Banqnote is committed to maintaining the integrity of the financial markets and ensuring compliance with international regulations concerning Anti-Money Laundering (AML) and Know Your Customer (KYC) policies. These measures are designed to prevent illegal activities, including money laundering, terrorism financing, fraud, and other financial crimes. By using Banqnote’s platform, clients agree to adhere to our KYC and AML policies. Below are the detailed provisions of our AML and KYC policies.

Anti-Money Laundering (AML) Policy

1. AML Compliance Program

Banqnote has established a robust AML compliance program to detect and mitigate potential risks. The program includes policies, procedures, and internal controls that are reviewed and updated regularly to align with evolving regulatory standards and industry best practices.

2. Appointment of AML Officer

Banqnote has appointed a dedicated AML Compliance Officer responsible for overseeing all aspects of the AML program. This officer ensures compliance with applicable laws, monitors suspicious activities, and serves as a liaison with regulatory authorities.

3. Risk-Based Approach

Our AML measures follow a risk-based approach, assessing and categorizing clients according to their risk level. This assessment considers factors such as geographical location, transaction behavior, and the type of financial instruments being used.

4. Transaction Monitoring

Banqnote utilizes advanced technology to monitor client transactions in real-time. Our system identifies patterns and flags unusual activities for further investigation, such as unusually large transactions or discrepancies in trading behavior.

5. Suspicious Activity Reporting (SAR)

If suspicious activity is identified, Banqnote files a Suspicious Activity Report (SAR) with the appropriate regulatory authorities. Clients involved in reported activities will be notified only if permitted by law.

6. Sanctions and Watchlists Screening

Banqnote screens all clients and transactions against international sanctions lists, such as those maintained by the United Nations, OFAC, and the EU. Clients flagged on these lists are restricted from using our services.

7. Enhanced Due Diligence (EDD)

Clients categorized as high-risk are subject to Enhanced Due Diligence (EDD) procedures. This includes additional verification steps, closer transaction monitoring, and periodic reviews of account activity.

8. Record-Keeping

Banqnote maintains comprehensive records of client transactions, communications, and identification documents for a minimum of five years. These records are stored securely and are accessible only to authorized personnel.

9. Training and Awareness

All Banqnote employees undergo regular training to recognize and prevent money laundering activities. This training ensures our team is aware of the latest regulations and techniques used by malicious actors.

10. Correspondent Banking Measures

For financial institutions engaging in correspondent banking relationships with Banqnote, additional AML measures are implemented. These include detailed assessments of the institution’s AML practices and monitoring of cross-border transactions.

11. Prohibited Transactions
Banqnote prohibits

transactions involving shell companies, anonymous accounts, and high-risk jurisdictions. Any such activity identified will result in immediate account suspension and reporting to authorities.

12. Customer Education

Banqnote provides resources to educate clients on the importance of AML compliance. Clients are informed about common money laundering techniques and encouraged to report any suspicious activities they encounter.

13. Reporting Thresholds

Transactions exceeding specific monetary thresholds are flagged for additional scrutiny. These thresholds vary by jurisdiction and are implemented in accordance with local and international AML regulations.

14. Independent Audits

Regular independent audits of Banqnote’s AML program are conducted to ensure its effectiveness. These audits provide actionable recommendations to improve our processes and maintain compliance.

15. Cross-Border Transactions

Banqnote implements additional checks for cross-border transactions, particularly those involving high-risk regions. These checks ensure compliance with international laws and reduce exposure to financial crime.

16. Internal Reporting

Banqnote employees are required to report any suspicious activities internally to the AML Compliance Officer. These reports are treated with strict confidentiality and prompt action is taken where necessary.

17. Politically Exposed Persons (PEPs)

Accounts belonging to Politically Exposed Persons (PEPs) undergo additional scrutiny. This includes verifying the source of funds and closely monitoring account activities.

18. Beneficial Ownership Identification

Banqnote requires identification of the ultimate beneficial owners of accounts, particularly for corporate clients. This measure prevents the misuse of legal entities for illicit activities.

