AML Policy

1.1 This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) Policy outlines Pure M Global LTD's comprehensive commitment to preventing money laundering, terrorist financing, and all forms of financial crime.

1.2 The Company operates under strict compliance with Vanuatu AML/CFT regulations, Financial Action Task Force (FATF) recommendations, and international AML standards.

1.3 Money laundering is the process of disguising proceeds from illegal activities (drug trafficking, corruption, fraud) as legitimate income. The Company prohibits all money laundering activity.

1.4 Terrorist financing involves providing funds or financial services to terrorist organizations or individuals. The Company strictly prohibits terrorist financing in all forms.

1.5 The Company maintains comprehensive AML/CFT compliance program including written policies, documented procedures, staff training, and ongoing monitoring.

1.6 Compliance responsibility is distributed across the organization. All staff members trained on AML procedures and reporting obligations.

1.7 An AML Compliance Officer appointed and responsible for policy implementation, monitoring, regulatory reporting, and investigation.

1.8 This policy applies to all clients, business partners, employees, third-party service providers, and all individuals conducting business with the Company.

2.1 KYC Identification Requirement: All clients must provide government-issued identification including (a) Passport, (b) Driver's license, (c) National ID card, or (d) Other official government ID.

2.2 KYC Verification Process: Client identification verified against official government databases, multiple cross-references conducted, and verification documents retained.

2.3 Address Verification: Proof of residential address required within 3 months of account opening, including (a) Utility bills (electricity, water, gas), (b) Bank statements, (c) Government documents, or (d) Lease agreements.

2.4 Source of Funds Verification: Clients required to verify legitimate source of trading capital through documentation including (a) Employment letters, (b) Income statements, (c) Inheritance documents, or (d) Business ownership proof.

2.5 Beneficial Ownership Identification: For legal entities, beneficial owners identified and verified. Ownership structure reviewed. Hidden beneficial ownership investigated.

2.6 Trading Purpose Assessment: Client trading purpose determined including (a) Profit generation, (b) Portfolio diversification, (c) Hedging strategies, or (d) Speculation/retail trading.

2.7 Politically Exposed Persons (PEP): Clients identified as politically exposed persons subject to enhanced due diligence including additional background checks and source of wealth verification.

2.8 Adverse Media Screening: All clients checked against adverse media reports including (a) Criminal convictions, (b) Regulatory violations, (c) Sanction designations, or (d) Negative press reports.

3.1 OFAC SDN Screening: All clients screened against U.S. Office of Foreign Assets Control (OFAC) Specially Designated Nationals list containing individuals and entities subject to U.S. sanctions.

3.2 European Union Sanctions: All clients screened against European Union consolidated sanctions lists. EU sanctions apply to all member state nationals.

3.3 United Nations Sanctions: All clients screened against United Nations Security Council sanctions lists. UN sanctions apply globally to designated persons and entities.

3.4 UK OFSI Screening: UK Office of Financial Sanctions Implementation (OFSI) sanctions lists checked. UK sanctions apply to all UK-related transactions.

3.5 Prohibited Jurisdictions: Clients from the following sanctioned jurisdictions are prohibited from opening accounts: (a) Afghanistan, (b) Cuba, (c) Eritrea, (d) Iraq, (e) Iran, (f) Israel, (g) Liberia, (h) Libya, (i) Nicaragua, (j) Pakistan, (k) Russia, (l) Somalia, (m) Syria, (n) Sudan, (o) Vanuatu, (p) Malaysia, (q) United States (with limited exceptions).

3.6 Individual Designation Prohibition: Individuals listed on any international sanctions list are prohibited from opening accounts or conducting business with the Company.

3.7 Continuous Monitoring: Sanctions lists monitored continuously for changes. New sanctions designations checked daily. Existing accounts screened against updated lists weekly.

3.8 Account Blocking Procedures: Upon sanctions designation discovery, accounts immediately blocked. All funds frozen. Regulatory authorities notified. Accounts remain frozen pending resolution.

4.1 Real-Time Transaction Monitoring: All client transactions monitored in real-time for suspicious activity. Automated monitoring systems flag unusual patterns for investigation.

4.2 Suspicious Activity Definition: Suspicious activity defined as transactions inconsistent with client profile, trading history, financial situation, or stated business purpose.

4.3 Suspicious Activity Indicators: Red flags include (a) Rapid deposits followed immediately by withdrawals, (b) Unusual large transactions, (c) Structured deposits below reporting thresholds, (d) Inconsistent trading behavior, (e) Multiple failed login attempts, (f) Unusual geolocation activity.

4.4 Transaction Threshold Monitoring: Transactions exceeding specified reporting thresholds identified and examined. Large deposit activity triggers additional scrutiny.

4.5 Pattern and Trend Analysis: Client transaction patterns continuously analyzed for anomalies. Deviations from established patterns trigger investigation.

4.6 Frequency and Volume Analysis: Unusual frequency or volume of transactions triggers enhanced review. Sudden increases in activity investigated.

4.7 Suspicious Activity Reporting Timelines: Suspicious activity reported within 10 business days of detection to Vanuatu Financial Intelligence Unit (FIU).

4.8 No Tipping Off Rule: Clients not informed of suspicious activity reports or investigations. Tipping off prohibited by law. Notification would compromise investigation effectiveness.

5.1 Large Deposit Enhanced Diligence: Deposits exceeding $50,000 USD automatically trigger enhanced due diligence (EDD) procedures. Enhanced investigation conducted.

