1. PURPOSE

The purpose of this Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy is to establish the commitment of FXLIVE CAPITAL LIMITED to the prevention of money laundering, terrorist financing, fraud, and other financial crimes, in accordance with applicable legal and regulatory requirements.

This policy is also designed to ensure that all users of our platform are properly identified, that transactions are monitored to detect suspicious activities, and that the integrity of our services is preserved. Through the implementation of robust AML and KYC procedures, our goal is to foster a safe and transparent environment for all users and stakeholders.

2. INTRODUCTION

At FXLIVE CAPITAL LIMITED, we are dedicated to strictly complying with international trade standards and all relevant legislation to combat money laundering and terrorist financing. Our Compliance Department oversees compliance with these requirements, ensuring that all processes comply with FATF recommendations and internal AML/KYC standards. This policy is mandatory for all employees, officers, directors, and external agents of the company involved in financial transactions, client onboarding, and account management.

The Compliance Department ensures:

Document Verification: All client documentation must be accurate, up to date, and comply with applicable legal standards.

Standardization with International AML Protocols: All operations of the company must consistently comply with international anti-money laundering standards.

Mandatory Compliance for Staff and Clients: All employees, clients, and external agents must comply with these AML/KYC standards.

3. KNOW YOUR CUSTOMER (KYC) RULES FOR CLIENTS

3.1 KYC Policy Compliance

At FXLIVE CAPITAL LIMITED, we prioritize the security and integrity of our platform and comply with legal Know Your Customer (KYC) verification requirements. All clients must comply with the following rules when using our services and throughout their relationship with us.

All clients must provide the following documents for identity verification:

Natural Persons:

Government-Issued Identity Document: Valid official document to verify identity.

Proof of Address: Document that allows verification of the residential address.

Selfie: Photograph of the client required to complete identity verification.

Corporate:

Certificate of Incorporation/Registration: Document proving the legal incorporation or registration of the company.

Identification and Proof of Address of Directors: Documentation corresponding to the directors of the company.

Ownership Structure and Ultimate Beneficial Owner (UBO) Details: Information on the ownership structure of the company and its ultimate beneficial owners.

At the company's discretion, you may be requested to provide additional documentation and complete a KYC questionnaire as part of the ongoing compliance process. You agree to provide the requested information in a timely manner.

3.2 Document Submission; Process and Levels

Clients must submit the required documents during registration or when requested, before accessing all services on the platform. Failure to provide the necessary information may result in restrictions or denial of access to services.

Clients are obliged to provide accurate, complete, and updated information during the onboarding process and throughout their relationship with FXLIVE CAPITAL LIMITED. Furthermore, clients must promptly inform the company of any changes to their information to ensure that it remains current and accurate.

FXLIVE CAPITAL LIMITED implements a multi-level client verification process to ensure robust compliance with AML and KYC requirements. Clients must complete the following verification levels to access different services:

3.2.1. Default Level: Registered

Description: This is the initial level where clients provide basic registration information to create an account.

3.2.2. Level 1: Verified

Required Documents:

Proof of Identity: Passport, driver's license, permanent residence card, and a selfie.

Proof of Address: Utility bill, bank statement, or registration document issued by a government authority (dated within the last three months).

Access: Basic trading features and withdrawals.

3.2.3. Level 2: Verified+

Required Documents:

Proof of Funds: Bank statements, proof of income, or other relevant documents confirming the lawful source of funds.

Access: Expanded features, higher transaction limits, and additional account benefits.

3.3 Risk Assessment

FXLIVE CAPITAL clients are classified into risk levels (low, medium, and high) based on factors such as:

Nature of the Business

Country/Geographical Risk

Transaction Patterns

3.3.1. NATURE OF THE BUSINESS

Risk related to the nature of the business, also referred to as Service Risk, relates to the potential for financial crimes such as money laundering, fraud, or terrorist financing based on the type of services provided by FXLIVE CAPITAL LIMITED or the business activities of its clients. Certain services or industries may inherently present higher risks due to their complexity, transaction volume, or susceptibility to misuse.

FXLIVE CAPITAL LIMITED's approach to assessing and mitigating risks associated with the nature of its services and its clients' business operations is outlined below:

1. Identification of High-Risk Services or Businesses

FXLIVE CAPITAL LIMITED identifies high-risk activities and industries based on factors such as:

High Transaction Volumes or Significant Cash-Based Operations: Activities characterized by a high volume of financial movements or significant use of cash.

Industries Subject to Greater Regulatory Scrutiny: Such as gambling, real estate, cryptocurrencies, or financial intermediaries.

Businesses with Cross-Border Transactions: Especially those operating with high-risk jurisdictions.

