Anti-Money Laundering (AML) Policy

1. Purpose and Commitment

TradeFlux is committed to preventing its services from being used to facilitate financial crime. We take this responsibility seriously, and we ask our customers to work with us in doing so.

This policy sets out the principles we apply to help prevent our services being used in connection with:

• money laundering
• terrorist financing
• fraud
• sanctions evasion
• other forms of financial crime

TradeFlux maintains proportionate controls intended to identify, assess and manage financial-crime risk associated with the use of its services. These controls are reviewed from time to time and may be adjusted as our services and risk profile change.

2. Scope

This policy applies to customers who use, or seek to use, TradeFlux services, and to the onboarding and account-review processes that support them.

It covers the information we may collect during registration and verification, the reviews we may carry out while a relationship is active, and the circumstances in which we may restrict or end access to our services.

3. Risk-Based Approach

We consider financial-crime risk using a risk-based approach. This means the level of review applied is proportionate to the risk presented, rather than identical in every case.

Factors we may consider, where relevant

• information provided by the customer
• country or geographic risk associated with the relationship
• the nature and intended purpose of the relationship
• behaviour that appears unusual in the circumstances
• inconsistencies between information supplied at different points
• other risk indicators we consider relevant

Where a situation appears to present a higher risk, we may carry out additional review before or during the provision of services. Where risk appears lower, the review applied may be more limited.

4. Customer Due Diligence

TradeFlux may request information reasonably necessary to understand and verify a customer before or during the provision of services.

Information we may request

• full legal name
• date of birth, where required
• country of residence
• contact information
• identity documentation, where required
• information regarding the intended use of the service
• other information reasonably necessary for verification

Not every customer will be asked for every item listed above. What we request depends on the circumstances of the relationship and the outcome of the risk-based approach described in Section 3.

Where requested information is not provided, or cannot be verified, we may be unable to proceed with onboarding or to continue providing services. Section 11 explains this further.

5. Enhanced Due Diligence

Where a relationship or activity appears to present a higher financial-crime risk, TradeFlux may carry out additional checks beyond those described in Section 4.

Measures that may apply

• requesting additional identification information
• carrying out additional verification steps
• seeking clarification of information already supplied
• reviewing the intended purpose of the relationship in more detail
• conducting further review before activation or before continuing to provide services

These measures are applied where we consider them appropriate in the circumstances. They are not intended to be exhaustive, and the presence of a higher-risk indicator does not by itself imply wrongdoing.

6. Sanctions and Higher-Risk Persons

Where required or otherwise appropriate, TradeFlux may carry out checks relating to sanctions and other elevated-risk indicators in connection with the use of its services.

Matters these checks may relate to

• sanctions measures applicable to a customer or relationship
• politically exposed persons (PEPs) and their close associates
• other circumstances that appear to present elevated risk

Where a check raises a concern, we may request further information, delay activation, or take the steps described in Sections 8 and 11. Being identified as a higher-risk person does not automatically prevent access to TradeFlux services, but it may lead to additional review.

7. Ongoing Monitoring and Review

TradeFlux may periodically review customer information and activity associated with the use of its services, so that the information we hold remains accurate and our understanding of the relationship stays current.

Reasons a review may be carried out

• material changes to a customer's details
• information that appears inconsistent
• behaviour that appears unusual in the circumstances
• risk indicators identified through our controls
• compliance or security concerns

Where appropriate, we may request additional information as part of a review. We aim to keep such requests proportionate and to explain what is needed.

8. Suspicious or Unusual Activity

TradeFlux may review activity or information that appears inconsistent, unusual, or potentially connected to financial crime.

Steps we may take, where appropriate

• request further information or clarification
• delay or restrict activation of a service
• suspend access to TradeFlux services
• terminate the relationship
• make reports or disclosures where required by applicable law

There may be circumstances in which we are limited in what we can tell a customer about a review or a disclosure. Where we are able to explain our reasoning, we will aim to do so.

9. Record Keeping

TradeFlux may retain records relating to onboarding, verification, communications and compliance for as long as required by applicable law, or for as long as reasonably necessary for legitimate business and compliance requirements.

Records may include information supplied during registration, verification materials, correspondence with our team, and records of reviews carried out under this policy.

How personal information within those records is handled is described in our Privacy Policy.

10. Customer Responsibilities

Our controls work best when the information we hold is accurate. We ask customers to:

• provide accurate and complete information
• keep important information current
• respond to reasonable verification requests
• not provide false or misleading information
• not use TradeFlux services for unlawful purposes
• notify TradeFlux where relevant customer information materially changes

If you are unsure whether a change is relevant, it is usually easier to tell us than not to. Keeping details current helps us avoid unnecessary requests later.

11. Restriction or Termination of Service

TradeFlux may decline, delay, suspend or terminate access to its services where:

• information we reasonably require cannot be obtained
• information provided appears materially inaccurate or misleading
• financial-crime concerns arise in connection with the relationship
• continued service would expose TradeFlux to unacceptable legal or compliance risk
• restricting the service is otherwise reasonably necessary

12. Third-Party Services

Using TradeFlux involves interacting with independent third-party providers, including brokers such as RoboForex.

• TradeFlux and RoboForex are separate services, operated separately.
• Customers remain responsible for meeting the broker's own verification, account and legal requirements.
• TradeFlux does not control RoboForex's AML or KYC procedures, and this policy does not describe them.

Meeting TradeFlux's requirements under this policy does not mean a broker's requirements have been met, and the reverse is also true. Each is assessed separately by the party responsible for it.

13. Privacy and Personal Information

Personal information collected for onboarding, verification and compliance purposes is handled in accordance with the TradeFlux Privacy Policy, which explains what we collect, how it is used, and the choices available to you.

View Privacy Policy

14. Policy Updates

This AML Policy may be updated from time to time to reflect changes to:

• TradeFlux services
• our risk controls
• legal requirements applicable to us
• our operational processes

The version published on the TradeFlux website is the current one. We recommend reviewing it periodically, and checking the Last Updated date shown at the top of this page.