BVI COI Policy

POLITICALLY EXPOSED PERSON (PEP) POLICY
1. INTRODUCTION
Fx1 Markets Ltd. is an entity incorporated under the International Business
Companies (Amendment and Consolidation) The REGISTRAR OF CORPORATE
AFFAIRS of the British Virgin Islands HEREBY CERTIFIES that, pursuant to the BVI
Business Companies Act, 2004 on the 20th day of March 2019.
BVI COMPANY NUMBER 2009068.
Pursuant to FATF Recommendation 10 and 12, the Company outlines the internal
processes and measures taken in dealing with Politically Exposed Person (PEP).
The Company is required to implement measures requiring financial institutions to
have appropriate risk management systems in place to determine whether customers
or beneficial owners are foreign PEPs or related or connected to a foreign PEP. If
they are, they are required to take additional measures beyond performing normal
customer due diligence (CDD) (as defined in Recommendation 10) to determine if and
when they are doing business with them.
For domestic PEPs and international organization PEPs, The Company takes
reasonable measures to determine whether a customer or beneficial owner is one.
The 2003 FATF Recommendations encouraged countries to extend the requirements
to domestic PEPs. For higher risk business relationships with domestic PEPs and
international organization PEPs, the Company takes additional measures consistent
with those applicable to foreign PEPs.
The relationship between Recommendations 10 and 12, and the resulting
requirements for determining if clients are foreign or domestic/international
organization PEPs can be summarized in the following key measures.
2. KEY MEASURES
There are some key measures that The Company will enforce in accordance to the
PEP policy:
2.1 Primary Measures
The Company exercises Client Self-Declarations. Before onboarding a Client,
the Company requires the prospective Client to declare their PEP status (i.e. by
disclosing present or former employment or principal occupation clearly
recognizable as a PEP) as a means of helping to determine whether that
prospective Client is a PEP.
To help prospective Clients better understand if they are indeed a PEP, the
Company actively displays the definition of PEP and different elements
pertaining to such definition.
2.2 Secondary Measures
As an additional step, the Company utilizes publicly available search engines in
order to prevent the scenario that the Client falsely declare their PEP status.
Internet and media searches focus on sources that could be linked to the
customer may assist in locating relevant information (for example, (social) media
websites in the customer’s country of origin). Internet searches can also assist
in retrieving general relevant (country) information. For example, for a financial
institution or DNFBP it is relevant to know which countries prohibit certain PEPs
(such as elected officials) from maintaining bank accounts abroad.
2.3 Continuous Monitoring
Regular review
• The Company conducts enhanced regular review to ensure Client CDD
Information is up to date. For high-value account that has balances of more
than USD100,000 or equivalent; the Company will conduct special monitoring
by means of phone calls to registered phone number. Existing clients
sometimes become PEPs after they enter a business relationship, so it is
essential that The Company monitors non-PEP accounts for a change in the
PEP status, customer profile or account activity and update customer
information. Such ongoing monitoring should be based on risk, consistent
with FATF Recommendation 10.
Ongoing Employee Training
• The Company ensure a robust internal control policy with ongoing employee
training programs. These training programs need to address effective ways
of determining whether clients are PEP and to understand, assess and
handle the potential risks associated with PEPs. Training should also use real
life case studies and examples to ensure it is up to date. Human input and
analysis from experienced and trained employees can be more valuable than
automated software programs for detecting and handling the risks associated
with PEPs. This is especially the case for high net worth customers that are
PEPs, which potentially carry the highest corruption and money-laundering
risks.
Escalation to senior management
• The Company establishes escalation to senior management to engage with
high-risk PEPs. Domestic PEPs and foreign PEPs (of account balances more
than USD 100,000 or equivalent) are always considered high risk and require
the application of enhanced due diligence measures. This should further lead
to more proactive steps, in particular, to an increase in the monitoring of the
business relationship, in order to determine whether those transactions or
activities appear unusual or suspicious. The Company also takes reasonable
measures to establish the source of wealth and the source of funds.
3. RELEVANT DEPARTMENT
3.1 Customer Service Department
Email: support@fx1markets.com
3.2 Compliance Department
Email: legal@fx1markets.com