification procedures and customer due diligence measures provided that all data and information is held by the third person for customer identification, and certified copies of the originals are provided to trader-cap.
ON-GOING MONITORING AND RECORDING OF ACCOUNTS AND TRANSACTIONS
On-going monitoring is an essential aspect of effective KYC procedures. trader-cap can only effectively control and reduce the risk if it has an understanding of normal and reasonable account activity of its customers so that it has means of identifying transactions which fall outside the regular pattern of an account’s activity. Without such knowledge, it is likely to fail in its duty to report suspicious transactions to the appropriate authorities in cases where they are required to do so. The extent of the monitoring needs to be risk-sensitive.
For all accounts, trader-cap has systems in place to detect unusual or suspicious patterns of activity. This can be done by establishing limits for a particular class or category of accounts. Particular attention is paid to transactions that exceed these limits.
Certain types of transactions alert to the possibility that the customer is conducting unusual or suspicious activities. They may include transactions that do not appear to make economic or commercial sense (big transactions), or that involve large amounts of cash deposits that are not consistent with the normal and expected transactions of the customer.
Intensified monitoring for higher risk accounts is conducted. trader-cap has set key indicators for such accounts, taking note of the background of the customer, such as the country of origin and source of funds, the type of transactions involved, and other risk factors.
RECORD KEEPING
trader-cap is required to keep records for a period of at least 7 years by law . The 7 year period is calculated following the carrying out of the transactions or the end of the business relationship.
The following records must be kept:
All documents and information are available rapidly and without delay to the authorities for the purpose of discharging the duties imposed on them by the law. The AML/CFT Supervisor needs to be able to compile a satisfactory audit trail. Document retention may be in original documents or certified true copies and be kept in hard copy, or other format such as electronic form given that they can be available at any time and without delay.
When setting up document retention policies, trader-cap considers the statutory requirements and the potential needs of the unit. Documents and information must be original or true copies. In cases where the documents are being certified by another person and not trader-cap, or the third party, then the documents must be notarized.
RISK MANAGEMENT
Effective KYC procedures embrace routines for proper management oversight, systems and controls, segregation of duties, training and other related policies. The board of directors of trader-cap is fully committed to an effective KYC programme and procedures that ensures their effectiveness.
Explicit responsibility is allocated within the organization for ensuring that trader-cap’s policies and procedures are managed effectively and are in accordance with local supervisory practice. The channels for reporting suspicious transactions are clearly specified and communicated to all personnel.
trader-cap maintains an ongoing employee training program so that the staff are adequately trained in KYC procedures. The timing and content of training for various staff categories is adapted by trader-cap for its own needs.
Training requirements should have a different focus for new staff, front-line staff, compliance staff or staff dealing with new customers. New staff are educated in the importance of KYC policies and the basic requirements at trader-cap.
Staff members who deal directly with the customers are trained to verify the identity of new customers, to exercise due diligence in handling accounts of existing customers on an on-going basis and to detect patterns of suspicious activity. Regular refresher training is provided to ensure that employees are reminded of their responsibilities and are kept informed of new developments. It is crucial that all relevant staff fully understand the need for and implement KYC policies consistently. A culture within services that promotes such understanding is the key to a successful implementation.
SPECIFIC CUSTOMER DUE-DILIGENCE AND IDENTITY PROCEDURES.
Resident Natural Person/s (a)
Joint accounts
In cases of joint accounts of two or more persons, the identity of all persons (individuals) that hold or have the right to manage the account must be verified, as set out in Part A and B above where appropriate.
Accounts of unions, societies, clubs, provident funds and charitable institutions
Accounts of unincorporated businesses, partnerships and other persons with no legal substance
Accounts for Legal Persons
It is noted that at any times during the business relationship, trader-cap can obtain additional documents and information if required.
