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AML Policy

Compliance and Supervisory Procedures

Anti-Money Laundering and Counter-Terrorist Financing: Ibinex is committed to providing you
with safe, compliant, and reputable Services. Accordingly, Ibinex insists on a comprehensive
and thorough customer due diligence process and implementation and ongoing analysis and
reporting. This includes monitoring of and for suspicious transactions and mandatory reporting
to international regulators. Ibinex needs to keep certain information and documentation on file
pursuant to applicable law and its contractual relationships, and Ibinex hereby expressly
reserves the right to keep such information and documentation. This will apply even when you
terminate your relationship with Ibinex or abandon your application to have an account with

Ibinex reserves the right to refuse registration to, or to bar transactions from or to, or terminate
any relationship with, any customer for any reason (or for no reason) at any time. Without
limiting the generality of the foregoing, this includes, but is not limited to, anyone from or in
jurisdictions that do not meet international AML–CTF standards as set out by the FATF; anyone
that is a Politically Exposed Person within the meaning of the FATF’s 40 Recommendations; or,
anyone that fails to meet any customer due diligence standards, requests, or requirements of
Ibinex. In lieu of refusing registration, Ibinex may perform enhanced customer due diligence
procedures. At all times, you may be subject to enhanced customer due diligence procedures in
your use of the Site and any Service.




The UK AML regime is set out in the following legislation and regulations:
The Proceeds of Crime Act 2002 (POCA), as amended by the:
i. Serious Organised Crime and Police Act 2005 (SOCPA); and the
ii. Proceeds of Crime Act (Amendment) Regulations 2007;
The Terrorism Act 2000, as amended by the:
i. The Anti Terrorism, Crime & Security Act 2001; and the
ii. Terrorism Act (Amendment) Regulations 2007;
The Terrorism Act 2006; The Money Laundering Regulations 2007; and
The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector on
the prevention of money laundering/combating terrorist financing.
The Ibinex AML Policy is designed to prevent money laundering by meeting the UK/SVG AML
legislation obligations including the need to have adequate systems and controls in place to
mitigate the risk of the firm being used to facilitate financial crime.

This AML Policy sets out the minimum standards which must be complied with and includes:
The appointment of a Money Laundering Reporting Officer (MLRO) by the client, who has
sufficient level of seniority and independence and who has responsibility for oversight of
compliance with relevant legislation, regulations, rules and industry guidance;
Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing
the money laundering and terrorist financing risks to the company;
Establishing and maintaining risk-based customer due diligence, identification, verification and
know your customer (KYC) procedures, including enhanced due diligence for those customers
presenting higher risk, such as Politically Exposed Persons (PEPs);
Establishing and maintaining risk based systems and procedures to monitor on-going customer
Procedures for reporting suspicious activity internally and to the relevant law enforcement
authorities as appropriate;
The maintenance of appropriate records for the minimum prescribed periods;
Training and awareness for all relevant employees

Ibinex is prohibited from transacting with individuals, companies and countries that are on
prescribed Sanctions lists. Ibinex will therefore screen against United Nations, European Union,
UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions
in which we operate.