AML and KYC Policy

The firm is committed to the prevention, detection, and deterrence of money laundering, terrorist financing, proliferation financing, tax evasion, bribery, corruption, and other forms of financial crime (together, "Financial Crime"). We take our responsibilities in relation to Financial Crime seriously and have adopted internal procedures designed to be consistent with the recommendations of the Financial Action Task Force ("FATF") and with generally accepted industry practice in the international brokerage sector.

This policy is not a representation that the firm operates under the supervision of any particular financial services regulator. TFC Funder Ltd is incorporated in England and Wales; it is not authorised by the Financial Conduct Authority, and the retail contract-for-difference activity conducted under the TFC Global Markets brand does not benefit from any statutory investor compensation scheme. The controls described in this policy are commercial controls adopted voluntarily; they reflect the standards we consider appropriate for a firm offering leveraged trading products to a global retail client base.

The firm's senior management is accountable for maintaining an effective AML/KYC control environment and for allocating adequate resources to compliance functions. The remainder of this policy sets out the practical operation of that control environment.

This policy applies to every prospective and existing Client of the firm and to every Client Account opened with us. It applies to:

1. all applications for account opening, whether for demo or real-money use;
2. every deposit received into a Client Account, by any payment rail we support (mobile money, card, or crypto-asset);
3. every trading activity conducted on a Client Account, including trading in currency-venue instruments, in our in-house Volatility Indices and Surge Indices, and in copy-trading arrangements;
4. every withdrawal from a Client Account; and
5. every request to close, transfer, or restructure a Client Account.

The policy applies to Clients regardless of jurisdiction of residence, subject to the geographical restrictions set out in Section 6. It applies whether the Client interacts with the firm through the website at https://www.tfcglobalmarkets.com, through the trading platform, through email, or through any other supported channel.

The controls described in this policy operate alongside the terms of the Client Agreement (see /legal/client-agreement), the Risk Disclosure Notice (see /legal/risk-disclosure), the Order Execution Policy (see /legal/order-execution-policy), and the Privacy Notice (see /legal/privacy). Where this policy is silent on a matter addressed by one of those documents, the other document governs.

Before we open a real-money Client Account, and in every case before we credit any deposit against a real-money Client Account, we carry out customer due diligence ("CDD") on the applicant. CDD comprises the following minimum steps.

3.1 Identity verification. The Client is required to provide a valid, unexpired government-issued photographic identity document. Acceptable documents include a passport, national identity card, or driving licence bearing a photograph. The document is checked for authenticity indicators, for consistency with the information supplied at registration, and against the Client's likeness through a live selfie or equivalent liveness check.

3.2 Address verification. The Client is required to provide proof of residential address dated within the preceding three (3) months. Acceptable documents include a utility bill, bank statement, tax notice, or equivalent official correspondence. Post-office box addresses are not accepted.

3.3 Date of birth and age verification. The firm accepts Clients aged eighteen (18) years or older only. Age is verified against the identity document supplied under Section 3.1.

3.4 Source-of-funds declaration. The Client is required to state the origin of the funds intended for deposit (for example, employment income, business proceeds, savings, or investment returns). Supporting documentation may be requested where the declared source is material to the risk assessment.

3.5 Contact verification. Email address and, where collected, telephone number are verified through a one-time verification code or equivalent mechanism.

3.6 Sanctions and PEP screening. The Client is screened against consolidated sanctions lists and against politically exposed persons ("PEP") databases before the account is opened. Screening is repeated on an ongoing basis (see Section 4).

We reserve the right to refuse any application at our discretion and without giving reasons, in particular where CDD cannot be completed to our satisfaction, where the documents supplied do not meet our authenticity or currency thresholds, or where the risk profile of the applicant is inconsistent with our onboarding criteria.

CDD is not a one-time exercise. For the duration of the Client relationship, the firm applies ongoing due diligence in the form of:

1. Transaction monitoring. Deposits, trading activity, and withdrawals are monitored for patterns consistent with money laundering, terrorist financing, market abuse, or third-party funding. Automated rules and manual review are both used.
2. Periodic re-verification. Identity and address documents are periodically re-verified, typically upon expiry of the underlying document, upon a material change in Client information (for example, a change of residential country), or on a rolling schedule set by the compliance function.
3. Ongoing sanctions and PEP screening. Client records are periodically re-screened against updated sanctions and PEP lists to reflect changes in the underlying data sources.
4. Trigger-based review. Certain events, including a first deposit above a defined threshold, a rapid escalation in trading volume, a change of deposit rail, a request to withdraw to a payment method different from the deposit method, or a change of stated country of residence, will trigger an ad-hoc review of the Client's CDD file.

