AML/KYC Policy

This policy is designed to ensure compliance with international AML/CFT standards and the laws of the Comoros Union where Jaaz Markets LTD is registered.

1.1 Purpose

• Prevent the use of our services for money laundering or terrorist financing
• Protect our reputation and maintain the integrity of financial markets
• Comply with legal and regulatory requirements
• Detect and report suspicious activities

1.2 Definitions

• Money Laundering: The process of making illegally-gained proceeds appear legal
• Terrorist Financing: Providing financial support to terrorist activities
• KYC: Know Your Customer - procedures to verify client identity
• CDD: Customer Due Diligence - assessment of money laundering risks
• PEP: Politically Exposed Person - individuals with prominent public functions

2.1 Account Opening Requirements

All clients must provide the following information:

2.2 Identity Verification Documents

Acceptable Identity Documents:

• Valid passport (preferred)
• National identity card (both sides)
• Driver's license (if includes photo and date of birth)

Acceptable Proof of Address (dated within 3 months):

• Utility bill (electricity, water, gas)
• Bank statement
• Government-issued document
• Tenancy agreement

3.1 Risk Assessment

We assess each client's risk level based on:

• Geographic location and country of residence
• Nature of business or employment
• Expected transaction volume and frequency
• Source of funds and wealth
• PEP status or association with PEPs

3.2 Enhanced Due Diligence (EDD)

Enhanced measures apply to high-risk clients, including:

• Additional documentation requirements
• Source of wealth verification
• More frequent account reviews
• Senior management approval for account opening
• Restricted transaction limits until full verification

3.3 Simplified Due Diligence

Simplified measures may apply to low-risk clients from well-regulated jurisdictions, subject to regulatory approval.

We continuously monitor client accounts for:

4.1 Periodic Reviews

Account reviews are conducted based on risk level:

• High Risk: Every 6 months
• Medium Risk: Annually
• Low Risk: Every 2 years

5.1 Red Flags

Examples of suspicious activities include:

• Client reluctant to provide KYC information
• Use of falsified or suspicious documents
• Unusual concern about compliance procedures
• Deposits followed by immediate withdrawal requests
• Trading patterns suggesting market manipulation
• Third-party funding without clear relationship

5.2 Reporting Procedures

We maintain comprehensive records including:

• All KYC documentation and verification records
• Transaction records and account statements
• Correspondence with clients
• Internal suspicious activity reports
• Risk assessment documentation

Retention Period: All records are retained for a minimum of 5 years after the termination of the business relationship or completion of the transaction.

We screen all clients against:

• UN Security Council Sanctions List
• EU Consolidated Sanctions List
• OFAC Specially Designated Nationals List
• Local sanctions lists
• PEP databases
• Adverse media databases

Screening is performed at account opening and regularly thereafter. Positive matches result in account restrictions pending investigation.

8.1 Staff Training

All employees receive:

• Initial AML/KYC training upon joining
• Annual refresher training
• Updates on regulatory changes
• Role-specific compliance training

8.2 Compliance Monitoring

Our Compliance Officer conducts regular audits to ensure policy adherence and effectiveness. Any deficiencies are promptly addressed.

Clients must:

• Provide accurate and complete information
• Submit genuine documents for verification
• Update information when circumstances change
• Cooperate with periodic reviews
• Explain unusual transactions when requested
• Not use accounts for illegal activities

10.1 Account Restrictions

We may impose the following restrictions:

• Freeze account pending investigation
• Restrict deposits or withdrawals
• Limit trading activities
• Require additional documentation
• Close positions and return funds

10.2 Reporting to Authorities

We are legally obligated to report suspicious activities to relevant authorities without notifying the client. This may result in:

• Investigation by law enforcement
• Asset freezing orders
• Criminal prosecution
• Permanent exclusion from financial services