19. Cooperation with Authorities

Banqnote fully cooperates with local and international authorities in investigations related to money laundering. This includes providing access to records and assisting in identifying criminal activities.

20. Zero Tolerance Policy

Banqnote enforces a zero-tolerance policy for money laundering. Any client or employee found to be involved in such activities will face immediate consequences, including account closure and legal action.

Know Your Customer (KYC) Policy

1. Purpose of KYC

The KYC policy is designed to verify the identity of Banqnote’s clients and ensure their activities align with legal and ethical standards. This process helps prevent identity theft, fraud, and other financial crimes.

2. Client Identity Verification

All clients are required to submit valid identification documents during account registration. These include government-issued IDs, passports, or driver’s licenses. Banqnote reserves the right to request additional documents for verification.

3. Proof of Address

Clients must provide proof of residential address, such as utility bills or bank statements issued within the last three months. This information is used to confirm the client’s physical location.

4. Document Authenticity Checks

Banqnote conducts rigorous checks to ensure the authenticity of submitted documents. Any falsified or tampered documents will result in immediate account suspension.

5. Ongoing KYC Reviews

Periodic reviews of client information are conducted to ensure it remains accurate and up-to-date. Clients are required to update their information promptly if there are changes.

6. Corporate Account Verification

For corporate clients, Banqnote requires detailed information about the company’s ownership structure, directors, and authorized signatories. This includes submitting incorporation documents and shareholder details.

7. High-Risk Client Identification

Clients identified as high-risk, based on factors such as geographic location or account activity, are subject to additional KYC measures. These measures include enhanced verification and closer monitoring.

8. Verification During Withdrawals

Banqnote may conduct additional identity verification before processing withdrawals. This ensures funds are released only to authorized account holders.

9. Source of Funds Declaration

Clients are required to declare the source of their funds when making significant deposits. Banqnote may request supporting documents, such as bank statements or pay slips, to verify this information.

10. Data Privacy in KYC

All personal information collected during the KYC process is handled in compliance with data protection laws. Banqnote ensures that client data is stored securely and used solely for verification purposes.

11. Account Limitations for Non-Compliance

Clients who fail to complete the KYC process are subject to account limitations, including restricted access to trading features and withdrawals. Non-compliance may result in account suspension.

12. PEP Screening

Banqnote screens all clients to identify Politically Exposed Persons (PEPs). PEPs are subject to additional verification and monitoring to mitigate risks associated with their status.

13. Beneficiary Identification

For accounts involving third-party beneficiaries, Banqnote requires full disclosure of beneficiary information. This ensures transparency and reduces the risk of misuse.

14. KYC for Multiple Accounts

Clients holding multiple accounts must complete the KYC process for each account. This ensures consistency and accuracy in client records.

15. KYC for Account Reactivation

Dormant or suspended accounts require re-verification before reactivation. Clients must provide updated documents and confirm their intent to continue using Banqnote’s services.

16. Geographic Restrictions

Banqnote prohibits accounts from jurisdictions subject to international sanctions or high-risk assessments. Clients from such regions are automatically restricted from accessing our services.

17. KYC for Large Transactions

Clients engaging in large transactions may be required to undergo additional KYC verification. This includes providing documentation to substantiate the transaction’s purpose and source of funds.

18. Training on KYC Standards

All Banqnote employees receive regular training on KYC requirements to ensure compliance and maintain high verification standards.

19. Automated Verification Tools

Banqnote uses automated tools to streamline the KYC process. These tools enhance accuracy, reduce processing times, and identify discrepancies efficiently.

20. Continuous Improvement

Banqnote regularly evaluates and updates its KYC policies to adapt to regulatory changes and emerging threats. This ensures our processes remain robust and effective.

Commitment to Compliance

Banqnote’s KYC and AML policies reflect our unwavering commitment to regulatory compliance and financial integrity. By implementing these measures, we strive to create a secure, transparent, and trusted trading environment for all clients.