Where ongoing due diligence identifies information gaps or inconsistencies, we may require the Client to provide updated documentation or explanation before permitting further activity on the Client Account.

Enhanced due diligence ("EDD") applies where the risk profile of the Client, of a particular transaction, or of the underlying jurisdiction warrants a higher level of scrutiny than the standard CDD framework. Circumstances in which EDD applies include:

1. Clients identified as PEPs, close associates of PEPs, or family members of PEPs (see Section 7);
2. Clients resident in, or transacting from, jurisdictions identified by FATF as having strategic AML/CFT deficiencies (so-called "grey list" and "black list" jurisdictions);
3. Clients whose declared source of funds cannot be corroborated through the documentation initially supplied;
4. Deposits or aggregated deposit patterns exceeding thresholds set from time to time by the compliance function;
5. Transactions displaying features associated with layering, structuring, or third-party funding;
6. Clients using anonymity-enhancing payment mechanisms in a manner inconsistent with a bona fide retail profile.

EDD measures may include, without limitation: requesting additional identity or address documentation; requesting bank statements or other evidence corroborating the declared source of funds and source of wealth; requesting a written explanation of trading rationale; requiring senior-management approval to open, maintain, or extend the Client Account; and imposing lower deposit or withdrawal limits pending resolution.

The firm screens Clients and transactions against the consolidated sanctions lists maintained by the Office of Foreign Assets Control ("OFAC") of the United States Department of the Treasury, the United Nations Security Council, His Majesty's Treasury of the United Kingdom, and the European Union, together with any other sanctions regime we determine relevant.

We do not open or maintain Client Accounts for:

1. natural persons or legal entities appearing on the sanctions lists identified above;
2. natural persons ordinarily resident in the United States of America, or United States persons for the purposes of United States securities and commodities laws;
3. natural persons ordinarily resident in any jurisdiction subject to comprehensive economic sanctions administered by OFAC or the United Nations, which currently includes Cuba, the Islamic Republic of Iran, the Democratic People's Republic of Korea, the Syrian Arab Republic, the Russian Federation, the Republic of Belarus, and the non-government-controlled regions of Ukraine; and
4. natural persons ordinarily resident in jurisdictions in which the marketing or retail distribution of contract-for-difference products ("CFDs", contracts for difference) is expressly prohibited by local law, including, at the date of this policy, Belgium.

The list of prohibited jurisdictions is not exhaustive and is updated from time to time to reflect changes in the underlying sanctions and regulatory regimes. It is the Client's responsibility to confirm that opening and operating a Client Account is lawful in the Client's own jurisdiction.

A politically exposed person is an individual who is or has been entrusted with a prominent public function, together with immediate family members and known close associates. Where an applicant, or a person connected with an applicant, is identified as a PEP:

1. senior-management approval is required before the Client Account is opened or, if the status is identified after onboarding, before it is permitted to continue;
2. enhanced source-of-wealth verification is applied, including documentary evidence of the origin of the assets used to fund the Client Account, not only of the immediate source of the funds;
3. the Client Account is placed under enhanced ongoing monitoring, with tighter thresholds for transaction review; and
4. the CDD file is re-reviewed at a shorter interval than for non-PEP Clients.

The status of a Client as a PEP does not, of itself, imply any wrongdoing. Enhanced measures reflect the heightened financial-crime risk associated with the category as a whole.

The firm's retail proposition is directed at natural persons trading on their own account. Where corporate or other legal-entity accounts are offered on a bespoke basis, the firm requires identification and verification of each ultimate beneficial owner ("UBO") holding, directly or indirectly, twenty-five per cent (25%) or more of the entity, together with identification of the controlling natural persons where no UBO meets that threshold. The corporate entity itself is subject to CDD in respect of its constitutional documents, its registered office, its trading address, its regulatory status where applicable, and the identity of its directors or equivalent officers. Any change in beneficial ownership must be notified to the firm promptly and may trigger re-verification.

