At AFD Reserve, we are committed to upholding the highest standards of compliance with Anti-Money Laundering (AML) regulations. This AML Policy outlines our procedures to detect, prevent, and report any suspicious activity related to money laundering, financing of terrorism, and other illicit financial activities.

1. Purpose of the AML Policy

This policy is designed to:

• Prevent the use of AFD Reserve’s services for money laundering, terrorist financing, or any other criminal activities.
• Ensure compliance with all applicable AML laws, regulations, and guidelines.
• Protect AFD Reserve and its customers from potential fraud, reputational risk, and regulatory consequences.

AFD Reserve complies with the laws of the United Kingdom and international AML standards to safeguard our operations and maintain the integrity of the financial system.

2. Customer Due Diligence (CDD)

AFD Reserve employs comprehensive Customer Due Diligence (CDD) measures, including:

• Identity Verification: All customers must provide accurate, verifiable personal information upon registration, including government-issued identification and proof of address.
• Enhanced Due Diligence (EDD): For customers who pose a higher risk, we conduct additional due diligence to confirm their source of funds and monitor account activities more closely.
• Ongoing Monitoring: We continually review account activity to detect unusual or suspicious patterns, with a particular focus on high-risk customers and transactions.

3. Know Your Customer (KYC)

KYC procedures are central to our AML efforts and include:

• Collecting and verifying personal information, such as name, address, date of birth, and occupation.
• Screening customers against sanctions lists, politically exposed persons (PEP) lists, and other high-risk categories.
• Implementing strict identity verification protocols to confirm the legitimacy of all new accounts and account holders.

Failure to provide necessary KYC documentation may result in account restrictions, suspension, or closure.

4. Transaction Monitoring and Reporting

To detect and prevent money laundering, AFD Reserve employs sophisticated monitoring systems to identify potentially suspicious transactions:

• Transaction Analysis: Our automated systems track and analyze customer transactions for unusual patterns, including unusually large transactions, rapid changes in account activity, and other red flags.
• Reporting Suspicious Activities: If suspicious activity is detected, we are legally obligated to report it to relevant authorities, such as the Financial Conduct Authority (FCA) and the National Crime Agency (NCA).
• Record-Keeping: We maintain detailed records of all transactions, account activity, and customer identification documents for a minimum of five years, as required by law.

5. Risk Assessment

AFD Reserve conducts ongoing risk assessments of its customers, products, and services to identify and mitigate potential money laundering and terrorism financing risks. This includes:

• Regular evaluation of customer profiles and activities.
• Classification of customers into risk categories.
• Application of additional controls and monitoring for higher-risk accounts.

6. Training and Awareness

All AFD Reserve employees are trained regularly to recognize and prevent money laundering and terrorist financing risks. This includes:

• Understanding AML laws, regulations, and internal policies.
• Identifying potential red flags associated with suspicious transactions.
• Promptly reporting any suspicious behavior or transactions to the AML Compliance Officer.

7. AML Compliance Officer

Our appointed AML Compliance Officer oversees the implementation and enforcement of this AML Policy. Responsibilities include:

• Ensuring compliance with all AML regulations and reporting obligations.
• Reviewing and updating AML practices and procedures.
• Acting as the primary point of contact for regulatory authorities regarding AML-related matters.

The AML Compliance Officer is responsible for ensuring AFD Reserve’s commitment to maintaining a strong AML culture and implementing proactive measures to mitigate financial crime risks.

8. Customer Responsibilities

AFD Reserve requires that all customers:

• Provide truthful and accurate information during registration and verification processes.
• Promptly update any changes in personal information, such as address or occupation.
• Avoid engaging in or attempting any activities that may be classified as money laundering or terrorism financing.

Failure to adhere to these requirements may result in account suspension or termination.

9. Cooperation with Authorities

AFD Reserve cooperates fully with national and international law enforcement agencies, regulatory bodies, and other financial institutions in the detection, prevention, and investigation of money laundering and financial crime. We reserve the right to:

• Share customer information with regulatory authorities in cases of suspected money laundering.
• Freeze or close accounts found to be in violation of AML regulations.

10. Changes to the AML Policy

AFD Reserve reserves the right to update or modify this AML Policy as required by changes in AML laws, regulations, or operational needs. All updates will be published on our website with the effective date.

11. Contact Us

For further information regarding our AML Policy or to report suspicious activity, please contact:

AFD Reserve Compliance Department
Email: compliance@afdreserve.com
Phone: +44 746 060 9423