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Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Legal Document

1. Introduction

Fxxpress is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. Our AML Policy is designed to prevent and detect any attempt to use our services for money laundering, terrorist financing, fraud, or other financial crimes.

This policy sets out the principles and procedures Fxxpress follows to comply with applicable laws, regulations, and global standards, including the Financial Action Task Force (FATF) Recommendations.

2. Purpose

The purpose of this AML Policy is to:

  • Protect Fxxpress, its clients, and the financial system from being exploited for criminal purposes.
  • Detect, prevent, and report suspicious activities, including money laundering and terrorist financing.
  • Establish procedures to verify customer identities and monitor transactions.
  • Ensure Fxxpress and its employees comply with applicable AML/CTF laws and regulations.

3. Scope

This AML Policy applies to:

  • All Fxxpress employees, officers, and directors
  • All customers and counterparties
  • All products and services offered by Fxxpress

4. Definitions

Money Laundering (ML):

The process of disguising the proceeds of criminal activity to make them appear legitimate.

Terrorist Financing (TF):

Providing or collecting funds, by any means, with the intention that they should be used to carry out terrorist acts.

5. Key Principles

Fxxpress follows these core principles to combat money laundering and terrorist financing:

1. Customer Due Diligence (CDD)

  • Collect and verify accurate identification information before opening accounts or processing transactions.
  • Obtain government-issued photo ID, proof of address, and other supporting documentation.
  • Apply Enhanced Due Diligence (EDD) for high-risk clients, politically exposed persons (PEPs), or jurisdictions with weak AML controls.

2. Know Your Customer (KYC)

  • Perform ongoing KYC reviews to ensure client data remains accurate and up to date.
  • Monitor changes in ownership structure, business activity, or risk profile.

3. Transaction Monitoring

Monitor transactions continuously for unusual or suspicious activity, including:

  • Large or rapid transfers inconsistent with customer profile
  • Structuring transactions to avoid reporting thresholds
  • Frequent deposits/withdrawals without clear economic purpose

4. Record Keeping

  • Maintain all customer identification and transaction records for a minimum of five (5) years, or longer if required by law.

5. Suspicious Activity Reporting (SAR)

  • Investigate and report suspicious transactions promptly to the relevant financial intelligence unit (FIU) or regulator.
  • Cooperate fully with law enforcement authorities and regulators.

6. Sanctions Screening

  • Screen all clients against relevant sanctions lists (OFAC, UN, EU, etc.) before onboarding and periodically thereafter.
  • Reject or freeze transactions involving sanctioned individuals, entities, or countries.

6. Employee Training

Fxxpress provides ongoing AML/CTF training to all relevant staff to ensure they:

  • Understand money laundering and terrorist financing risks
  • Recognize red flags and suspicious activities
  • Know how to escalate concerns internally

7. Compliance Officer

Fxxpress has appointed a Money Laundering Reporting Officer (MLRO) responsible for:

  • Implementation and oversight of this AML Policy
  • Acting as the primary contact with regulatory bodies
  • Investigating and filing Suspicious Activity Reports (SARs)
  • Ensuring staff training and policy updates

8. Independent Audit

Fxxpress may engage independent auditors or compliance consultants to periodically review its AML/CTF program to ensure its effectiveness and regulatory compliance.

9. Zero-Tolerance Policy

Fxxpress maintains a zero-tolerance approach toward money laundering and terrorist financing. Any attempt to use our platform for illegal purposes will result in:

  • Immediate termination of account
  • Freezing of funds where legally permissible
  • Reporting to competent authorities

10. Policy Review

This AML Policy will be reviewed at least annually or whenever there are significant regulatory changes to ensure it remains up-to-date and effective.

11. Limitation of Liability & Indemnification

Fxxpress will make every reasonable effort to implement and maintain effective Anti-Money Laundering and Counter-Terrorist Financing controls. However, by using Fxxpress services, you acknowledge and agree that:

Fxxpress shall not be liable for any losses, damages, or expenses incurred as a result of:

  • Account restrictions, transaction delays, or terminations due to AML/CTF reviews
  • Compliance with applicable laws, regulations, or requests from competent authorities
  • Freezing, blocking, or seizure of funds where required by law or regulatory mandate
  • False positives arising from sanctions screening or automated monitoring systems

You indemnify and hold harmless Fxxpress, its affiliates, directors, officers, and employees from any claims, liabilities, costs, or expenses (including legal fees) arising out of:

  • Your breach of applicable AML/CTF laws or this policy
  • Misuse of Fxxpress services for illegal or prohibited purposes
  • Any regulatory, legal, or enforcement actions related to your account activity

By maintaining an account with Fxxpress, you accept that Fxxpress' decisions relating to AML/CTF compliance (including but not limited to account restrictions, suspensions, or closures) shall be final and binding, and Fxxpress shall bear no responsibility for any consequential, incidental, or indirect loss suffered as a result.

Last updated: September 16, 2024

For questions about this policy, please contact our compliance team.