ANTI-MONEY LAUNDERING (AML) POLICY
TRADIIFY is a premier financial education platform that serves as a nexus for connecting students with top-tier mentors, institutions, and industry experts. By offering a diverse range of meticulously curated courses, TRADIIFY empowers users to develop comprehensive financial acumen, covering areas from Financial Markets and Instruments, Investment Strategies, Corporate Finance and Planning, Risk Management, Financial Services, Automation, NFTs, Assets Classes, Trading Strategies, Stock and Forex Market, Blockchain and Crypto related topics, market strategies and investment principles to global economic trends. TRADIIFY fosters a dynamic learning environment driven by innovation, practicality, and real-world applications. The platform's commitment to high-quality education ensures that users are equipped with the skills and insights necessary to thrive in the ever-evolving financial landscape.
TRADIIFY Investment Consultant LLC (herein referred to as a “Company” or “We” or “Us” or “TRADIIFY”), a Limited Limited Company having its registered Place of Business at Latifa Tower - Office No. 3206, 32nd Floor, Sheikh Zayed Road, Opposite Museum of The Future, Trade Centre 1 - Dubai, United Arab Emirates (UAE), operates the online platform on its website https://www.tradiify.com/ (herein the “Website” or “Platform”).
TRADIIFY is dedicated to complying with rigorous Anti-Money Laundering (AML) regulations. This commitment includes adhering to mandated user (customer) identification procedures for registration and transactions on our platform. By utilizing our services, users enter into a legally binding agreement with TRADIIFY, ensuring the integrity and security of their educational journey within the financial sector. This agreement enhances the learning experience for both novice and seasoned learners, as well as mentors, fostering an environment where knowledge is effectively shared and skills are continuously developed. Mentors benefit from a structured platform to impart expertise, while learners gain valuable insights, all within a framework that supports growth and adherence to the platform’s standards and policies. We value your continued trust in our platform and our commitment to maintaining the highest standards of compliance and security.
INTRODUCTION
The Company has implemented an AML strategy aimed at thwarting and reducing the potential for illicit activities utilizing our services. Our dedication lies in providing a secure and reliable platform for our users to engage in their educational activities and access financial market insights with confidence and execute their transactions. In alignment with this dedication, we've formulated an Anti-Money Laundering (AML) Policy (referred to as the "Policy" or "AML Policy"), which encompasses all our operational endeavors. Oversight of this AML framework is managed by TRADIIFY, a legally established entity under UAE Laws. For inquiries, reach out to us via email at support@tradiify.com
Money laundering and financing terrorism pose significant risks to the global financial system's stability and integrity. Criminals and terrorists exploit financial institutions to conceal, transfer, and legitimize illicit funds, making it challenging to track and seize their illegal proceeds. To address these dangers, numerous nations have adopted Anti-Money Laundering (AML) policies. These policies outline measures and obligations for financial institutions and designated non-financial businesses and professions (DNFBPs) to prevent, identify, and report instances of money laundering and terrorism financing.
This AML policy has three main components:
Purpose of the policy
The Anti-Money Laundering (AML) policy of TRADIIFY aims to establish a framework to prevent, detect, and deter the illegal use of the company's services for money laundering and terrorism financing purposes. It outlines measures and procedures to effectively identify and manage associated risks. The policy's implementation ensures compliance with relevant laws and regulations, protects the company's reputation, and safeguards stakeholders from the adverse effects of such activities. Applicable to all individuals associated with TRADIIFY including employees, officers, agents, and third-party service providers, the policy serves as a crucial tool to mitigate risks associated with money laundering and terrorism financing, fostering a safe and secure business environment.
Overview of AMLD 5 & 6 Regulations
The Anti-Money Laundering Directives (AMLD) represent critical European Union (EU) regulations designed to prevent financial systems' abuse for money laundering and terrorism financing. AMLD 5 and 6 are the latest directives aimed at strengthening the EU's anti-money laundering framework. They introduce new requirements, including risk-based approaches and enhanced due diligence measures.
