AML Policy

1.1 Policy Purpose

MitheralFX is committed to maintaining the highest standards of anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. This AML Policy outlines our procedures to prevent, detect, and report suspicious activities in accordance with applicable laws and regulations.

1.2 Regulatory Framework

We comply with relevant AML/CTF regulations including:

• UK Money Laundering Regulations 2017
• EU Fourth Anti-Money Laundering Directive (4AMLD)
• Financial Action Task Force (FATF) Recommendations
• Local regulatory requirements in jurisdictions where we operate

1.3 Scope

This policy applies to all MitheralFX employees, contractors, and agents. It covers all products, services, and transactions conducted through our platform.

2.1 Risk-Based Approach

We implement a risk-based approach to customer due diligence, applying enhanced measures for higher-risk customers and simplified measures for lower-risk situations.

2.2 Customer Risk Assessment

All customers are assessed for risk based on factors including:

• Customer location and jurisdiction
• Type of trading activities
• Transaction volumes and patterns
• Source of funds and wealth
• Occupation and business activities

2.3 Enhanced Due Diligence

Enhanced due diligence is applied to higher-risk customers including:

• Politically Exposed Persons (PEPs)
• Customers from high-risk jurisdictions
• Complex ownership structures
• Unusually large transactions
• Customers with limited public information

3.1 Identity Verification

We verify the identity of all customers using reliable and independent sources:

• Individual Customers: Government-issued ID, proof of address, and verification of identity documents
• Corporate Customers: Certificate of incorporation, register of directors/beneficial owners, and proof of business address

3.2 Document Requirements

Required documents include but are not limited to:

• Valid passport or national identity card
• Recent utility bill or bank statement (within 3 months)
• Proof of source of funds or wealth
• For corporate entities: Articles of association and register of shareholders

3.3 Ongoing Monitoring

KYC is not a one-time process. We continuously monitor customer relationships and update customer information as necessary.

4.1 Transaction Monitoring

We employ automated and manual monitoring systems to detect suspicious activities including:

• Unusually large transactions
• Rapid movement of funds between accounts
• Transactions inconsistent with customer profile
• Structuring transactions to avoid reporting thresholds
• Transactions involving high-risk jurisdictions

4.2 Suspicious Activity Reporting

We have established procedures for identifying and reporting suspicious activities:

• Immediate escalation of suspicious transactions to the Compliance Officer
• Documentation of suspicious activity reports (SARs)
• Reporting to relevant financial intelligence units
• Freezing of suspicious transactions when required

4.3 Threshold Reporting

We comply with all applicable threshold reporting requirements, including:

• Cash transactions above €10,000
• Wire transfers above €1,000
• Any transaction that appears suspicious regardless of amount

5.1 Retention Period

We maintain records in accordance with regulatory requirements:

• Customer Identification Records: 5 years after account closure
• Transaction Records: 5 years from the date of transaction
• Correspondence and Communications: 3 years
• AML Training Records: 3 years
• Suspicious Activity Reports: 5 years

5.2 Record Security

All records are stored securely with appropriate access controls and encryption to prevent unauthorized access, alteration, or destruction.

5.3 Record Accessibility

Records are made available to regulatory authorities upon request. We maintain an organized system for quick retrieval of required documentation.

6.1 Initial Training

All new employees receive comprehensive AML training within 30 days of hire, covering:

• Relevant AML laws and regulations

Company AML policies and procedures

• Recognition of red flags and suspicious activities
• Reporting procedures and responsibilities

6.2 Ongoing Training

We provide annual refresher training for all employees and additional training when:

• There are significant changes to AML regulations
• New products or services are introduced
• Internal procedures are updated
• Specific AML risks are identified

6.3 Training Documentation

We maintain detailed records of all training provided, including attendance records, training materials, and assessment results.

7.1 Annual Risk Assessment

We conduct a comprehensive AML risk assessment annually, evaluating:

• Customer risk profile changes
• Geographic risk exposures
• Product and service risks
• Delivery channel risks
• Emerging threats and typologies

7.2 Risk Mitigation

Based on the risk assessment, we implement appropriate mitigation measures including:

• Enhanced monitoring for high-risk customers
• Additional documentation requirements
• Increased management oversight
• Updated policies and procedures

7.3 Risk Review

The risk assessment and mitigation measures are reviewed and approved by senior management and the Compliance Officer.

8.1 Appointment

MitheralFX has appointed a designated Compliance Officer responsible for overseeing the implementation of this AML Policy and ensuring regulatory compliance.

8.2 Responsibilities

The Compliance Officer is responsible for:

• Developing and implementing AML policies and procedures
• Conducting AML risk assessments
• Overseeing KYC and transaction monitoring systems
• Reviewing suspicious activity reports
• Liaising with regulatory authorities
• Providing AML training to employees
• Ensuring record-keeping requirements are met

8.3 Independence

The Compliance Officer has sufficient authority and independence to perform their duties effectively, with direct access to senior management and the board when necessary.