Anti-Money Laundering & Counter-Terrorism Financing Policy

FXCRM ("we", "our", "the Company") is committed to the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. This AML Policy sets out the principles, controls, and procedures we apply to prevent the use of our technology, platforms, and services for money laundering, terrorist financing, sanctions evasion, bribery, corruption, tax evasion, or any other financial crime.

The policy applies to all FXCRM entities, employees, officers, directors, contractors, agents, introducing brokers, resellers, and clients (including brokerages, prop firms, exchanges, and their end users) who interact with any FXCRM software, hosted infrastructure, payment orchestration, or KYC integration.

Our AML program is designed to meet or exceed the requirements of:

• The Financial Action Task Force (FATF) 40 Recommendations
• EU 4th, 5th and 6th Anti-Money Laundering Directives (AMLD4/5/6)
• UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• US Bank Secrecy Act (BSA) and USA PATRIOT Act
• OFAC, UN, EU, HMT and other applicable sanctions regimes
• Local licensing requirements in each jurisdiction FXCRM operates within

FXCRM adopts a Risk-Based Approach (RBA) that classifies clients, transactions, jurisdictions, and products according to a multi-factor risk model. Higher risk triggers enhanced due diligence, additional monitoring, and senior compliance sign-off.

Risk factors considered include, without limitation:

• Client type (natural person, corporate, trust, PEP, sanctioned nexus)
• Geography (FATF grey/black lists, high-risk third countries)
• Product exposure (leveraged FX, CFDs, prop funding, copy trading, crypto rails)
• Delivery channel (fully remote onboarding vs face-to-face)
• Transaction pattern, velocity, structuring indicators, and counterparty concentration

All clients onboarded through FXCRM-powered platforms are subject to:

• Identity verification via government-issued photographic ID
• Address verification through utility bills, bank statements, or official registries
• Liveness detection and biometric face-match against the presented document
• Sanctions, PEP, and adverse media screening against real-time global databases
• Source of funds and source of wealth questionnaires where risk warrants
• Corporate structure verification, UBO identification (25%+ ownership threshold)

Enhanced Due Diligence (EDD) is applied to Politically Exposed Persons, clients from high-risk jurisdictions, complex ownership structures, unusually large or unexplained transactions, and any relationship flagged by our monitoring engine.

FXCRM operates a rules-based and behavioural transaction monitoring engine that screens deposits, withdrawals, internal transfers, IB commissions, bonus grants, and trading activity 24/7. Alerts trigger investigation workflows, four-eye review, and where appropriate, filing of a Suspicious Activity Report (SAR) / Suspicious Transaction Report (STR) with the relevant Financial Intelligence Unit.

Typical red flags include:

• Rapid deposit-withdrawal cycles with minimal trading activity
• Third-party funding or payments to unrelated beneficiaries
• Structuring below regulatory reporting thresholds
• Use of anonymising services, mixers, or non-compliant crypto counterparties
• Sudden change in trading pattern inconsistent with declared profile

FXCRM does not onboard, service, or maintain relationships with any individual or entity appearing on OFAC SDN, UN, EU, HMT, or other applicable sanctions lists. Clients resident in, ordinarily located in, or with material nexus to comprehensively sanctioned jurisdictions are prohibited. Screening is performed at onboarding, on every material change, and on a rolling daily basis against updated list feeds.

All KYC records, transaction data, correspondence, screening results, and internal investigation files are retained for a minimum of five (5) years following the end of the business relationship or completion of the transaction, or longer where required by applicable law. Records are stored in encrypted, access-controlled, tamper-evident infrastructure with a full audit trail.

All FXCRM personnel receive AML/CTF induction training and annual refresher courses covering regulatory obligations, red flags, escalation procedures, and personal liability. A designated Money Laundering Reporting Officer (MLRO) reports directly to the Board and holds independent authority to file SARs, freeze accounts, and terminate relationships without commercial override.

Suspicious activity must be reported internally to the MLRO without tipping off the subject. The MLRO evaluates each internal report and, where the threshold is met, files an external SAR/STR with the competent Financial Intelligence Unit within statutory deadlines. FXCRM cooperates fully with lawful requests from regulators, law enforcement, and courts of competent jurisdiction.

• Money laundering in any form, including layering, integration, or placement
• Terrorist financing and proliferation financing
• Sanctions evasion, including circumvention through nominees or shell entities
• Market abuse, insider dealing, wash trading, or manipulative practices
• Tax evasion facilitation or bribery of foreign officials

Reports, disclosures, and enquiries regarding this AML Policy should be directed to the FXCRM Compliance Department at compliance@fxcrm.net. We treat every submission confidentially and in accordance with applicable whistleblower protection laws.