TRADIIFY, committed to regulatory compliance, voluntarily adopts AMLD 5 and 6 regulations. This decision offers several benefits:
Improved Reputation: Adherence to AMLD 5 and 6 demonstrates TRADIIFY’s dedication to regulatory compliance, enhancing its reputation among stakeholders.
Enhanced Risk Management: AMLD 5 and 6 provide a comprehensive framework to mitigate money laundering and terrorism financing risks, enabling TRADIIFY to implement robust measures effectively.
Better Stakeholder Protection: By implementing AMLD 5 and 6 measures, TRADIIFY safeguards stakeholders from financial crimes' adverse effects.
Future-Proofing: Voluntary adoption of AMLD 5 and 6 ensures TRADIIFY’s readiness for potential future regulatory changes, setting high standards in AML compliance.
Increased Efficiency: AMLD 5 and 6 regulations can enhance the efficiency of TRADIIFY’s AML program by providing tailored measures and procedures.
By adopting AML policies based on AMLD 5 and 6, TRADIIFY underscores its commitment to regulatory compliance and proactive stance against financial crimes
Scope of the Policy
TRADIIFY implements a comprehensive AML Policy based on the European Union's AMLD 5 and 6 directives. This policy outlines measures to identify, mitigate, and manage money laundering and terrorism financing risks.
We expect strict adherence to this policy from all employees, officers, agents, and third-party service providers. Regular reviews and updates ensure compliance with evolving legal and regulatory requirements, fostering a culture of AML compliance.
In essence, TRADIIFY remains dedicated to preventing money laundering and terrorism financing, contributing to a safer financial ecosystem.
Definition
“Available Law” means any law, regulation, rule, order, or requirement that is applicable and enforced within Dubai, UAE, including, but not limited to, the Federal Decree Law No. (20) of 2018, Federal Decree-Law No. (7) of 2024 and any amendments thereon.
“Customer Due Diligence” means and involves collecting and verifying personal data, understanding the customer’s (user’s) activities, and assessing associated risks for ongoing monitoring.
“Client," “Customer,” "User," or "You" means any individual or entity who uses or accesses the Platform, which includes students, mentors, educational organizations and institutions, prospective users and authorized representatives.
“Designated Director” means an individual appointed by TRADIIFY overseeing the complete execution of the duties.
“Enhanced Due Diligence” means a comprehensive and detailed customer verification process used for high-risk individuals or entities. This rigorous procedure includes deeper background checks, closer examination of the source of funds, and ongoing monitoring.
“Know Your Customer (KYC)” means the protocol established to confirm and authenticate the identities of potential users and/or their beneficial owners. It acts as the primary mechanism for identifying individuals or entities that establish and manage a User Account. KYC procedures are implemented at least once a year to guarantee continuous compliance and verification.
“Politically Exposed Person(PEP’s)” means Foreign dignitaries and individuals appointed to significant positions by foreign countries, such as Heads of States/Governments, senior politicians, high-ranking government officials, judges, military officers, executives of state corporations, and prominent political party leaders, are classified as Politically Exposed Persons (PEPs). Additionally, individuals may be categorized as PEPs if they are family members or close associates of such persons.
“Simplified Due Diligence” means a streamlined verification process for low-risk customers, requiring fewer checks and less data collection to efficiently manage relationships while adhering to anti-money laundering regulations.
“Suspicious Transaction Report(STR)” means a critical document filed when a transaction is suspected of being linked to money laundering or terrorism financing.
REGULATORY COMPLIANCE
Legal Compliance
TRADIIFY rigorously adheres to all relevant national and international AML laws and guidelines, including those set forth by the Financial Action Task Force (FATF) and local regulatory bodies.
