AML / KYC Policy

Introduction

SEwealthMarket ("we", "us", "our", "the Company") operates as a professional Forex and cryptocurrency account management service. We are committed to preventing our services from being used for money laundering, terrorist financing, or any other financial crime.

This Anti-Money Laundering and Know Your Customer (AML/KYC) Policy establishes the framework within which we identify, assess, and manage the risks of financial crime. It applies to all clients, staff, and third parties who interact with our services.

Our AML/KYC procedures are designed in accordance with internationally recognized standards, including guidelines issued by the Financial Action Task Force (FATF), applicable regional regulations, and the regulatory requirements of our broker partners.

Purpose & Scope

The purpose of this policy is to:

• Prevent SEwealthMarket from being used as a vehicle for money laundering, terrorist financing, or other financial crimes
• Establish clear procedures for verifying the identity of all clients (KYC)
• Define how we monitor transactions and client behavior for suspicious activity
• Ensure compliance with applicable AML laws and international standards
• Protect the Company's reputation and the integrity of the financial system
• Establish reporting obligations for suspicious activity

This policy applies to all individuals and entities seeking to use or currently using SEwealthMarket's services, regardless of their location or the size of their investment.

Key Definitions

• Money Laundering (ML): The process of concealing the origin of funds obtained through criminal activities by passing them through a complex sequence of banking transfers or commercial transactions
• Terrorist Financing (TF): The provision or collection of funds with the intention of using them, or knowing they will be used, to carry out terrorist acts
• Know Your Customer (KYC): The process of verifying a client's identity and understanding the nature of their activities to assess potential risks
• Customer Due Diligence (CDD): The steps taken to identify and verify a customer's identity and the nature of their business relationship with us
• Enhanced Due Diligence (EDD): Additional, more rigorous checks applied to higher-risk clients or transactions
• Politically Exposed Person (PEP): An individual who holds or has held a prominent public position, which may create a higher risk of bribery or corruption
• Suspicious Activity Report (SAR): A report filed with the appropriate authorities when we suspect money laundering or terrorist financing
• Beneficial Owner: The natural person who ultimately owns or controls a client or on whose behalf a transaction is conducted

KYC Onboarding Process

All new clients must complete our KYC verification process before accessing our account management services. No funds will be managed until KYC is successfully completed. Our verification process follows these steps:

Required Documents

All clients must provide the following documentation to complete KYC verification:

All documents must be clear, legible, and unexpired. We reserve the right to request additional documentation if deemed necessary for verification purposes. Documents may be submitted digitally through our secure client portal.

Customer Due Diligence (CDD)

Standard Customer Due Diligence is applied to all new and existing clients. CDD measures include:

• Verifying the identity of the client using reliable, independent source documents
• Verifying the identity of any beneficial owner (where applicable)
• Understanding the nature and purpose of the business relationship
• Assessing the source of funds to be invested
• Conducting ongoing monitoring of the business relationship and transactions
• Keeping documents, data, and information up to date

CDD is an ongoing process. We may require clients to provide updated documentation at any time, particularly when there are significant changes to their account activity or personal circumstances. Failure to provide required information may result in restriction or termination of services.

Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to clients who present a higher risk of money laundering or financial crime. EDD is triggered by factors including, but not limited to:

• Clients identified as Politically Exposed Persons (PEPs) or their associates
• Clients from high-risk jurisdictions identified by FATF or international bodies
• Unusually large or complex transactions without clear economic justification
• Business relationships with an unusual structure or opacity regarding beneficial ownership
• Clients whose source of funds cannot be satisfactorily explained or verified
• Clients flagged during sanctions or adverse media screening

EDD measures may include requesting additional documentation, seeking third-party verification, requiring senior management approval, conducting more frequent monitoring, and requesting face-to-face or video verification.