Companies in Sectors Associated with Corruption or Tax Evasion Risks: Businesses operating in industries with higher exposure to these risks.

2. Enhanced Due Diligence (EDD) for High-Risk Services or Businesses

Clients involved in high-risk activities are subject to Enhanced Due Diligence measures, including:

Detailed Information on Business Operations: Including the source of funds and the nature of transactions.

Additional Supporting Documentation: Such as licenses, permits, and audited financial statements.

Regular Account Monitoring: To detect unusual transaction patterns.

3. Risk Assessment of the Services Provided

FXLIVE CAPITAL LIMITED assesses risks associated with its own services to ensure that its products and services are not misused for illegal purposes. This includes:

Transaction Limits and Monitoring Tools: Implementation of controls for high-risk services, such as digital wallets or cross-border transfers.

Onboarding Process Review: Evaluation of the onboarding process for clients requesting access to such services.

4. Ongoing Monitoring and Reviews

Clients classified under high-risk categories due to the nature of their business are subject to ongoing monitoring. This includes periodic reviews of their accounts, transactions, and risk levels.

5. Mitigation Measures

Based on the risk assessment, FXLIVE CAPITAL LIMITED may adopt the following measures:

Limitation of the Scope of Services: Restricting services provided to certain industries or companies.

Stricter KYC Requirements: Imposing more rigorous KYC requirements for specific sectors.

Denial of Services: Denying services to businesses presenting unacceptable risks, such as those involved in illegal or unethical practices.

3.3.2. COUNTRY/GEOGRAPHICAL RISK

Country/geographical risk refers to the potential for financial crimes, such as money laundering or terrorist financing, based on the geographical location or jurisdiction where a client operates or resides. Certain countries or regions may present higher risks due to weak regulatory frameworks, prevalence of corruption, political instability, or association with sanctioned entities or activities.

FXLIVE CAPITAL LIMITED's approach to identifying and mitigating risks associated with clients or transactions involving high-risk jurisdictions is outlined below:

1. Identification of High-Risk Countries

FXLIVE CAPITAL LIMITED uses publicly available resources and regulatory guidelines to identify high-risk jurisdictions, including but not limited to:

Countries Identified by the Financial Action Task Force (FATF): Countries classified as high-risk or subject to increased monitoring ("grey list" or "black list").

Countries Subject to International Sanctions or Embargos: Jurisdictions affected by international restrictive measures.

Tax Havens or Countries with Lack of Transparency: Jurisdictions identified as tax havens or whose financial systems lack transparency.

2. Enhanced Due Diligence (EDD) for High-Risk Countries

Clients residing in high-risk countries or transacting with them will be subject to Enhanced Due Diligence measures, including:

Additional Documentation: Providing additional documentation to verify identity and the source of funds.

Detailed Transaction Review: Closely examining operations to ensure their legitimacy and compliance.

Ongoing Monitoring: Continuously supervising account activities to detect unusual or suspicious behavior.

3. Restrictions on Certain Jurisdictions

FXLIVE CAPITAL LIMITED reserves the right to deny services or restrict transactions involving certain jurisdictions deemed too high risk according to regulatory guidelines or internal risk assessments. This may include:

Prohibition of Transactions: Prohibiting transactions with countries subject to international sanctions.

Rejection of Clients: Rejecting clients operating in jurisdictions with inadequate AML/CFT frameworks.

4. Monitoring and Updates

The list of high-risk jurisdictions is reviewed and updated periodically according to guidelines from:

FATF

Local and International Regulatory Authorities

3.3.3. TRANSACTION PATTERNS

Transaction patterns refer to the behaviors and trends in how clients conduct financial transactions on the FXLIVE CAPITAL LIMITED platform. Monitoring these patterns helps identify potential risks of money laundering, fraud, or other illicit activities by detecting unusual or suspicious activities that deviate from a client's normal financial behavior.

1. Normal Transaction Patterns

FXLIVE CAPITAL LIMITED establishes a baseline understanding of each client's typical transaction behavior during the onboarding process. This includes:

Average Transaction Amount

Transaction Frequency

Types of Transactions: For example, payments, transfers, and withdrawals.

Geographical Locations Involved

This baseline is derived from information provided during KYC verification and initial transaction history.

2. Identification of Unusual or Suspicious Patterns

Transactions that deviate significantly from a client's typical patterns may be flagged for review. Examples include:

Large or Sudden Transactions: Unusually high sums that are inconsistent with the client's profile.

Frequent Transfers: High frequency of transactions within a short period, especially to unknown or high-risk jurisdictions.

Geographical Anomalies: Transactions involving countries with high risks of money laundering or terrorist financing.

Structured Transactions: Multiple small transactions designed to avoid detection thresholds.