Where the firm forms a suspicion, or has reasonable grounds to suspect, that funds credited to a Client Account, or activity conducted through a Client Account, may be connected with Financial Crime, an internal escalation is raised to the compliance function. Following internal review, the firm will make such reports to the relevant competent authorities as it is required to make under applicable law.

The firm will not disclose to a Client the fact that an internal escalation has been raised, that an external report has been made, or that a Client Account is under review, where such disclosure would or might amount to "tipping off" or would otherwise prejudice a lawful investigation. The firm may, in accordance with applicable law and its own risk appetite, restrict activity on a Client Account, freeze pending withdrawals, or close a Client Account in connection with a suspicion or report, without further notice or explanation to the Client.

The firm applies the following controls to withdrawals from Client Accounts:

1. KYC completion. No withdrawal is processed from a real-money Client Account before CDD under Section 3 has been fully completed. This is the case for the first withdrawal in every instance, and for any subsequent withdrawal after which the underlying CDD file has been re-opened.
2. Return-to-source. Withdrawals are returned, so far as commercially and technically practicable, to the same payment method and to the same beneficiary as the corresponding deposit. Where a return-to-source is not practicable (for example, where the deposit rail does not support outbound payments), the firm applies alternative return controls of equivalent rigour.
3. Third-party funding prohibition. Deposits from, and withdrawals to, third parties are not permitted. The name on the payment instrument must match the name on the Client Account.
4. Source-of-funds documentation. For withdrawals above thresholds set from time to time, additional documentary support in relation to source of funds or source of wealth may be requested prior to release.
5. Sanctions and screening checks. Sanctions and adverse-media screening is re-run at the point of withdrawal.

Client funds are held separately from the operating accounts of the firm. This operational practice is described further in the Client Agreement (see /legal/client-agreement) and is not a claim of segregation under any specific statutory client-money regime.

The firm retains identity documents, CDD questionnaires, source-of-funds evidence, transaction records, correspondence relevant to the Client relationship, and internal AML records, for a period of seven (7) years from the date on which the Client Account is closed, or such longer period as may be required by applicable law. Retention and destruction are conducted in accordance with the Privacy Notice (see /legal/privacy).

Team members involved in Client onboarding, transaction monitoring, withdrawal review, and the handling of Client correspondence receive training in the identification of Financial Crime indicators, in the operation of this policy, and in the internal escalation procedures. Training is provided on induction and thereafter on a periodic basis and following material changes to this policy or to the underlying legal and regulatory landscape. Training records are retained on the same basis as other AML records under Section 11.

The firm arranges for a review of its AML/KYC procedures by a party independent of the day-to-day compliance function on an annual basis, where practicable. The scope of the review includes the design and operating effectiveness of the controls described in this policy, sample testing of CDD files, and review of transaction-monitoring output. Findings are reported to senior management, together with an agreed remediation plan where deficiencies are identified.

The Client agrees, as a term of the Client Agreement (see /legal/client-agreement), to cooperate with the firm's AML/KYC processes. In particular, the Client will:

1. provide true, complete, and current information at onboarding and at any subsequent re-verification;
2. respond to reasonable requests for further information or documentation within the timeframes stated in the relevant request, which will typically be between five (5) and thirty (30) calendar days;
3. notify the firm promptly of material changes to information previously supplied, including changes of residential country, name, or beneficial ownership;
4. refrain from funding the Client Account with, or through, any third party; and
5. refrain from any attempt to disguise, misstate, or fragment the true source or beneficial ownership of funds deposited to the Client Account.

Failure to cooperate with these obligations, or the provision of false or misleading information, may result in restrictions on the Client Account, suspension of trading or withdrawal rights, closure of the Client Account, and, where applicable, reporting to competent authorities.

Personal data collected and processed under this policy is handled in accordance with the Privacy Notice (see /legal/privacy). Processing for AML/KYC purposes is undertaken on the legal bases described in that notice, including compliance with legal obligations to which the firm is subject and the firm's legitimate interests in preventing Financial Crime and protecting the integrity of its systems and Clients.

Questions in relation to this policy, including requests concerning CDD documentation and the status of AML reviews, should be addressed to the firm at aml@tfcglobalmarkets.com. General legal enquiries should be addressed to legal@tfcglobalmarkets.com. Data-protection enquiries should be addressed to dpo@tfcglobalmarkets.com. Operational and account enquiries should be addressed to support@tfcglobalmarkets.com.