This policy sets forth FFF's commitment to preventing money laundering and terrorist financing, covering customer due diligence, monitoring, and reporting obligations.
Data Protection
This Policy outlines the framework for identifying, preventing, and reporting suspicious activities that may be linked to money laundering or the financing of terrorism. It applies to all personnel, directors, contractors, and relevant service providers of FFF, and all customers who engage with the FFF platform.
FFF's AML/CTF framework is designed to:
Prevent the use of FFF services for money laundering or terrorist financing purposes.
Ensure compliance with all relevant AML/CTF laws and regulations in Saint Lucia and Saint Lucia.
Protect the integrity of FFF's platform and uphold the confidence of stakeholders.
Establish a risk-based approach (RBA) to monitoring customer activities.
Money Laundering (ML)
The process of disguising the origin of criminal proceeds to make them appear legitimate.
Terrorist Financing (TF)
Providing or collecting funds with the intention that they be used to support terrorist acts or organizations.
Customer Due Diligence (CDD)
The process of verifying a customer's identity, understanding their activities, and assessing associated ML/TF risks.
Politically Exposed Persons (PEPs)
Individuals with prominent public functions, and their close associates and family members.
Beneficial Owner
A natural person who ultimately owns or controls a customer or the person on whose behalf a transaction is being conducted.
Saint Lucia
Money Laundering (Prevention) Act
Proceeds of Crime Act
Guidelines and directives issued by the Financial Intelligence Authority (FIA)
Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
Organized and Serious Crimes Ordinance (OSCO)
Drug Trafficking (Recovery of Proceeds) Ordinance (DTROP)
United Nations (Anti-Terrorism Measures) Ordinance (UNATMO)
Guidelines issued by the Joint Financial Intelligence Unit (JFIU), SFC, and HKMA
Risk-Based Approach (RBA)
Geographic location
Nature of business activities
Source of funds and wealth
Use of intermediaries or third parties
Trading patterns and volume
Verify identity documents and biometric data
Cross-check against sanctions and PEPs lists
Conduct liveness checks and device risk scoring
Customer Types
Individual Clients
Verified using government-issued ID, facial recognition, and address verification.
Corporate Clients
Submit Certificate of Incorporation, Articles, list of directors, beneficial owners, and authorized signatories.
Ongoing CDD is conducted periodically or on the occurrence of red flags.
Enhanced Due Diligence (EDD)
EDD is performed where:
The customer is a PEP or related to one
The customer resides in or is associated with a high-risk jurisdiction
There are anomalies in trading behavior
EDD measures include:
Obtaining additional identification documents
Independent verification of information
Conducting adverse media checks
Obtaining senior management approval
Customer activity is monitored on a continuous basis through:
Real-time alerts generated by our third party KYC providers and internal systems
Transaction pattern analysis
Monitoring for unusual volumes, counterparties, or jurisdictions
Biometric identity verification
Automated risk scoring
Real-time fraud detection
CDD and EDD documents
Transaction histories
Internal reviews and communications
Filed STRs and related documentation
Records are securely stored and protected from unauthorized access.
FFF must report any suspicious activity to the MLRO. Examples include:
Inconsistent customer behavior
Use of multiple or layered accounts
Requests for anonymity
STRs are submitted to:
FIA — under the Money Laundering (Prevention) Act
JFIU — under the AMLO
The AML program is supported by internal controls, including:
Segregation of duties
Management oversight
Regular compliance audits
Training is provided:
At onboarding for all staff
Annually thereafter
On an ad-hoc basis when changes occur
Training covers:
AML/CTF laws
Internal procedures
Red flags and escalation protocol
FFF screens all customers and transactions against sanctions issued by:
United Nations Security Council
Office of Foreign Assets Control (OFAC)
European Union
Saint Lucia Monetary Authority
Data Protection & Confidentiality
All AML-related data is collected, processed, and stored in accordance with:
The General Data Protection Regulation (GDPR), where applicable
The Saint Lucia Personal Data (Privacy) Ordinance (PDPO)
Applicable data protection laws in Saint Lucia
Information is shared only with authorized personnel or regulators.
All AML/CTF-related queries and internal reports must be directed to the Compliance Department.
Compliance Department
CRN: 2025-00415
CRN: 78177928