Our AML policy is crafted in alignment with the Anti-Money Laundering Regulations covered under Federal Decree-Law No. (20) of 2018, Federal Decree-Law No. (7) of 2024 of UAE and amendments to these regulations which establish the legal framework essential for the prevention of money laundering and terrorist financing within the jurisdiction. In addition to these, TRADIIFY also ensures compliance with the Anti-Money Laundering Directives (AMLD) 5 and 6, reinforcing our commitment to maintaining the highest standards of regulatory adherence.
Voluntary Adoption
The Anti-Money Laundering Directives (AMLD) are critical regulations within the European Union (EU) aimed at preventing the misuse of financial systems for money laundering and terrorism financing. AMLD 5 and 6, the latest iterations, enhance the EU's regulatory framework by introducing requirements such as risk-based approaches and enhanced due diligence measures.
TRADIIFY has proactively adopted AMLD 5 and 6 regulations, a move that offers several advantages, including improved reputation, enhanced risk management, better protection for stakeholders, readiness for future regulatory changes, and greater efficiency in implementing AML measures. By aligning with these directives, TRADIIFY demonstrates a firm commitment to the highest standards of regulatory compliance and a proactive approach to combating financial crimes.
Commitment to Regulatory Update
Our company recognizes the evolving regulatory environment surrounding Anti-Money Laundering (AML) activities. We are committed to continuously monitoring and adapting to any changes, amendments, or updates in relevant regulatory laws to ensure that our AML policy remains up-to-date and in compliance with the latest legal standards.
Legal Consequence
TRADIIFY understands the serious nature of money laundering and terrorism financing offenses and recognizes the legal ramifications involved. Individuals found guilty of such offenses may be subject to legal actions, including criminal charges, fines, and imprisonment, as adjudicated by the relevant authorities.
VERIFICATION BY CUSTOMER DUE DILIGENCE
In compliance with AMLD 5 and 6 regulations, TRADIIFY conducts Customer Due Diligence (CDD) to verify customer identities, mitigating money laundering and terrorist financing risks.
CDD procedures encompass identifying customer types, verification, and assessing risk levels. Enhanced Due Diligence (EDD) is applied to higher risk customers, while Simplified Due Diligence (SDD) may suffice for lower risk customers.
Identifying and Verifying Customers:
Before initiating any business relationship or conducting intermittent transactions, TRADIIFY implements risk-adjusted protocols for customer identification and verification. This process encompasses in Gathering and validating essential customer information, including:
Full name, date and place of birth
Residential address
Nationality or country of origin
Occupation or business pursuits
Official identification documents like passports or national ID cards
Supporting documents such as utility bills or bank statements
Business Registration Documents such as Certificate of Incorporation, Business License, Memorandum and Articles of Association, utility bills or bank statements, lease agreement
Tax Identification Number of Business such as GST/Tax ID or VAT number
Contact Information such as Official email address, Phone number
Authorized Representative Information of the person authorized to act on behalf of the organization such as Personal Identification Information, Contact details
Bank Details such as Bank account information for financial transactions
Moreover, we delve into evaluating the provenance of the customer's funds, assets and transactions where deemed necessary, and assess their business conduct and reputation.
Enhanced Due Diligence (EDD) for High-Risk Customers:
Customers exhibiting higher risk profiles, including politically exposed persons (PEPs), high-net-worth individuals (HNWIs), and those from jurisdictions with elevated risk levels, undergo intensified due diligence measures. These may involve:
Acquiring supplementary information through comprehensive checks
Seeking senior management endorsement for establishing or sustaining the business relationship
Deploying additional safeguards like transaction thresholds or third-party audits to mitigate potential risks.
Simplified Due Diligence (SDD) for Lower Risk Customers:
Conversely, for customers categorized with lower risk levels TRADIIFY streamlines its due diligence processes. While still conducting risk assessments, we may adopt simplified measures like accepting copies of identification documents and conducting fundamental identity validations. However, should the risk necessitate, supplementary controls may be implemented.