Accounts for Legal Person (Companies or Legal Entities)
Shareholder – another entity
In case of client – legal person applying for the conclusion of a business relationship or the execution of an occasional transaction and whose sole or direct shareholder is another legal person, before proceeding to the following must be provided:
Shareholder Trust
If the beneficial owner of an entity is a trust then the following documents are required:
Investment funds, mutual funds and firms providing financial or investment services:
Nominees or agents of third persons
The following information is required:
ADDITIONAL INFORMATION NOTICE
trader-cap AT ANY TIME CAN INQUIRE AND OBTAIN ADDITIONAL DOCUMENTS AND INFORMATION IF REQUIRED.
IF AT ANY LATER STAGE ANY CHANGES OCCUR IN THE STRUCTURE OF THE OWNERSHIP STATUS OR TO ANY DETAILS, THE CUSTOMERS HAS TO INFORM trader-cap AND PROVIDE ANY NEW INFORMATION AND DOCUMENTS.
IF IN THE COUNTRY OF THE POTENTIAL/EXISTING CLIENT ANY OF THE REQUIRED DOCUMENT DOES NOT EXIST IN THE FORM REQUIRED BY trader-cap THE COMPLIANCE OFFICER MAY ACCEPT A SIMILAR DOCUMENT SERVING THE NEEDS OF DUE DILIGENCE.
DEPOSIT AND WITHDRAWAL REQUIREMENTS
ALL THE CLIENTS’ OPERATIONS TO DEPOSIT AND WITHDRAW FUNDS HAVE THE FOLLOWING REQUIREMENTS:
DUE TO AML / CTF LAWS, trader-cap CANNOT DEPOSIT FUNDS TO THIRD PATIES. AL THE MONEY WITHDRAWN FROM YOUR ACCOUNT MUST GO TO A BANK ACCOUNT IN THE SAME NAME AS YOUR trader-cap TRADING ACCOUNT.
WITHDRAWING FUNDS FROM THE TRADING ACCOUNTS VIE THE METHOD, WHICH IF DIFFERENT FROM DEPOSING METHOD, IS POSSIBLE SOLELY AFTER WITHDRAWING THE SUM, WHICH IS EQUAL TO THE SUM OF CLIENT’S DEPOSITS VIA THE METHOD AND TO THE SAME ACCOUNT USED FOR DEPOSITING.
IF THE ACCOUNT WAS CREDITED IN THE WAY THAT CANNOT BE USED FOR FUNDS WITHDRAWAL, FUNDS MAY BA WITHDRAWN TO A BANK ACCOUNT OF THE CLIENT OR ANY OTHER WAY MAY BE USED, AS LONG AS THE CLIENT PROVIDES SATISFACTORY EVIDENCE OF THE OWNERSHIP OF THE BANK ACCOUNT.
IN CASE OF DEPOSITING VIA VISA/MASTERCARD, WIRE TRANSFER, THE WITHDRAWAL OF FUNDS, WHICH EXCEED THE SUM OF THE CLIENT’S DEPOSITS, IS POSSIBLE VIA ANY OF THE FOLLOWING METHODS: VISA/MASTERCARD, WIRE TRANSFER, AS LONG AS OUR SYSTEM PERMITS AND WE HAVE SUFFICIENT EVIDENCE THAT THE DESTINATION ACCOUNT IS UNDER THE SAME NAME AS THE TRADING ACCOUNT HOLDER.
Disclaimer: trader-cap is an online trading platform. The financial products offered by the Company, are complex financial products, trading is concluded outside a regulated exchange or venue and most financial products have no set maturity date. We are an industry leading, Forex Trading Brokers because we offer our investors the ability to trade underlying assets on an accurate and state of the art Forex Trading platform. trader-cap advises its clients to read our terms and conditions carefully before opening positions on our platform. Currencies quotes displayed on trader-cap platform are rates that the company is prepared to offer, and as a result may not necessarily correspond to the exact live market quotations. Trading Forex Currencies contains risks which may result in partial or full loss of an investment. There are risks associated with utilizing an Internet-based trading system including, but not limited to, the failure of hardware, software, and Internet connection. The Company is not responsible for communication failures or delays when trading via the Internet. Any opinions, news, research, analyses, or other information contained on this website are provided as general market commentary and do not constitute investment advice. The Company is not liable for any loss or damage, including and without limitation to, any loss of profit which may arise directly or indirectly from use of or reliance on such information.