AML Policy

Company: Apex Trader Capital LTD
Address: 3rd Floor, 86-90 Paul Street, London EC2A 4NE
Company Registration No.: 16982254

1. Policy Statement and Commitment

Apex Trader Capital LTD is committed to preventing the misuse of its platform for money laundering, terrorist financing, or other criminal activities. The company operates under the jurisdiction of the United Kingdom and complies with all applicable UK laws and regulations.

This policy demonstrates Apex Trader Capital LTD’s dedication to ethical business practices, protecting its reputation, and building public trust.

2. Purpose and Objectives

This policy provides a clear framework for Apex Trader Capital LTD’s employees and partners to ensure compliance with UK regulations for Designated Non-Financial Businesses and Professions (DNFBPs) under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).

Key objectives include:

• Establishing clear policies regarding money laundering, terrorist financing, and sanctions compliance.
• Defining compliance responsibilities for all employees.
• Providing guidance to employees in daily business tasks in line with UK legal requirements.
• Promoting a workplace culture that prioritizes legal compliance and ethical conduct.

3. Know Your Client (KYC) Procedures

Apex Trader Capital LTD implements robust KYC procedures to verify the identity of all clients before onboarding.

For Individuals:

• Collect personal details such as full name, gender, date of birth, nationality, and residential address.
• Verify identity using a valid government-issued ID (passport, driving license, or national ID card) that is current.
• Verify proof of address with documents such as utility bills, bank statements, or official letters not older than three months.

Due Diligence:

• All documentation must be clear, valid, and legible.
• Inability to provide adequate documentation may result in the refusal to establish or maintain a business relationship, in line with MLR 2017 obligations.

4. Internal Controls and Monitoring

Apex Trader Capital LTD maintains internal procedures to monitor client activity and detect suspicious behaviour.

Risk-Based Approach:

• A Risk Management Unit will assess clients based on risk factors and conduct due diligence proportionate to risk.
• The company follows a risk-based approach in line with UK law and guidance for DNFBPs.

Suspicious Activity Reporting (SAR):

• Employees are trained to recognize unusual or complex transactions and escalate concerns to the Money Laundering Reporting Officer (MLRO).
• All identified suspicious activity must be reported to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002 (POCA).
• Clients must not be informed of any ongoing investigations.

Record Keeping:

• Client identification, transaction records, and due diligence documentation will be retained for at least five years, in accordance with UK law.

5. Enhanced Customer Due Diligence (EDD)

Enhanced due diligence will be applied in higher-risk situations, including:

• High-risk clients or transactions.
• Politically Exposed Persons (PEPs).
• Clients from jurisdictions with weak AML/CFT controls.
• Unusual or suspicious transactions.

EDD includes:

• Verification of the source of funds and wealth with supporting evidence, such as pay slips, tax returns, audited accounts, or bank statements.
• If sufficient evidence cannot be provided, Apex Trader Capital LTD may suspend or terminate the business relationship.

6. Employee Training and Compliance Team

Training:

• All employees receive annual training on AML/CFT obligations under UK law, including:

1. Recognizing and reporting suspicious activity to the MLRO.
2. Identifying forms of money laundering and terrorist financing relevant to the company’s products and services.
3. Understanding internal policies and procedures.

Compliance Oversight:

• A Designated MLRO/Compliance Officer is responsible for the AML/CFT program and its day-to-day management.
• The Risk Management team performs regular compliance testing and audits to ensure adherence to UK regulations.

7. Policy Review

This AML policy will be reviewed annually or sooner if required, to ensure compliance with UK law and internal business practices.