ANTI-MONEY LAUNDERING (AML), COUNTER-TERRORIST FINANCING (CTF) AND KYC POLICY

1. INTRODUCTION

CaravanFX Limited (the “Company”) is committed to preventing money laundering, terrorist financing, fraud, sanctions evasion, and other financial crimes.

The Company applies a zero-tolerance policy toward financial crime and implements a risk-based AML/CTF framework aligned with international standards.

2. REGULATORY FRAMEWORK

The Company complies with:

Money Laundering (Prevention) Act – Saint Lucia;
Proceeds of Crime Act;
Anti-Terrorism Act;
Financial Intelligence Authority Act.

And international standards:

FATF 40 Recommendations;
UN Sanctions;
OFAC;
EU & UK sanctions regimes.

3. RISK-BASED APPROACH (RBA)

The Company applies a Risk-Based Approach to assess and mitigate risks.

Risk factors include:

country of residence;
source of funds;
trading behavior;
transaction patterns;
product type (Forex, CFD, crypto-related flows).

Clients are classified as:

Low Risk;
Medium Risk;
High Risk.

4. CUSTOMER IDENTIFICATION (KYC)

The Company verifies all clients before establishing a business relationship.

Individual Clients:

Full name;
Date of birth;
Nationality;
Address.

Documents:

Passport / ID;
Proof of address.

5. CORPORATE CLIENTS & UBO

Required:

Certificate of Incorporation;
Articles of Association;
Directors & shareholders;
UBO identification (≥10%).

6. SOURCE OF FUNDS / SOURCE OF WEALTH

Clients may be required to provide:

bank statements;
salary confirmation;
business income evidence;
investment history.

7. ENHANCED DUE DILIGENCE (EDD)

Applied to:

PEPs;
high-risk jurisdictions;
complex structures.

Includes:

additional verification;
senior approval;
ongoing monitoring.

8. ONGOING MONITORING

Client activity is continuously monitored:

trading patterns;
deposits/withdrawals;
unusual behavior.

9. TRANSACTION MONITORING

The Company uses:

automated systems;
manual review;
behavioral analytics.

10. SANCTIONS SCREENING

Clients are screened against:

OFAC;
UN;
EU;
UK lists.

11. SUSPICIOUS ACTIVITY REPORTING (SAR)

Employees must report suspicious activity.

MLRO submits reports to:

Financial Intelligence Authority (Saint Lucia).

12. CRYPTO & BLOCKCHAIN RISK

The Company may accept crypto-based funding (e.g., USDT TRC-20).

Risks:

irreversible transactions;
wallet misuse;
AML risks.

The Company:

monitors blockchain flows;
may request wallet verification;
may reject suspicious deposits.

13. RECORD KEEPING

Data retained minimum:

7 years.

Includes:

KYC data;
transactions;
SAR.

14. THIRD-PARTY RISK

Partners (IB, PSP, LP):

undergo due diligence;
are required to comply with AML standards.

15. ACCOUNT RESTRICTIONS

The Company may:

freeze accounts;
block transactions;
terminate relationship.

16. MLRO

An MLRO is appointed and responsible for:

AML control;
SAR;
interaction with the regulator.

17. POLICY REVIEW

Reviewed periodically by Director.

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