Timing and Frequency of Customer Due Diligence (CDD):
CDD procedures are executed prior to rendering any services, ensuring ongoing accuracy and currency of customer data. We remain vigilant for signs of suspicious activity or fluctuations in customer risk profiles, triggering supplementary CDD measures as warranted.
Record Keeping and Communication:
In compliance with AML regulations, TRADIIFY maintains meticulous records of customer information and verification procedures for a minimum of five years. These records are securely archived and made accessible to regulatory authorities upon request. Furthermore, we ensure transparent communication of our CDD procedures to all customers, reinforcing their obligation to furnish accurate and current information. Our employees and agents receive comprehensive training to adeptly execute these procedures.
On-Going Customer Activity Monitoring
Our Customer Due Diligence (CDD) processes include ongoing monitoring of customer transactions and activities to promptly identify any unusual or suspicious behavior related to financial crimes such as money laundering or terrorist financing. If suspicious activity is detected, our company immediately reports it to the appropriate authorities and takes the necessary steps to address the situation.
Politically Exposed Persons (PEPs) and Third-Party Reliance:
Recognizing the elevated risk associated with politically exposed persons (PEPs), TRADIIFY conducts thorough due diligence, scrutinizing their wealth sources and transactional activities. Moreover, we may enlist the expertise of reputable third-party service providers for certain aspects of the CDD process, adhering to AML standards diligently.
RISK ASSESSMENT
TRADIIFY adopts a risk-based approach to combat money laundering and terrorism financing, anchoring its AML Policy on robust risk assessment methodologies. This systematic process serves as the cornerstone of our AML framework, aiming to identify, evaluate, and mitigate risks inherent in our business operations and relationships.
Risk Factors Considered:
In assessing risk levels,TRADIIFY considers a spectrum of factors, including:
Type of Customer: Whether an individual, company, or politically exposed person (PEP).
Nature and Purpose of Transaction: Considering transaction size, frequency, complexity, and uniqueness.
Geographical Location of Customer: Particularly scrutinizing countries or regions with heightened money laundering or terrorist financing risks.
Source of Funds: Assessing legitimacy and flagging suspicious activity indicators.
Risk Assessment Process:
Our risk assessment process is comprehensive and entails:
Customer Information Collection: Including identity verification and transaction details.
Data Analysis: To ascertain the risk level associated with each customer and transaction.
Due Diligence Application: Tailoring measures commensurate with identified risks.
Ongoing Monitoring: Ensuring continual review and adjustment of risk levels as circumstances evolve
Risk Appetite and Tolerance:
TRADIIFY maintains a clear comprehension of its risk appetite and tolerance thresholds, aligned with our business strategy, regulatory obligations, and risk management framework. Periodic reviews and updates guarantee alignment with evolving conditions.
Cross Border Mitigation:
We perform detailed risk assessments tailored to each jurisdiction where we operate, identifying and evaluating potential AML risks. These assessments consider factors such as local regulations, political stability, economic conditions, and other pertinent elements. We thoroughly analyze the regulatory frameworks, legal environments, and geopolitical conditions in each area of operation. Early detection and assessment of geopolitical risks enable us to enact effective risk mitigation strategies promptly.
Risk Ranking and Scoring:
Following risk factor evaluation, we assign rankings and scores to each risk category, blending quantitative and qualitative assessments of likelihood and impact. These scores prioritize risks, guiding the implementation of appropriate mitigation strategies.
Ongoing Risk Monitoring:
Risk monitoring is dynamic, necessitating continual vigilance. TRADIIFY employs ongoing monitoring mechanisms leveraging appropriate systems and tools such as transaction monitoring and customer screening software. This ensures timely detection of suspicious activities and facilitates prompt integration of regulatory updates into our risk assessment procedures.
SANCTION COMPLIANCE
TRADIIFY is dedicated to rigorous adherence to all relevant international and local sanctions, including those enforced by the United Nations, the United States, the European Union, and other pertinent authorities.
