AML & CTF Policy

OFF CAPITAL TRADING

ANTI-MONEY LAUNDERING (AML) AND COUNTER-TERRORIST FINANCING (CFT) POLICY

(Comoros Union Regulatory Compliance Version)

1. Purpose

The purpose of this AML/CFT Policy is to establish the framework and internal controls adopted by Off Capital Trading to prevent, detect, and report money laundering, terrorist financing, sanctions violations, and other financial crimes.

The Company is committed to full compliance with the applicable AML/CFT laws and regulations of the Union of Comoros and international best practices.

2. Legal and Regulatory Framework

Off Capital Trading complies with:

  • Applicable AML/CFT legislation of the Union of Comoros
  • Reporting obligations to the Service de Renseignement Financier (FIU)
  • United Nations Security Council sanctions resolutions
  • FATF Recommendations

The Company fully cooperates with competent supervisory and enforcement authorities.

3. Risk-Based Approach (RBA)

The Company adopts a Risk-Based Approach (RBA) to identify, assess, and mitigate ML/TF risks.

3.1. Risk Categories

Risk assessments consider:

  • Customer Risk
  • Geographic Risk
  • Product and Service Risk
  • Transaction Risk
  • Delivery Channel Risk

Enhanced Due Diligence (EDD) measures shall be applied to high-risk customers.

4. Customer Due Diligence (CDD) – KYC Procedures

CDD is conducted before establishing a business relationship.

4.1 Individual Clients

The Company collects and verifies:

  • Valid passport or national ID
  • Proof of address (issued within the last 3 months)
  • Source of funds declaration
  • Occupation and income details
  • Politically Exposed Person (PEP) screening

4.2 Corporate Clients

The Company obtains:

  • Certificate of incorporation
  • Memorandum & Articles of Association
  • Register of directors and shareholders
  • Identification of Ultimate Beneficial Owners (UBOs) (25% or more ownership)
  • Proof of registered address
  • Business activity description

5. Sanctions and PEP Screening

All clients are screened:

  • At onboarding
  • On an ongoing basis
  • Before executing significant transactions

Screening includes:

  • UN sanctions lists
  • International sanctions databases
  • PEP databases

The Company will not establish or continue business relationships with sanctioned individuals or entities.

6. Ongoing Monitoring

The Company maintains continuous monitoring systems to:

  • Detect unusual or suspicious transaction patterns
  • Identify large, complex, or economically unjustified transactions
  • Update client risk profiles periodically
  • Review high-risk accounts more frequently

7. Suspicious Transaction Reporting (STR)

Employees must immediately report any suspicious activity to the AML Compliance Officer.

Where suspicion is confirmed:

  • A Suspicious Transaction Report (STR) will be filed with the Service de Renseignement Financier without delay.
  • Confidentiality is strictly maintained.
  • “Tipping off” is strictly prohibited.

Examples of suspicious activities include:

  • Unexplained large deposits
  • Transactions inconsistent with the client profile
  • Use of complex structures without an economic rationale
  • Attempts to avoid reporting thresholds

8. Record Keeping

The Company maintains:

  • Customer identification records
  • Transaction records
  • Risk assessment documentation

Records shall be retained for a minimum of 10 years or as required under Comoros law.

All records are securely stored and made available to authorities upon lawful request.

9. AML Compliance Officer

The Company appoints a designated AML Compliance Officer responsible for:

  • Monitoring AML/CFT compliance
  • Reviewing suspicious activity reports
  • Liaising with regulatory authorities
  • Conducting annual AML risk assessments
  • Updating internal policies

The Compliance Officer has full independence and direct access to senior management.

10. Internal Controls

The Company implements:

  • Segregation of duties
  • Independent internal review
  • Risk assessment updates at least annually
  • Periodic policy review and board approval

11. Training

All employees receive:

  • Mandatory AML/CFT training upon hiring
  • Annual refresher training
  • Training on identifying suspicious activities
  • Updates on regulatory changes

Training records are maintained for audit purposes.

12. Breach of Policy

Failure to comply with this policy may result in:

  • Disciplinary action
  • Termination of employment
  • Reporting to competent authorities

13. Policy Review and Approval

This AML/CFT Policy is approved by the Board of Directors of Off Capital Trading and shall be reviewed at least annually or when regulatory changes occur.

Risk Warning

Off Capital Trading LTD offers trading on Foreign Exchange (‘Forex’ or ‘FX’) and Contracts for Difference (‘CFDs’), which are complex financial products that are traded on margin. They carry a high level of risk since leverage can work both to your advantage and disadvantage. As a result, these products may not be suitable for all investors, as loss of all invested capital may occur. You should not risk more than you are prepared to lose. Before deciding to trade, you need to ensure that you understand the risks involved and consider your investment objectives and level of experience. Seek independent advice, if necessary.

Off Capital Trading LTD does not issue advice, recommendations or opinions in relation to acquiring, holding or disposing of a CFD. Off Capital Trading LTD is not a financial advisor and all services are provided on an execution-only basis. This communication is not an offer or solicitation to enter into a transaction and shall not be construed as such.

This website is not directed at any jurisdiction and is not intended for any use that would be contrary to local law or regulation. Services are not available for residents of Turkey, USA, North Korea.

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