This Anti-Money Laundering (AML) Policy is established to ensure that Forex Prop Firm, a Canadian-based Forex Proprietary Trading Firm, complies with all applicable laws and regulations related to anti-money laundering, counter-terrorism financing, and sanctions. The policy outlines the company’s commitment to preventing money laundering activities and sets guidelines for employees, contractors, and other relevant parties to follow.
2. Policy Objective
The primary objective of this AML Policy is to detect, prevent, and report any suspicious activities related to money laundering, terrorism financing, or any other illicit financial activities. Forex Prop Firm is dedicated to maintaining the integrity of the financial system and ensuring its services are not misused for unlawful purposes.
3. AML Compliance Officer
Forex Prop Firm shall designate an AML Compliance Officer responsible for overseeing the implementation and effectiveness of this AML Policy. The AML Compliance Officer will have the authority to take necessary actions and report directly to senior management and the Board of Directors.
4. Customer Due Diligence (CDD)
4.1. Know Your Customer (KYC): The firm shall conduct thorough customer due diligence during onboarding and periodically review existing clients. This includes obtaining and verifying customer identification information, understanding the customer’s source of funds, and assessing the risk associated with each client.
4.2. Enhanced Due Diligence (EDD): For high-risk clients, politically exposed persons (PEPs), and clients from high-risk jurisdictions, additional enhanced due diligence measures shall be applied.
5. Reporting Suspicious Activities
5.1. Internal Reporting: All employees and relevant parties are required to promptly report any suspicious activities or transactions to the AML Compliance Officer. This includes unusual transaction patterns, large or frequent cash transactions, or any behavior that raises AML concerns.
5.2. Whistleblower Protection: Forex Prop Firm shall ensure that individuals reporting suspicious activities are protected from any retaliation or adverse actions.
6. Record Keeping
The firm shall maintain accurate and up-to-date records of customer identification, transaction details, and all related documents in compliance with Canadian AML regulations. These records shall be kept for a minimum period as required by law.
All employees and relevant parties involved in financial services shall receive regular AML training. This training will educate them about the importance of AML compliance, how to identify suspicious activities, and the company’s procedures for reporting such activities.
8. Sanctions Compliance
Forex Prop Firm shall adhere to all Canadian and international sanctions programs. This includes monitoring and screening transactions and clients against relevant sanctions lists to ensure compliance.
9. Risk Assessment and Review
The AML Compliance Officer shall conduct periodic risk assessments and reviews of the AML Policy’s effectiveness. Any necessary updates or improvements shall be made based on the findings of these assessments.
Non-compliance with this AML Policy or any AML-related laws and regulations may lead to disciplinary actions, including termination of employment or business relationships, as well as potential legal consequences.
11. Law Clauses for Anti-Money Laundering in Canada
11.1. Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA): Forex Prop Firm shall comply with the PCMLTFA, which includes obligations for customer identification, record-keeping, reporting of suspicious transactions, and reporting large cash transactions.
11.2. Financial Transactions and Reports Analysis Centre of Canada (FINTRAC): Forex Prop Firm shall register with FINTRAC as required under the PCMLTFA and provide necessary reports and information to the agency.
11.3. Canadian Sanctions Laws: Forex Prop Firm shall comply with the Special Economic Measures Act (SEMA) and the United Nations Act (UNA), which impose restrictions on financial transactions with sanctioned countries, individuals, and entities.
By adhering to this Anti-Money Laundering Policy, Forex Prop Firm aims to contribute to a safe and transparent financial environment. All employees and relevant parties are expected to understand and comply with this policy to prevent and detect any potential money laundering or illicit financial activities within the company’s operations.
This AML Policy shall be reviewed and updated regularly to reflect changes in regulations and best practices and to ensure ongoing compliance with Canadian laws and regulations.
Document Required from Individuals Opening an Account
In accordance with applicable Canadian laws, Forex Prop Firm (FPF) must verify your identity before allocating company capital to any individuals as a contractor. There are various ways to verify your identity, but we usually confirm a person’s identity with a photo ID and proof of address.
A valid photo ID may either be a (1) passport or (2) government-issued ID, such as a driver’s license. Please ensure that the photo ID shows your full name and date of birth. Any missing information may disqualify you from opening an account with FPF.
A valid proof of address comes in many forms. The following is a list of documents that are acceptable forms of proof of address:
- Lease agreement or mortgage statement
- Insurance card
- Voter registration card
- Utility bill
- Mail with name of applicant
- Bank or credit card statement
- Government-issued tax document
- Record of employment or pay stub
- School transcript
Note that any of the aforementioned proof of identity documents must be current. Any document that is expired or more than three (3) months old will not be accepted. Additionally, any document with the individual’s name and a P.O. Box address will not be accepted.
However, should you have trouble accessing or having possession of any of the documents listed above, please contact us so we can assist further. We may be able to accept the certificate of citizenship. Documents must be in English. If documents are in another language, FPF reserves the right to require the document to be translated in English alongside the original document.
FPF performs actions to adhere to applicable laws and regulations. It does not accept cash deposits nor does it disburse cash under any circumstance. Furthermore, FPF does not accept third-party deposits of any kind. FPF reserves the right to refuse processing of a transaction along any stage where it believes that the transaction is or may be associated with unlawful, illegal, or willful misconduct that may lead to money laundering crimes or criminal activity. Should there be suspicion or a determination that the account holder is engaged in criminal activity, FPF is not obligated to inform the client if suspicious activity is reported to any regulatory or legal body of the government.