Effective Date: 20/09/2024

Monnaris.com is owned and operated by GLOBAL Markets LLC with registration number 3796 LLC 204 and registration address of Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines.

Monnaris.com is committed to preventing and detecting money laundering, terrorist financing, and other illegal financial activities that could harm the integrity of the financial markets. This Anti-Money Laundering (AML) Policy outlines the steps we take to detect, prevent, and report suspicious activities to ensure compliance with relevant regulations.

1. Purpose of the AML Policy

The purpose of this policy is to:

• Prevent and detect money laundering, terrorist financing, and other illegal activities.
• Ensure compliance with all applicable anti-money laundering laws and regulations.
• Protect Monnaris.com’s reputation and maintain the trust of our clients, stakeholders, and regulatory bodies.
• Establish procedures for reporting suspicious activity and identifying the source of funds used in transactions.

2. Legal Compliance

Monnaris.com will comply with the Anti-Money Laundering (AML) laws and regulations applicable to its operations. This includes, but is not limited to:

• Know Your Customer (KYC) Regulations: To verify the identity of our customers and ensure they are not involved in illegal activities.
• Financial Action Task Force (FATF) Recommendations: We follow international best practices for combating money laundering and terrorist financing.
• Local and International Regulations: We comply with the relevant laws in the jurisdictions where we operate, including all regulatory bodies and their requirements.

3. Customer Due Diligence (CDD)

Monnaris.com has established comprehensive customer identification and verification procedures to prevent the use of our services for money laundering purposes. The steps in the Customer Due Diligence (CDD) process include:

• Identity Verification: Users must provide valid and government-issued identification, such as a passport, driver’s license, or national ID card, to confirm their identity.
• Address Verification: Users must provide proof of their residential address (e.g., utility bills, bank statements) to ensure that the address provided is legitimate.
• Enhanced Due Diligence (EDD): For higher-risk clients, including those with a history of criminal activity or involvement in high-risk countries, we will conduct further checks to assess the risk level and establish the legitimacy of their activities.

4. Ongoing Monitoring

Once an account is opened, Monnaris.com will monitor account activities for suspicious or irregular transactions. This includes:

• Regular monitoring of transactions for large or unusual amounts, especially if they are inconsistent with the user’s history or profile.
• Identifying transactions or patterns of transactions that appear to be structured to avoid detection or reporting thresholds.
• Monitoring users who are located in high-risk jurisdictions or countries that may have weak anti-money laundering controls.

5. Politically Exposed Persons (PEPs)

A Politically Exposed Person (PEP) is an individual who holds a prominent public position, such as a government official, or is closely associated with one. Monnaris.com will apply enhanced due diligence procedures for all PEPs to assess the potential risk they may present. This may include:

• Scrutinizing their source of funds.
• Verifying their ongoing involvement in public life.
• Monitoring transactions more closely.

6. Suspicious Activity Reporting

If we identify any suspicious activity or behavior that might be indicative of money laundering, terrorist financing, or other illegal actions, we will:

• Investigate the suspicious activity promptly.
• Report the activity to the relevant authorities, including law enforcement and regulatory agencies, in accordance with applicable laws and regulations.
• Provide full cooperation with any investigation or audit conducted by regulatory bodies or law enforcement.

7. Record Keeping

Monnaris.com maintains records of all customer identification documents, transactions, and reports of suspicious activity. These records are stored securely and kept for a minimum period in accordance with applicable legal requirements, ensuring that they are available for inspection by regulatory authorities.

8. Internal Controls and Procedures

We have implemented internal controls to ensure compliance with our AML policy. These controls include:

• AML Officer: We have appointed an AML officer responsible for overseeing and enforcing compliance with the AML policy.
• Training and Awareness: Our employees receive regular training on the identification and reporting of suspicious activities. Training includes understanding the legal requirements of AML compliance and recognizing indicators of money laundering.
• Independent Audits: We will conduct periodic independent audits of our AML procedures to ensure they remain effective and compliant with evolving laws and regulations.

9. Risk-Based Approach

We adopt a risk-based approach to assessing and mitigating the risks of money laundering. This approach involves:

• Assessing the risk associated with each customer based on factors such as their geographical location, business type, and transaction patterns.
• Applying proportionate measures to high-risk clients, such as enhanced due diligence, while allowing for simplified procedures for lower-risk customers.
• Continuously reviewing and updating our risk assessment procedures to ensure they remain effective and in line with global best practices.

10. Sanctions Compliance

We comply with all applicable sanctions laws and regulations issued by governments and international bodies. This includes:

• Screening customers against global sanctions lists (e.g., the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), EU sanctions lists, UN sanctions).
• Blocking accounts or transactions related to individuals or entities subject to sanctions.

11. Policy Review

This Anti-Money Laundering (AML) Policy will be reviewed regularly to ensure it is up-to-date with current regulations and industry best practices. Updates and changes to the policy will be communicated to all employees and relevant stakeholders.

12. Non-Compliance

Failure to comply with this AML Policy could result in disciplinary action, including termination of access to Monnaris.com services and reporting to the relevant authorities.

13. Contact Information

If you have any questions or concerns regarding our Anti-Money Laundering (AML) Policy, please contact our compliance team:

Email: [email protected]