3. Monitoring and Alerts

FXLIVE CAPITAL LIMITED utilizes automated monitoring systems and manual reviews to track transaction patterns. These systems:

Generate Alerts: Produce alerts for transactions that exceed predefined thresholds or present suspicious characteristics.

Automated Detection: Use machine learning or rule-based algorithms to detect unusual activity.

4. Enhanced Due Diligence (EDD) for Suspicious Patterns

If a client's transactions are flagged as suspicious, FXLIVE CAPITAL LIMITED may initiate Enhanced Due Diligence procedures, such as:

Request for Additional Documentation: To verify the legitimacy of transactions.

Temporary Suspension or Restriction: Temporarily suspending or restricting account activities until investigations are finalized.

Reporting to Authorities: Reporting the activity to relevant regulatory or law enforcement authorities, when necessary.

5. Reporting Requirements

In accordance with applicable laws, FXLIVE CAPITAL LIMITED is required to file Suspicious Transaction Reports (STR) or Suspicious Activity Reports (SAR) for flagged transactions that cannot be justified after investigation.

3.4 CLIENT CATEGORIZATION

Client categorization based on the prior risk assessment involves classifying clients according to their risk levels and business activities to ensure appropriate levels of due diligence and monitoring. FXLIVE CAPITAL LIMITED basically conducts two Due Diligence processes, which are:

Customer Due Diligence (CDD)

Initial Verification: All new clients must undergo a KYC process before initiating any transaction.

Ongoing Monitoring: Periodic reviews of transactions and client profiles to identify unusual or suspicious activities.

Enhanced Due Diligence (EDD)

High-risk clients may require additional verifications, such as:

Source of Funds/Income

Ongoing Transaction Monitoring

FXLIVE CAPITAL LIMITED classifies clients into the following categories according to their risk profiles:

1. Low-Risk Clients

These clients typically include individuals or entities with transparent financial records, limited transaction volumes, and operations in regulated industries. The review and monitoring period for the business relationship with low-risk clients is every 2 years. Examples include:

Salaried Individuals

Established Companies with Verifiable Records

Listed Companies: Companies whose securities are admitted to trading on a Regulated Market of a country or a third country subject to disclosure requirements consistent with Community legislation.

2. Medium-Risk Clients

These clients present moderate risks due to higher transaction volumes, slightly complex business structures, or limited transparency. The review and monitoring period for the business relationship with low-risk clients is every 2 years. Examples include:

Small and Medium-Sized Enterprises (SMEs)

Independent Workers and Consultants with Irregular Income

3. High-Risk Clients

Clients in this category present elevated risks due to factors such as:

Involvement in High-Risk Industries: For example, gambling, cryptocurrencies, or remittances.

Operations in High-Risk Jurisdictions: Operating or conducting transactions with jurisdictions deemed high risk.

Complex Ownership Structures or High Transaction Volumes

The review and monitoring period for the business relationship with high-risk clients is annual.

4. ANTI-MONEY LAUNDERING (AML) MEASURES

4.1 Transaction Monitoring

Transaction monitoring is the ongoing process of reviewing, analyzing, and tracking financial transactions conducted on the FXLIVE CAPITAL LIMITED platform to detect and prevent money laundering, terrorist financing, and other illicit activities. This clause ensures that all transactions are examined to verify compliance with Anti-Money Laundering (AML) laws and regulations, protecting the integrity of our platform.

FXLIVE CAPITAL LIMITED uses automated systems and manual processes to monitor transactions in real time. These systems are designed to:

Identify Unusual Patterns or Anomalies

Flag High-Value Transactions: Identify transactions that exceed established thresholds.

Detect Rapid Movement of Funds: Identify movements that may indicate structuring or layering activities.

FXLIVE CAPITAL LIMITED may contact client(s) to clarify transaction details or request supporting documents when certain activities are flagged. Failure to provide satisfactory responses may result in account restrictions or reporting to authorities.

4.2. Internal Review Process

Upon identifying a suspicious activity, the following internal review process is conducted:

Initial Assessment: The compliance team conducts a preliminary investigation of the flagged activity, analyzing transaction details, the client profile, and any available supporting documents.

Enhanced Due Diligence (EDD): If necessary, further investigation is conducted, which may involve contacting the client to request additional documentation or clarifications.

Escalation: If the suspicious activity remains unresolved or further investigation confirms it may involve illicit activities, the case is escalated to senior management or compliance officers for a final assessment.

4.3 Suspicious Activity Reporting

This section establishes FXLIVE CAPITAL LIMITED's commitment to detecting, investigating, and reporting any suspicious financial activity that may involve money laundering, terrorist financing, or other illegal actions. This process ensures we comply with Anti-Money Laundering (AML) regulations and contribute to the global fight against financial crime.