Screening Process
We are dedicated to maintaining robust processes that screen both customers and transactions against international sanctions lists and watchlists. Our approach includes:
Continuously monitoring customer transactions in real time.
Integrating sanctions compliance within our Customer Due Diligence (CDD) processes to establish a thorough customer risk profile.
Implementing Enhanced Due Diligence (EDD) measures for high-risk customers.
Employing sophisticated technology tools to improve both accuracy and efficiency.
Regularly updating our sanctions screening procedures to reflect changes in sanctions lists and regulatory requirements.
Compliance Checks
TRADIIFY treats any breach of sanctions compliance measures with the utmost seriousness and takes swift corrective actions, including disciplinary measures. The company will fully cooperate with relevant authorities in the event of any investigations related to sanctions violations. Regular checks are conducted to ensure compliance with sanctions regulations, and immediate action is taken to rectify any identified instances of non-compliance.
TRANSACTION - SUSPICIOUS ACTIVITY REPORTING (SAR)
TRADIIFY is dedicated to identifying and promptly reporting suspicious activities to the compliance officer and relevant authorities, ensuring compliance with pertinent laws and regulations.
Trigger Events:
Various events may serve as triggers for submitting a SAR, including:
Unusual or unexplained transactions.
Transactions lacking an apparent lawful purpose.
Transactions involving known or suspected terrorists or terrorist organizations.
Transactions involving politically exposed persons (PEPs).
Transactions inconsistent with the customer's known business or financial activities.
Transactions involving customers from high-risk countries or regions.
Review and Assessment of Suspicious Activity:
TRADIIFY employees and officers are obligated to:
Review the transaction and gather all pertinent information regarding the customer and transaction.
Determine the suspicious nature of the transaction based on the risk assessment and specified factors.
Document the review and assessment comprehensively within the SAR report.
Escalate the matter to the compliance officer if suspicion arises regarding the transaction.
Internal Reporting Requirements:
Immediate reporting of suspicious activity to the compliance officer is mandatory for TRADIIFY employees and officers upon identification.
External Reporting Requirements:
If a transaction is deemed suspicious, the compliance officer will proceed to file a SAR report with the relevant authorities, adhering to applicable laws and regulations.The SAR report must encompass the following details:
Customer information, encompassing name, address, and any identification documentation.
Transaction particulars, including amount, currency, and date.
Details outlining the suspicious activity, including reasons for suspicion and the basis thereof.
Any additional pertinent information or documentation.
Cooperation with Authorities:
TRADIIFY commits to complete cooperation with relevant authorities in any subsequent investigation or inquiry associated with a SAR report. This cooperation is essential for ensuring transparency and regulatory adherence throughout the process.
Monitoring and Reporting
As part of our commitment to combating money laundering and terrorist financing, we will monitor transactions and activities for suspicious behavior and report any such activity to relevant authorities.
Monitoring transactions and activities for suspicious behavior
We will implement a risk-based transaction monitoring program that identifies and analyzes transactions and activities that are potentially suspicious. Our transaction monitoring program will be designed to detect transactions and activities that are unusual or not in line with the expected behavior of our customers or industry standards.
The transaction monitoring program will be reviewed and updated periodically to ensure that it is effective in detecting suspicious activities. The program will be calibrated based on the level of risk associated with different types of customers and transactions, as determined by our risk assessment process.
Identifying Suspicious Activity
The company will use a range of indicators to identify suspicious activity, including but not limited to:
Transactions involving high-risk customers or countries.
Transactions involving unusual patterns, such as large or frequent transactions, or transactions that deviate from the customer's usual behavior.
Transactions involving unexplained sources of funds, or funds that are inconsistent with the customer's profile or stated business activities.
Transactions involving parties that are not known to the customer or have no apparent business relationship with them.
Transactions that are inconsistent with the customer's stated purpose or business activities.
