1INTRODUCTION & PURPOSE

This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy ("Policy") sets forth the commitment and procedures implemented by Fx Funds Flow Limited (a company incorporated in Saint Lucia, CRN: 2025-00415) and FF Flow Limited (a company incorporated in Hong Kong, CRN: 78177928), collectively referred to as "Forex Funds Flow" or "FFF".

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.

2SCOPE

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 Hong Kong
  • Protect the integrity of FFF's platform and uphold the confidence of stakeholders
  • Establish a risk-based approach (RBA) to monitoring customer activities

3DEFINITIONS

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.

4REGULATORY FRAMEWORK

4.1. Saint Lucia

  • Money Laundering (Prevention) Act
  • Proceeds of Crime Act
  • Guidelines and directives issued by the Financial Intelligence Authority (FIA)

4.2. Hong Kong

  • 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

4.3. International Compliance

FFF will comply with all applicable international AML/CTF obligations, including those imposed by the Financial Action Task Force (FATF).

5RISK-BASED APPROACH (RBA)

5.1. Risk Assessment Framework

FFF applies an RBA to assess and mitigate ML/TF risks. Customers are classified into low, medium, or high-risk categories based on:

  • Geographic location
  • Nature of business activities
  • Source of funds and wealth
  • Use of intermediaries or third parties
  • Trading patterns and volume

5.2. Enhanced Due Diligence

Enhanced Due Diligence (EDD) is applied to high-risk customers.

6CUSTOMER DUE DILIGENCE (CDD)

6.1. CDD Requirements

CDD is mandatory before providing services. FFF uses Veriff as its third-party KYC/AML provider to:

  • Verify identity documents and biometric data
  • Cross-check against sanctions and PEPs lists
  • Conduct liveness checks and device risk scoring

6.2. 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

6.3. Ongoing Monitoring

Ongoing CDD is conducted periodically or on the occurrence of red flags.

7ENHANCED DUE DILIGENCE (EDD)

7.1. When EDD is Required

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

7.2. EDD Measures

EDD measures include:

  • Obtaining additional identification documents
  • Independent verification of information
  • Conducting adverse media checks
  • Obtaining senior management approval

8ONGOING MONITORING

8.1. Continuous Monitoring

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

8.2. Alert Management

Alerts are reviewed by Compliance, and suspicious behavior is escalated to the MLRO.

9TECHNOLOGY PROVIDERS

9.1. Veriff Integration

FFF uses Veriff for digital onboarding and compliance, offering:

  • Biometric identity verification
  • Automated risk scoring
  • Real-time fraud detection

9.2. Technology Review

The integration with Veriff is reviewed quarterly by the Compliance team.

10RECORD KEEPING

10.1. Record Retention Requirements

FFF retains the following records for at least 5 years after the end of a customer relationship:

  • CDD and EDD documents
  • Transaction histories
  • Internal reviews and communications
  • Filed STRs and related documentation

10.2. Data Security

Records are securely stored and protected from unauthorized access.

11REPORTING OBLIGATIONS

11.1. Suspicious Activity Reporting

FFF must report any suspicious activity to the MLRO. Examples include:

  • Inconsistent customer behavior
  • Use of multiple or layered accounts
  • Requests for anonymity

11.2. STR Submissions

STRs are submitted to:

  • FIA (Saint Lucia) under the Money Laundering (Prevention) Act
  • JFIU (Hong Kong) under the AMLO

12INTERNAL CONTROLS

12.1. Control Framework

The AML program is supported by internal controls, including:

  • Segregation of duties
  • Management oversight
  • Regular compliance audits

12.2. Independent Auditing

Independent audits are conducted annually or when material changes occur. Audit findings are reported to Senior Management.

13TRAINING & AWARENESS

13.1. Training Schedule

Training is provided:

  • At onboarding for all staff
  • Annually thereafter
  • On an ad-hoc basis when changes occur

13.2. Training Content

Training covers:

  • AML/CTF laws
  • Internal procedures
  • Red flags and escalation protocol

14SANCTIONS SCREENING

14.1. Sanctions Compliance

FFF screens all customers and transactions against sanctions issued by:

  • United Nations Security Council
  • Office of Foreign Assets Control (OFAC)
  • European Union
  • Hong Kong Monetary Authority

15DATA PROTECTION & CONFIDENTIALITY

15.1. Data Protection Compliance

All AML-related data is collected, processed, and stored in accordance with:

  • The General Data Protection Regulation (GDPR), where applicable
  • The Hong Kong Personal Data (Privacy) Ordinance (PDPO)
  • Applicable data protection laws in Saint Lucia

15.2. Information Sharing

Information is shared only with authorized personnel or regulators.

16CONTACT

16.1. Compliance Contact

All AML/CTF-related queries and internal reports must be directed to the Compliance Department at:

Email: support@forexfundsflow.com

Need Help?

For questions or concerns about this forex funds flow anti-money laundering policy, our support team is here to help.

📧support@forexfundsflow.com