If a transaction is deemed suspicious after investigation, FXLIVE CAPITAL LIMITED will file a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR) with the relevant authorities. The report includes:

Client Information: Details of the client involved in the suspicious activity.

Transaction Details: A description of the suspicious transaction(s), including amounts, dates, and any other relevant information.

Reason for Suspicion: A summary of the reasons why the activity is considered suspicious and the measures adopted during the internal review process.

4.4. Information Sharing

FXLIVE CAPITAL LIMITED is committed to protecting the privacy of its clients but will share information related to AML and CFT matters in accordance with applicable laws, regulations, and international agreements. Furthermore, FXLIVE CAPITAL LIMITED reserves the right to share your information with financial institutions and law enforcement agencies as required by legislation, without prior notice or consent.

Information will only be shared in accordance with the following principles:

Confidentiality: Shared information will be treated as confidential and handled securely. Only necessary details will be disclosed to authorized entities.

Compliance with Data Protection Laws: FXLIVE CAPITAL LIMITED complies with applicable data protection laws, such as the General Data Protection Regulation (GDPR), to ensure that any shared information is handled in a legally compliant manner.

In accordance with this policy, we retain your transaction records for a minimum of five years.

5. CLIENT OBLIGATIONS TO PREVENT ILLICIT ACTIVITIES

The obligations of FXLIVE CAPITAL LIMITED's clients are aimed at ensuring that their activities on our platform comply with Anti-Money Laundering (AML), Counter-Terrorist Financing (CFT), and other relevant laws and regulations.

1. Compliance with Legal Standards

You agree to comply with all relevant laws, including international regulations, to prevent illicit activities, financial fraud, and money laundering. You are responsible for avoiding direct or indirect involvement in illegal financial activities or transactions through the FXLIVECAPITAL website and services.

2. Verification of the Source of Funds

You confirm the legal source, ownership, and right to use all funds transferred to your FXLIVECAPITAL account. If there are indications of suspicious activity, deposits from untrustworthy sources, or fraudulent behavior (for example, chargebacks or payment cancellations), FXLIVECAPITAL reserves the right to conduct an investigation, block or close your account, cancel any transactions, and suspend account activities until the investigation concludes. Decisions will be governed by applicable laws, FATF recommendations, and industry best practices.

3. Prohibition of Third-Party Account Use

Clients are prohibited from using third-party accounts or providing false information regarding the ownership of funds. Transactions must be conducted through accounts in the client's own name. The use of false identities or external intermediaries for illicit purposes is strictly prohibited.

4. Restricted Jurisdictions

FXLIVE CAPITAL LIMITED does not provide services to clients in jurisdictions on the FATF blacklist. Additionally, services are not available to citizens or residents of the United States.

6. MONITORING OF SUSPICIOUS ACTIVITIES AND ACCOUNT RESTRICTIONS

1. Right to Refuse Suspicious Transactions

FXLIVE CAPITAL LIMITED reserves the right to refuse any transaction deemed suspicious. Preventive measures may be adopted, such as account suspension, blocking, or closure, and FXLIVE CAPITAL LIMITED will not assume civil liability for obligations resulting from such measures.

2. Client Cooperation and Ongoing Monitoring

Clients are obliged to cooperate with FXLIVE CAPITAL LIMITED's investigations related to suspicious activities. This includes:

Providing Requested Information: Clients must promptly provide any requested documents or explanations related to suspicious activities.

Ongoing Monitoring: Clients who have been flagged may be subject to enhanced monitoring, and periodic reviews will be conducted to ensure compliance with AML standards.

3. Confidentiality of Compliance Measures

FXLIVE CAPITAL LIMITED is not obliged to disclose to clients or third parties the specific details of measures adopted to comply with AML/CFT requirements, such as suspicions raised, reasons for transaction rejection, account closures, or requests for documentation.

4. Disciplinary Measures

In cases of serious misconduct, FXLIVE CAPITAL LIMITED may decide to initiate legal action against the client or a third party to address any criminal conduct, including civil or criminal penalties.

7. POLICY SCOPE AND COMPANY DISCRETION

1. Policy as a Reference Framework

This policy serves as a summary to establish FXLIVECAPITAL's commitment to global AML/KYC standards and the fundamental principles of our AML/KYC practices. Our internal AML/KYC procedures may develop these guidelines in greater detail, and nothing contained in this summary shall be interpreted as definitive or unalterable.

2. Policy Integration with the Client Agreement

This AML/KYC policy constitutes a fundamental component of any agreement with FXLIVE CAPITAL LIMITED. Failure to comply with this policy may result in immediate termination of the business relationship, at the discretion of FXLIVE CAPITAL LIMITED.