Investigating Suspicious Activity
If the company detects any suspicious activity, it will promptly investigate the matter and determine whether it constitutes money laundering or terrorist financing. The company will also consider filing a suspicious transaction report (STR) with the relevant regulatory authorities, as required by AML regulations.
Ongoing Monitoring and Review
The company will implement ongoing transaction monitoring and review procedures to ensure that any suspicious activity is promptly detected and investigated. This will involve the use of appropriate systems and tools, such as transaction monitoring software and alerts, as well as regular review of customer profiles and activity.
Communication of Transaction Monitoring Procedures
The company will communicate its transaction monitoring procedures to all customers, and will ensure that they are aware of their obligations to report any suspicious activity. The company will also provide training to employees and agents to ensure that they are aware of the transaction monitoring procedures and can implement them effectively.
Reporting suspicious activity to relevant authorities
If we detect any suspicious activities or transactions, we will report them to the relevant authorities in accordance with AMLD 5 and 6 regulations. Our reporting procedures will be designed to ensure that all necessary information is included in the report and that it is submitted in a timely manner.
We will maintain a record of all suspicious activities and transactions, as well as any reports that we submit to the authorities. These records will be kept for the minimum period required by law and may be used to support future investigations.
Record-keeping requirements
We will maintain records of all transactions and activities conducted by our customers for the minimum period required by law. These records will include customer identification and verification data, as well as information on the nature and purpose of the transaction or activity.
Our record-keeping procedures will be designed to ensure that all necessary information is captured and that it is stored securely. Access to these records will be restricted to authorized personnel only.
Compliance reporting and audit trail
We will regularly review and evaluate the effectiveness of this Policy, procedures, and controls to ensure that they remain up to date and effective in managing the risks of money laundering and terrorist financing.
We will maintain an audit trail of all compliance-related activities, including risk assessments, transaction monitoring, suspicious activity reporting, and record-keeping. This audit trail will be used to demonstrate compliance with AMLD 5 and 6 regulations and may be subject to review by regulatory authorities.
CROSS BORDER OPERATIONS
Our AML Policy acknowledges the unique challenges posed by cross-border activities and is dedicated to adhering to applicable laws and regulations in every jurisdiction in which we operate. The primary elements of this policy follows:
Regulatory Adherence
TRADIIFY pledges to comply with the AML regulations of every jurisdiction in which we operate, fostering a culture of rigorous adherence. We engage collaboratively with regulatory bodies in various regions to ensure alignment with local requirements.
Cross Border Mitigation
Our risk management strategies are tailored to reflect the distinct risk landscapes of different jurisdictions, with a risk assessment process that accounts for regional specificities to ensure effective risk mitigation. Globally, we implement Enhanced Due Diligence (EDD) measures, taking into account the unique risks associated with cross-border transactions.
Transparent Reporting
Clear and transparent reporting to regulatory authorities in each jurisdiction underpins our cross-border operations. Our proactive communication and cooperation with these bodies build trust and underscore our dedication to compliance with AML regulations.
Legal and Regulatory Update
Our operations are informed by regular updates on legal and regulatory changes in each jurisdiction. Proactive measures are taken to adapt our AML practices to evolving regulatory landscapes, ensuring up-to-date compliance.
INTERNAL CONTROLS
TRADIIFY upholds a commitment to establishing a comprehensive framework of compliance and internal controls aimed at mitigating the risks associated with money laundering and terrorism financing. This section provides an overview of the key components of TRADIIFY’s compliance and internal controls framework.
Designation of Compliance Officer:
TRADIIFY has a Compliance Officer tasked with overseeing the implementation and maintenance of the AML Policy, aligned with AMLD 5 and 6 regulations. Reporting directly to the Board of Directors, the Compliance Officer bears responsibility for ensuring TRADIIFY's adherence to all relevant laws and regulations.