Politically Exposed Person (PEP) Screening

SEwealthMarket screens all clients against PEP databases as part of our standard onboarding and ongoing monitoring procedures. Politically Exposed Persons include:

• Current or former heads of state or government
• Senior government officials, judicial officers, or military officers
• Senior executives of state-owned enterprises
• Senior officials of political parties
• Immediate family members and known close associates of the above

PEPs are not automatically refused services, but they are subject to Enhanced Due Diligence, senior management approval, and enhanced ongoing monitoring. We take a risk-based approach to assessing each PEP relationship individually.

Transaction Monitoring

We conduct ongoing monitoring of client accounts and transactions to detect unusual or suspicious activity. Our transaction monitoring includes:

• Monitoring of account activity against established client profiles and expected transaction patterns
• Automated alerts for transactions that deviate significantly from normal patterns
• Review of large, unusual, or complex transactions that lack an obvious legitimate purpose
• Monitoring for patterns consistent with layering, placement, or integration of illicit funds
• Screening of all transactions against current sanctions and watchlists
• Periodic reviews of higher-risk client accounts

Clients are expected to promptly explain the nature of any unusual transactions upon request. Failure to provide satisfactory explanations may result in account restriction and reporting to relevant authorities.

Suspicious Activity Reporting

We are legally obligated to report suspicious activities to the appropriate authorities. Indicators of suspicious activity include:

• Transactions that appear inconsistent with the client's known business, income, or financial profile
• Unusual requests for secrecy or reluctance to provide required documentation
• Use of multiple accounts or third-party accounts without legitimate explanation
• Requests to structure transactions in ways that appear designed to avoid reporting thresholds
• Evidence or suggestion that funds may originate from criminal activity
• Attempts to conduct transactions involving countries, entities, or individuals under international sanctions

Record Keeping

We maintain comprehensive records of all KYC documentation, transactions, and compliance activities in accordance with regulatory requirements:

• KYC Records: Retained for a minimum of 5 years from the date of account closure or end of the business relationship
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction
• Suspicious Activity Reports: Retained for a minimum of 5 years from the date of the report
• Correspondence Records: Retained as required by applicable regulations and for at least 3 years

All records are stored securely with appropriate access controls and encryption. Records may be made available to competent authorities upon lawful request. We comply with applicable data protection laws in the storage and handling of these records.

Sanctions Compliance

SEwealthMarket maintains a strict sanctions compliance program. We do not knowingly conduct business with individuals, entities, or countries subject to international sanctions:

• All clients are screened against OFAC (US), EU, UN, and other relevant sanctions lists at onboarding and on an ongoing basis
• We will not process transactions involving sanctioned countries, entities, or individuals
• Any match against a sanctions list results in immediate account freeze pending investigation
• Confirmed sanctions matches are reported to the relevant authorities immediately
• We do not provide services to residents of countries under comprehensive international sanctions

Our sanctions screening is updated regularly to reflect new and amended designations from all relevant sanctioning bodies.

Staff Training

All SEwealthMarket staff who interact with clients or handle client data receive regular AML/KYC training covering:

• Recognition of money laundering and terrorist financing red flags
• KYC verification procedures and document review
• Sanctions screening processes and obligations
• Suspicious Activity Reporting procedures and legal obligations
• Data protection and confidentiality requirements
• Updates on regulatory changes and emerging financial crime trends

Training is conducted at onboarding and at regular intervals thereafter. Staff involved in compliance functions receive enhanced and specialized training appropriate to their roles.

Compliance Officer

SEwealthMarket has designated a Compliance Officer responsible for overseeing the implementation and effectiveness of this AML/KYC Policy. The Compliance Officer's responsibilities include:

• Implementing, maintaining, and updating this AML/KYC Policy
• Reviewing and approving high-risk client onboarding decisions
• Reviewing and approving Suspicious Activity Reports before filing
• Liaising with regulatory authorities and law enforcement as required
• Ensuring all staff receive appropriate AML/KYC training
• Conducting regular internal audits of AML/KYC compliance
• Staying current with regulatory developments and updating policies accordingly

The Compliance Officer has direct access to senior management and operates independently to ensure the integrity of our compliance framework.

Contact Us

For any questions regarding our AML/KYC Policy, verification requirements, or compliance matters, please contact our Compliance team: