Anti-Money Laundering Policy

Anti-Money Laundering (AML) Policy for Vbulls Pte Ltd/Funded Nation, Singapore

Introduction

This Anti-Money Laundering (AML) policy outlines Vbulls Pte Ltd/Funded Nation's commitment to prevent, detect, and report any attempts to use its services for money laundering or any other illegal activities. As a proprietary trading firm registered in Singapore, we are dedicated to complying with all applicable AML laws and regulations, including the Monetary Authority of Singapore (MAS) guidelines.

Scope

This policy applies to all employees, contractors/traders, and third parties associated with Vbulls Pte Ltd/Funded Nation.

Regulatory Framework

Our firm adheres to the Corruption, Drug Trafficking, and Other Serious Crimes Act 1992 (CDSA) and guidelines set by the Monetary Authority of Singapore (MAS).

Definitions

Money Laundering (ML): The process of making illegally-gained proceeds appear legal. Terrorism Financing (TF): Providing funds for terrorist activity.

Obligations

1. Risk Assessment:

   Given the nature of proprietary trading, the firm will:
   • Regularly assess the ML and TF risks associated with trading patterns, counterparties, and jurisdictions.
   • Monitor for unusual size, volume, or patterns of trades.
   • For high-risk traders or clients, additional measures include:
     • Obtaining additional information on their trading strategies.
     • Understanding the origin of large or frequent fund transfers.
     • Increased monitoring of their trading activities.

2. Establishing Internal Policies:

   • Develop and implement adequate internal policies, procedures, and controls considering our money laundering risks and business size.
   • Ensure timely communication of these policies to all employees and traders.

3. Performing Customer Due Diligence (CDD):

   • Establish proper CDD procedures during customer onboarding.
   • Collect and verify the following information from individuals:
     1. Full name
     2. Unique identification number (e.g., identity card number, birth certificate number, or passport number)
     3. Residential address
     4. Date of birth
     5. Nationality
   • For legal entities or arrangements, collect:
     1. Full name, including any aliases
     2. Unique identification number of the connected party
   • Use external services or databases to ensure the authenticity of provided documents.
   • Check customers against sanctions lists (e.g., OFAC, UN, HMT, EU, DFT), Politically Exposed Persons (PEP) lists, and adverse media.
   • Engage in ongoing monitoring of customer information.
4. Recordkeeping:
   • Maintain records of customers and transactions for a minimum of five years from the end of the business relationship or the final transaction.
5. Reporting Suspicious Activities:
   • Report any suspicious activities to the Suspicious Transaction Reporting Office (STRO) immediately.
   • Types of reports include:
     1. Suspicious Transaction Report
     2. Cash Transaction Report
     3. Cash Movement Report

Training

All traders and employees will undergo regular AML training tailored to the forex environment to understand their responsibilities and recognize signs of suspicious trading activity.

Compliance Officer

The firm will appoint a Compliance Officer responsible for:

• Ensuring the AML policy is implemented and updated.
• Reporting to senior management and regulatory authorities.
• Overseeing training and awareness programs.

Review and Update

This policy will be reviewed annually or whenever there are significant changes to regulations or the firm's operations

Penalties for Non-Compliance

Non-compliance with this policy may result in disciplinary action, including termination of trading privileges, and may also result in criminal or civil penalties.

Conclusion

Vbulls Pte Ltd/Funded Nation is committed to maintaining the highest standards of AML compliance specific to the trading environment. All traders and employees are expected to adhere to this policy and report any suspicious trading activities.