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Anti-Money Laundering (AML) Policy 1. Introduction 1.1 Next Trade Wave Ltd (referred to as “the Brokerage,” “we,” or “us”) is committed to preventing money laundering and complying with applicable laws and regulations related to anti-money laundering efforts. This Anti-Money Laundering (AML) Policy outlines our measures to detect, prevent, and report suspicious activities, as well as the client identification and verification procedures we implement. Legal and Regulatory Framework 2.1 The Brokerage operates in accordance with the anti-money laundering laws, regulations, and guidelines of the jurisdictions in which we operate. We are committed to upholding the highest standards of integrity and complying with all relevant AML and counter-terrorism financing requirements. Customer Due Diligence (CDD) 3.1 The Brokerage implements a risk-based approach to customer due diligence, which includes identifying and verifying the identity of our clients before establishing a business relationship or conducting transactions. The level of due diligence may vary based on the risk assessment of the client, transaction, and jurisdiction involved. 3.2 Client identification information may include, but is not limited to, full legal name, residential address, date of birth, nationality, government-issued identification documents, and contact details. We may also collect additional information and supporting documents as necessary to meet our AML obligations. 3.3 The Brokerage conducts ongoing monitoring of client accounts and transactions to detect and report any suspicious activities or unusual patterns that may indicate potential money laundering or terrorist financing. Enhanced Due Diligence (EDD) 4.1 Enhanced due diligence measures are implemented for high-risk clients, countries, or transactions, as determined by our risk assessment processes. These measures may include obtaining additional information, conducting additional verification steps, and performing enhanced monitoring of the client relationship. 4.2 Politically Exposed Persons (PEPs) and individuals or entities associated with high-risk jurisdictions are subject to enhanced due diligence procedures to mitigate the increased risk of money laundering or corruption. Suspicious Activity Monitoring and Reporting 5.1 The Brokerage maintains robust systems and controls to monitor client transactions, account activities, and other relevant data for the purpose of identifying and investigating suspicious activities. 5.2 If we identify any transactions or activities that raise suspicions of money laundering, terrorist financing, or other illegal activities, we will promptly report such activities to the appropriate regulatory authorities as required by law. Record-Keeping 6.1 The Brokerage maintains comprehensive records of client identification information, transaction details, and relevant supporting documents in accordance with applicable AML laws and regulations. These records are securely stored and maintained for the required retention period as determined by the applicable jurisdiction. Staff Training and Awareness 7.1 The Brokerage provides regular training and awareness programs to our employees to ensure they understand their AML obligations and are equipped to detect, prevent, and report suspicious activities. Staff members are trained on customer due diligence procedures, recognizing red flags, and the importance of maintaining confidentiality and reporting obligations. Compliance Officer 8.1 The Brokerage appoints a designated compliance officer responsible for overseeing the implementation of the AML program, ensuring compliance with relevant laws and regulations, and addressing any AML-related concerns or issues. Cooperation with Regulatory Authorities 9.1 The Brokerage cooperates fully with regulatory authorities, law enforcement agencies, and other competent authorities in their efforts to combat money laundering and terrorist financing. We provide necessary information and assistance in response to lawful requests and inquiries from these authorities. AML Policy Updates 10.1 The Brokerage regularly reviews and updates its AML Policy to reflect changes in laws, regulations, and best practices. Any updates will be communicated to our employees, clients, and relevant stakeholders. Risk Assessment 11.1 The Brokerage conducts regular risk assessments to identify, assess, and mitigate the money laundering and terrorist financing risks associated with our business activities. These assessments consider factors such as client types, geographical locations, transaction volumes, and emerging money laundering trends. Know Your Customer (KYC) Procedures 12.1 The Brokerage has implemented robust Know Your Customer (KYC) procedures to ensure the identification and verification of clients’ identities and assess their suitability for the services offered. 12.2 The KYC procedures include verifying the accuracy and validity of client-provided information and conducting risk-based assessments of client backgrounds and activities. Transaction Monitoring Systems 13.1 The Brokerage utilizes advanced transaction monitoring systems to detect and analyze patterns of suspicious activities and unusual transactions. These systems employ algorithms and filters to identify potentially high-risk transactions for further investigation. 