Compliance Framework:
The compliance framework encompasses policies, procedures, and controls meticulously designed to identify, mitigate, and manage the risks associated with money laundering and terrorism financing. This framework undergoes regular reviews and updates to ensure its ongoing effectiveness and relevance.
Internal Controls:
TRADIIFY has instituted a robust system of internal controls to ensure the effective implementation of the AML Policy and to enforce compliance among all employees, officers, and agents. Key components of these internal controls include:
Segregation of Duties: Procedures are in place to prevent any single individual from having control over all aspects of a transaction or process, thus mitigating the risk of fund or asset misuse.
Authorization and Approval: All transactions and processes within TRADIIFY necessitate authorization and approval from designated individuals, ensuring legitimacy and alignment with the AML Policy.
Monitoring and Reporting:TRADIIFY employs a systematic approach to monitoring and reporting to identify and prevent suspicious activity. This includes regular reviews of customer transactions and periodic assessments of employee transactions.
Review and Monitoring of Compliance:
Regular reviews and monitoring efforts are undertaken by TRADIIFY to evaluate compliance with the AML Policy, in accordance with AMLD 5 and 6 regulations. The Compliance Officer conducts periodic assessments to pinpoint any compliance gaps and recommend enhancements to the compliance framework, with the results reported to the Board of Directors for further action.
TRAINING & AWARENESS
Training requirements for staff:
All employees who are involved in customer onboarding, transaction monitoring, or compliance-related activities must receive regular training on AML regulations, the company's policies and procedures, and the identification and reporting of suspicious activity. The training should be tailored to the specific roles and responsibilities of each employee, and cover the following topics:
Overview of AML regulations and their impact on the company
The company's AML policies and procedures
Identification and verification of customers
Risk assessment methodology
Transaction monitoring and reporting
Record-keeping requirements
Handling of suspicious activity reports
Red flags and indicators of suspicious activity
Consequences of non-compliance with AML regulations
Training should be conducted upon hiring and periodically thereafter, as well as whenever significant policy changes occur. The company should maintain records of all training provided, including the date, content, and attendance.
Ongoing awareness and education programs
The company should provide ongoing awareness and education programs to ensure that employees remain up-to-date with AML regulations and any changes to the company's policies and procedures. These programs may include:
Regular newsletters or bulletins
Online courses or modules
Webinars or in-person training sessions
Compliance reminders or alerts
Refresher training for employees who require it
Communication of policy changes and updates
The company should communicate any changes or updates to its AML policies and procedures to all employees. This may include notifying employees of changes through email, company-wide announcements, or other means of communication. The company should ensure that all employees understand the changes and receive any necessary training or support to implement them.
By ensuring that employees are well-informed and trained on their responsibilities, the company can mitigate the risk of non-compliance with AML regulations and protect its reputation and operations.
REGULATORY COMPLIANCE
At TRADIIFY adherence to AMLD 5 and 6 regulations is paramount to our operations. We are dedicated to complying with all relevant AML regulations, including robust policies, procedures, and controls designed to prevent money laundering and terrorist financing activities. Moreover, we are committed to promptly identifying and reporting any suspicious activities to the appropriate authorities.
Identification and Management of Regulatory Risks
Recognizing the inherent regulatory risks within the Web 2.0 industry and EdTech (educational-technology) industry and services, we proactively identify and manage these risks. Our approach involves regular reviews and assessments of our policies, procedures, and controls to ensure their effectiveness and alignment with regulatory requirements. We stay vigilant by monitoring regulatory developments and updates, ensuring that our policies remain current and compliant.
Regular Review and Update of Policies and Procedures
To maintain ongoing compliance with AML regulations, we conduct routine reviews and updates of our policies and procedures. This encompasses comprehensive risk assessments, thorough examinations of customer due diligence processes, and continuous monitoring and reporting procedures. Additionally, we regularly enhance our training and awareness programs to ensure that our staff remain well-informed about any changes to policies and procedures, thereby fostering a culture of compliance throughout our organization.
