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AML/KYC Policy

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Effective Date: 3.10.2024

Introduction

Volity Prop L.L.C-FZ (“the Company”) is committed to complying with all relevant Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations to prevent, detect, and report any activities relating to money laundering, terrorist financing, or other financial crimes. This policy outlines the AML and KYC procedures adopted by the Company to ensure the integrity of its operations, protect against illegal activities, and comply with applicable regulations.

1. Purpose

The purpose of this AML/KYC policy is to:

  • Safeguard the Company from being used, intentionally or unintentionally, by criminal elements for illicit purposes.
  • Establish a clear framework for the detection and reporting of suspicious activity.
  • Verify the identity of all clients and ensure that their activities are legitimate.
  • Ensure compliance with local and international laws regarding AML and KYC requirements.

2. Scope

This policy applies to all employees, directors, contractors, and agents of Volity Prop L.L.C-FZ, as well as to all clients and counterparties. It covers all operations and trading activities carried out by the Company on its proprietary trading platform or via any other channels.

3. Regulatory Framework

Volity Prop L.L.C-FZ adheres to the following regulatory frameworks:

  • FATF (Financial Action Task Force) guidelines.
  • UAE Federal Laws on Anti-Money Laundering and Combating the Financing of Terrorism (AML-CFT).
  • Relevant regulations and guidelines issued by financial regulatory authorities in jurisdictions where the Company operates.

4. Customer Due Diligence (CDD)

Volity Prop L.L.C-FZ will conduct a thorough Customer Due Diligence (CDD) process for all clients prior to establishing a business relationship. The following steps outline the CDD process:

  • Identity Verification:
    Clients must provide valid and accurate documentation, including but not limited to:
    • Government-issued identification (e.g., passport, national ID, driver’s license).
    • Proof of address (e.g., utility bills, bank statements).
    • Corporate clients must provide relevant business registration documents, ownership structures, and beneficial ownership details.
  • Risk Assessment:
    Each client will be categorized based on a risk assessment that considers factors such as:
    • Geographical location.
    • Nature and complexity of transactions.
    • Business activities and source of funds.
  • Enhanced Due Diligence (EDD):
    For high-risk clients (e.g., clients from high-risk jurisdictions or with complex structures), enhanced due diligence will be conducted. This may include additional documentation or interviews to verify the legitimacy of the client and their business.

5. Ongoing Monitoring

Volity Prop L.L.C-FZ will continuously monitor all client transactions and behavior to detect and prevent suspicious activity. This includes:

  • Regular review of transactions to ensure consistency with the client’s profile and expected activity.
  • Automated and manual checks on trading patterns, account usage, and large or unusual transactions.
  • Updating client profiles as new information is obtained or changes occur in the client’s circumstances.

6. Suspicious Activity Reporting (SAR)

If any suspicious activity is detected, the Company will:

  • Escalate the issue to the Compliance Officer.
  • File a Suspicious Activity Report (SAR) with the relevant authorities in accordance with applicable laws and regulations.
  • Freeze or restrict the client’s account if necessary, pending further investigation.

7. Record Keeping

The Company will maintain accurate and up-to-date records of:

  • All CDD and EDD processes and documentation.
  • Client transaction history.
  • Any suspicious activity reports filed with regulatory bodies.
  • All correspondence with clients related to AML/KYC matters.

These records will be retained for a minimum period of [insert applicable timeframe based on local law] after the client relationship ends or as required by relevant authorities.

8. Employee Training

All employees, especially those involved in compliance, trading, and client management, will receive ongoing AML and KYC training. This includes:

  • Understanding the legal and regulatory requirements.
  • Identifying suspicious behavior and red flags.
  • Properly conducting CDD and EDD procedures.
  • Reporting suspicious activity.

9. Compliance Officer

Volity Prop L.L.C-FZ will appoint a dedicated AML/KYC Compliance Officer who will be responsible for:

  • Ensuring compliance with this policy and relevant regulations.
  • Overseeing the implementation of AML/KYC procedures.
  • Liaising with regulators and law enforcement authorities.
  • Ensuring employees receive proper training.

10. Penalties for Non-Compliance

Failure to comply with this AML/KYC policy, whether by clients, employees, or third parties, may result in:

  • Termination of the business relationship with the client.
  • Disciplinary action against employees, including termination of employment.
  • Legal action or penalties as imposed by regulatory authorities.

11. Review and Updates

This policy will be reviewed annually or as necessary to reflect changes in applicable laws and regulations or the Company’s business operations. Any amendments will be communicated to all relevant parties.