13.2 The transaction monitoring systems are regularly updated and tested to ensure their effectiveness in identifying and reporting suspicious activities promptly. Politically Exposed Persons (PEPs) 14.1 The Brokerage has implemented specific procedures to identify and conduct enhanced due diligence on Politically Exposed Persons (PEPs), as defined by relevant AML regulations. This includes senior foreign political figures, their immediate family members, and close associates. 14.2 Additional scrutiny is applied to PEP relationships to ensure that the risks associated with these individuals are appropriately managed. Training and Awareness Programs 15.1 The Brokerage provides comprehensive and ongoing training programs to employees to ensure a high level of awareness and understanding of AML regulations, policies, procedures, and their individual responsibilities. 15.2 Training programs cover topics such as recognizing and reporting suspicious activities, understanding red flags, and ensuring compliance with AML obligations. Compliance Monitoring and Independent Audit 16.1 The Brokerage maintains an internal compliance monitoring program to assess the effectiveness of our AML policies, procedures, and controls. Regular internal reviews and audits are conducted to ensure compliance with applicable AML regulations and identify areas for improvement. 16.2 In addition to internal monitoring, the Brokerage may engage independent auditors or external consultants to conduct periodic AML audits to provide an objective assessment of our AML program’s effectiveness. Reporting Channels and Whistleblower Protection 17.1 The Brokerage provides secure and confidential channels for employees and other stakeholders to report any concerns, suspicions, or potential breaches of the AML Policy. 17.2 The Brokerage prohibits retaliation against individuals who report in good faith and provides appropriate whistleblower protections in accordance with applicable laws and regulations. Sanctions Compliance 18.1 The Brokerage is committed to complying with applicable economic and trade sanctions laws and regulations. We maintain procedures to screen clients, transactions, and counterparties against relevant sanctions lists to ensure compliance with these requirements. Cooperation with Financial Intelligence Units (FIUs) 19.1 The Brokerage cooperates with Financial Intelligence Units (FIUs) and other regulatory authorities by promptly and effectively reporting any suspicious transactions or activities as required by law. 19.2 We provide complete and accurate information to FIUs and support their investigations into suspected money laundering or terrorist financing activities. Third-Party Relationships 20.1 The Brokerage maintains a risk-based approach to managing relationships with third-party service providers, such as payment processors, financial institutions, and technology providers. We conduct due diligence on these entities to ensure they have appropriate AML controls and comply with applicable AML laws and regulations. 20.2 The Brokerage reserves the right to terminate or limit relationships with third parties that do not meet our AML standards or pose an unacceptable risk of facilitating money laundering or terrorist financing. Compliance with Customer Sanctions 21.1 The Brokerage maintains procedures to ensure compliance with customer sanctions, which involve identifying and screening clients against applicable sanctions lists and government-provided watchlists. 21.2 If a client is found to be on a sanctions list or associated with sanctioned entities, appropriate actions will be taken in accordance with applicable laws and regulations. Suspicious Activity Reporting (SAR) 22.1 The Brokerage has procedures in place to identify and report suspicious activities to the appropriate authorities in a timely manner. 22.2 Our employees are trained to recognize red flags and indicators of suspicious activities and are required to report such activities internally to our designated compliance officer. AML Governance and Oversight 23.1 The Brokerage maintains a governance framework that includes senior management oversight of AML policies, procedures, and controls. 23.2 A designated AML compliance officer is responsible for the implementation, monitoring, and enforcement of the AML Policy and ensuring compliance with applicable laws and regulations. Periodic Review and Updating of the AML Policy 24.1 The Brokerage conducts periodic reviews of the AML Policy to ensure its continued effectiveness and relevance in light of changing AML regulations, industry practices, and emerging money laundering and terrorist financing risks. 24.2 Any updates or amendments to the AML Policy will be communicated to employees and relevant stakeholders, and appropriate training and awareness programs will be conducted to ensure understanding and compliance. AML Policy Acknowledgment 25.1 Clients are required to acknowledge and accept the terms and requirements of the AML Policy as part of the onboarding process. 25.2 The Brokerage reserves the right to take appropriate actions, including the termination of client relationships, for non-compliance with the AML Policy. Contact Information 26.1 If you have any questions, concerns, or require further information regarding our AML Policy or related matters, please contact our designated compliance officer at [email protected]