GOVERNANCE AND OVERSIGHT
Our Governance and Oversight Clause delineates the essential mechanisms and roles within our organization dedicated to upholding the highest standards of integrity and compliance for AML governance, demonstrating our steadfast commitment to these principles.
Board Oversight
Our Board of Directors plays a crucial role in ensuring AML compliance, emphasizing transparency, accountability, and proactive risk management. The board commits to regularly evaluating the effectiveness of policies, aligning strategies with legal standards, and reviewing compliance and risk assessment reports. They also ensure that adequate resources are allocated to maintain and improve the AML program’s effectiveness.
Compliance Officer
The policy designates a compliance officer who shall be responsible for overseeing the implementation, update, and monitoring of policies, enforcement of compliance, conducting risk assessments, and facilitating communication with stakeholders. This officer shall be given regular training programs to elevate staff awareness and proficiency regarding AML practices.
Internal Control Framework
Our organization is committed to developing and sustaining a robust internal control framework to back our AML initiatives. This framework encompasses well-defined policies and procedures, clear segregation of duties, routine internal audits, and continuous training initiatives. It will undergo regular reviews and updates to adapt to new risks and changes in regulatory demands.
Stakeholder Communication
We ensure effective communication with stakeholders by establishing reporting channels for suspicious activities, collaborating with law enforcement and regulatory bodies, and consistently updating employees, customers, and other stakeholders on our AML policies.
REVIEW & UPDATE OF POLICY
At TRADIIFY, we acknowledge the dynamic nature of the money laundering and terrorism financing landscape and the imperative for continual review and enhancement of our AML Policy to ensure its ongoing effectiveness.
Overview of Review and Update Process
Our AML Policy undergoes periodic review and updates to accommodate changes in regulatory requirements, evolving risk factors, and our business operations. The Compliance Officer oversees this process, ensuring that the policy remains relevant and compliant with applicable regulations.
Frequency of Review and Update
We commit to reviewing and updating our AML Policy at least annually, with more frequent updates as warranted by shifts in risk factors, business activities, or regulatory mandates.
Changes to Legal and Regulatory Framework
Our AML Policy promptly reflects any modifications to the legal and regulatory landscape concerning money laundering and terrorism financing. The Compliance Officer diligently monitors regulatory developments to ensure timely updates to the policy.
Feedback and Suggestions
We welcome feedback and suggestions from employees, third-party service providers, and other stakeholders. Input from all parties is considered during the review and update process, fostering a collaborative approach to policy refinement.
Approval of Updated Policy
Before implementation, the updated AML Policy receives approval from TRADIIFY’s senior management. All employees, officers, and agents are duly notified of the updated policy and any revisions to their roles and responsibilities.
Communication of Updated Policy
The updated AML Policy is effectively communicated to all relevant stakeholders, including employees, officers, agents, and third-party service providers. The policy is readily accessible on our company website, and employees are required to acknowledge and adhere to its provisions. This transparent communication ensures alignment with our compliance objectives across the organization.
Conclusion
Commitment to AML compliance
We are committed to complying with the Anti-Money Laundering (AML) regulations under AMLD 5 and 6. We understand the importance of maintaining a safe and secure platform for our users and the wider financial system, and we will take all necessary measures to prevent our platform from being used for illicit activities.
Responsibilities and accountabilities
We recognize that AML compliance is a shared responsibility between our company and our employees. As such, we will ensure that all employees are aware of their AML obligations and responsibilities, and we will hold them accountable for their compliance with this policy.
Continuous improvement and evaluation
We will regularly review and evaluate our AML policy and procedures to ensure that they remain effective and up-to-date. This will include monitoring regulatory developments and industry best practices to identify areas where we can improve our AML program. We will also conduct regular internal audits to test the effectiveness of our AML program and identify any gaps or weaknesses that need to be addressed.