AML/KYC Policy

SequalFX Limited, incorporated in Saint Lucia, is committed to maintaining the highest standards of anti-money laundering (AML), counter-terrorist financing (CTF), and Know Your Customer (KYC) practices. This Policy outlines the principles and procedures implemented to protect the Company, its clients, and the financial system from misuse.

1. Purpose and Scope

1.1 The purpose of this Policy is to establish effective procedures to prevent money laundering, terrorist financing, and financial crimes.
1.2 This Policy applies to all employees, directors, partners, and clients of SequalFX Limited.
1.3 The Company strictly complies with international AML/CTF standards, including FATF Recommendations, EU AML Directives, and the laws of Saint Lucia.

2. Customer Identification (KYC Requirements)

2.1 Individual Clients must provide:

• Valid government-issued identification (passport, national ID, or driving license).
• Proof of residential address (utility bill, bank statement, or official correspondence not older than 3 months).

2.2 Corporate Clients must provide:

• Certificate of Incorporation and Articles of Association.
• Proof of registered address.
• Identification of directors and ultimate beneficial owners (UBOs).
• Board resolution authorizing account opening.

2.3 All documents must be clear, valid, and, if required, certified.

3. Verification Procedures

3.1 The Company conducts full verification before activating any trading account.
3.2 Verification may include electronic KYC checks, document authentication, and sanctions list screening.
3.3 Accounts with incomplete or unverifiable documents will not be approved.

4. Ongoing Monitoring

4.1 SequalFX continuously monitors client activity to detect unusual patterns.
4.2 Deposits and withdrawals inconsistent with the client’s profile may be subject to review.
4.3 The Company reserves the right to request updated documentation at any time.

5. Prohibited Activities

5.1 SequalFX strictly prohibits:

• Anonymous or fictitious accounts.
• Third-party deposits or withdrawals.
• Transactions involving countries or entities listed on international sanctions.
• Transactions inconsistent with declared source of funds/wealth.

6. Reporting of Suspicious Activity

6.1 Employees must immediately escalate any suspicious transaction to the Company’s AML Compliance Officer.
6.2 The Company is legally obliged to report such cases to the Financial Intelligence Unit (FIU) of Saint Lucia or other relevant authorities.
6.3 Clients acknowledge that the Company may disclose their information for regulatory compliance purposes without prior notice.

7. Record Keeping

7.1 The Company maintains records of all client identification documents, transactions, and communications for a minimum of five (5) years.
7.2 Such records will be made available to competent authorities upon lawful request.

8. Training & Internal Controls

8.1 All SequalFX employees undergo regular AML/KYC training.
8.2 The Company appoints a dedicated AML Compliance Officer responsible for oversight, reporting, and policy enforcement.
8.3 Internal audits and compliance reviews are carried out periodically.

9. Client Consent

9.1 By opening an account with SequalFX, the Client agrees to provide all requested documents and information.
9.2 The Client understands that failure to comply with AML/KYC requests may result in account suspension or termination.

10. Policy Review

This Policy is reviewed annually or as required to remain compliant with international AML/CTF regulations and the laws of Saint Lucia.

📍 Acknowledgment:
By registering for a trading account, the Client acknowledges and agrees to this AML/KYC Policy as part of the Company’s Terms of Business.