5.2 High-Risk Client Identification: Clients identified as high-risk include (a) Individuals from high-risk jurisdictions, (b) Politically exposed persons, (c) Clients with adverse media results, (d) Cash-intensive businesses.

5.3 EDD Investigation Components: Enhanced investigation includes (a) Additional identity verification, (b) Income documentation verification, (c) Third-party confirmations, (d) Source of wealth documentation, (e) Business relationship verification.

5.4 Ultimate Beneficial Owner Identification: For legal entities, ultimate beneficial owners identified through (a) Ownership structure analysis, (b) Board member verification, (c) Shareholder confirmations, (d) Beneficial ownership percentages verified.

5.5 Source of Wealth Analysis: For large accounts, clients provide detailed source of wealth documentation. Wealth sources traced to legitimate origins. Documentation reviewed and verified.

5.6 Business Purpose Assessment: Client trading purpose reviewed for legitimacy. Unusual business purposes investigated. Discrepancies addressed with client.

5.7 Ongoing Monitoring: EDD clients subject to ongoing monitoring. Transactions reviewed continuously. Annual re-verification conducted.

5.8 Documentation Retention: All EDD documentation retained for minimum 5 years. Documentation available for regulatory review. Files maintained securely.

6.1 Prohibited Jurisdictions Detailed List: Clients from the following countries prohibited: (a) Afghanistan - terrorism concerns; (b) Cuba - comprehensive U.S. embargo; (c) Eritrea - human rights violations; (d) Iraq - sanctions regime; (e) Iran - comprehensive sanctions; (f) Israel - political sensitivity; (g) Liberia - sanctions; (h) Libya - civil conflict sanctions; (i) Nicaragua - sanctions; (j) Pakistan - terrorism concerns; (k) Russia - comprehensive sanctions; (l) Somalia - fragile state; (m) Syria - civil conflict sanctions; (n) Sudan - sanctions regime.

6.2 Specially Designated Nationals Prohibition: Individuals or entities on OFAC, EU, UN, or UK sanctions lists are absolutely prohibited from opening accounts.

6.3 Terrorist Financing Prohibition: Accounts suspected of financing terrorism immediately closed without notice. Authorities notified. Funds frozen.

6.4 Politically Exposed Persons Restrictions: Senior government officials and their families subject to enhanced due diligence and enhanced monitoring.

6.5 Cash-Intensive Business Restrictions: Clients involved in cash-intensive businesses (nightclubs, casinos, money services) require additional monitoring.

6.6 Prohibited Industry Restrictions: Clients involved in weapons dealing, drug trafficking, human trafficking prohibited from opening accounts.

6.7 Structuring and Layering Prohibition: Clients attempting to structure deposits to avoid reporting thresholds prohibited. Layering of transactions monitored.

6.8 Beneficial Ownership Concealment Prohibition: Clients attempting to conceal beneficial ownership through shell companies prohibited.

7.1 Mandatory AML Training: All staff complete comprehensive AML training during onboarding. Annual refresher training required. Training completion documented.

7.2 Training Content Components: Training covers (a) Money laundering typologies and schemes, (b) Red flag indicators, (c) Reporting requirements and procedures, (d) KYC procedures, (e) Sanctions screening, (f) AML regulations.

7.3 Risk-Based Approach Training: Staff trained on risk-based approach to AML compliance. Higher-risk clients receive greater scrutiny and monitoring.

7.4 Internal Reporting Procedures: Staff trained on procedures for reporting suspicious activity internally. Clear escalation procedures established. Reporting encouraged.

7.5 Organizational Compliance Responsibility: All staff understand AML compliance is organizational responsibility. Compliance not solely IT/compliance function.

7.6 Confidentiality of Investigations: Staff trained to maintain confidentiality of AML investigations. Investigation details limited to need-to-know personnel.

7.7 Third-Party Training: Business partners, affiliates, and third-party contractors receive AML training. Contractors bound by AML requirements.

7.8 Training Documentation: All training documented with completion dates and topics covered. Training records retained for regulatory review minimum 5 years.

8.1 Customer File Retention: Complete customer files maintained including (a) Identification documents, (b) Source of funds documentation, (c) Complete transaction history, (d) Communication records, (e) Compliance notes. Retained minimum 5 years.

8.2 Transaction Record Retention: All transaction records retained including (a) Deposit and withdrawal details, (b) Trading activity records, (c) Fee transactions, (d) Dates, times, and amounts. Records retained minimum 5 years.

8.3 Regulatory Document Access: Documents produced promptly to regulatory authorities upon request. No delays permitted. Complete cooperation provided.

8.4 Access Control for Compliance Records: Access to compliance records restricted to authorized personnel. Role-based access controls enforced. Access logged.

8.5 Data Protection Measures: Compliance records treated as sensitive. Encryption applied. Secure storage implemented. Limited access provided.

8.6 Suspicious Activity Report Filing: Suspicious Activity Reports (SARs) filed with Vanuatu Financial Intelligence Unit. Filing procedures followed precisely. Filing confirmed.

8.7 Regulatory Authority Cooperation: Full cooperation provided to regulatory investigations. Compliance staff available for regulatory inquiries. Documents produced on demand.

8.8 External Regulatory Reporting: Additional reports filed with authorities as required by law including (a) Currency transaction reports, (b) Suspicious activity reports, (c) Cross-border transaction reports.