We at Carlos and Company, by the implication of the Anti Money Laundering Policy, testify to our commitment to illegal activities like money laundering and commercial financing of illegal and anti-social elements. As per the policy directives of the company code of law, we ensure that our offered services are completely in co-ordinance with the guidelines portrayed by the governing bodies and do not endorse being utilized for any criminal or forbidden offence, including but not limited to those under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (Cap.65 A of Singapore) and terrorism (Suppression of Financing) Act (Cap. 325 of Singapore). The organization has instituted this AML Policy under varied scopes, from employees to clients and business units, and appointed authorities to ensure transparency of trading and the prevention of money laundering and other illegal activities faced by financial consulting transactions. The terms “We”, “Our”, “Company”, and “Us” refer to the company, and the terms “User”, “You”, and “Your” refer to a User or Subscriber of our offered subscription services in varied segments of FOREX and COMEX. The AML Policy so defined under is equally applicable for any prospected subscriber desiring to avail of the offered services or otherwise using or benefitting from the use of our paid/unpaid online or social media platforms and must compulsorily be read as a part of the User Terms and Conditions. You must read this AML Policy before subscribing to our services, using our reports/signals through paid or unpaid official company social media platforms (authenticated official accounts only), or submitting any personal information. By subscribing to our services, you are expressing your mutual consent to be bound by the User Terms and Conditions and, consequently, this AML Policy as furnished in the company code of law.

DEFINITION

In this AML Policy:

“Beneficial Owner” means:

1. In the case of companies, the authority/entity or person who owns over 25% of the shares of the company is authorized to claim 25% of the profits or has the power, directly or indirectly, to appoint or elect more than half of the board of directors of such company, as the case may be

1. “Identification Document(s)” refers to:

1. Proof of Identity such as a passport or official identification documents like a national Identification card and birth certificate) demonstrating authentic and verified information like Photograph, Full Name, Unique Identification Number (as assigned by government authorities/institution of the country), Date of Birth, Nationality, and Affidavit of name alteration (if applicable);

2. Proof of address (driver’s license, utility bills, financial statements, or correspondence from a government agency within the last 3 months, displaying the full name and residential address and Any other document as an alteration in guidelines under the same concern by the regulatory bodies of the country or institution is classified under “Periodic Updates”. It refers to undertaking the user’s identity verification fresh by following the procedure formulated under Section-(Customer Verification Procedure)of this AML Policy at such intervals as the company deems fit or as directed by appropriate enforcement authorities. “Sanction Lists” refer to lists of authorized official and jurisdictional officials included under any list circulated by any country/government/law enforcing authority or international authority, including the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State, the United Nations Security Council, the European Union, Her Majesty’s Treasury, the Hong Kong Monetary Authority or the Monetary Authority of Singapore.

“Suspicious Transactions” refers to the following activities, whether attempted or executed:

I Terrorist Financing: It refers to any sort of transaction carried out or appears to be any fund collected to be utilized directly or indirectly in any anti-social, criminal or terrorist offences or acts, including all “Terrorism Financing Offence” as defined in the Terrorism (Suppression of Financing) Act (Cap.325of Singapore);

ii Unusually Complex: transactions which appear to have been structured/formulated portrayal in a manner of unusual or unjustified complex happenings or occurrences; or

iii Malafide Purpose: transactions appear to have not been faceted for Bonafede’s purpose or have a sound economic rationale. The capitalized terms used herein, but not defined, shall have the meaning given to such terms in the Terms (defined below)

2. AML POLICY IN USER TERMS AND CONDITIONS

This AML Policy, so formulated to safeguard the interest of both the parties involved (USER AND SERVICE PROVIDER), is incorporated within and is to be read along with the User Terms and Conditions (the “Terms”) any Subscriber enrolling or enquiring for the services in concurrent alliance or prospected to be a part of it is meant to be reading the said policy and expressing consent to the same.

3. POLICY EXECUTION AND CHANGES

The drafting institution or the governing bodies insole or co-ordination forex execution of better service provisions reserve all the rights to renew, amend and alter the formulated AML policy periodically with or without any prior notice. Any changes so implemented shall be effective from the amendment dates on the foregoing basis, not including or limited to a retroactive basis unless compulsory by the enforcement body. You are requested to keep track of the AML Policy whenever you get a chance to visit our online platforms.

4. USER OBLIGATIONS

1. The furnished AML Policy is to avoid using our services and any authorized official platforms of CarlosandCompany in any manner that results in commitment or attempt of any criminal offences. You also agree to the alterations implemented in the privacy policy in due course and without notice.

    

2. You must ensure that any personal information and/or Identification Documents submitted by you to the organization as a part of KYC should belong solely to you. Fabrication of documents or misappropriated information/identity so furnished shall lead to a suitable course of action against you on being diagnosed on forgery grounds.

    

3. A fresh proof of address or identity should be submitted at the latest within 6 months of any alteration being done to your original documentation with the proper government-approved affidavit of a declaration by you to the concerned department of the organization in support of the changes requested at your end. Non-submission of the same may lead to suspended services if diagnosed and indemnified as an offence under AML Policy.

    

4. In case you are acting on behalf of a juridical person, you must identify the Beneficial Owner and also assist in the verification of the identity of such Beneficial Owner and any individual who acts on behalf of such juridical person.

5. PURPOSE OF THIS POLICY

To safeguard the interest of the user and to minimize the risk of money laundering and other related illegal offences, the company intends to implement this AML policy, which comprises the following elements: –

1. Customer Acceptance Terms; and
2. Risk Management Procedure; and
3. Customer Verification Procedure; and
4.Transaction Monitoring Terms

6. CUSTOMER ACCEPTANCE TERMS

The organization may, either at the time of subscribing to the services or undertaking any transactions or during Periodic updates (with or without prior notice) or for any other reasons, ensure your compliance by following a KYC procedure as mentioned below: –

1. We need you to follow a KYC verification process during the activation process of your subscribed services by submitting your Identification Documents, Correspondence Address Proof, and Personal Information, as mandated under the Customer Verification Procedure of this AML Policy.

    

2. You are required to furnish the details as may be deemed procedurally necessary by the company to verify your identity, such that the company has reason to believe that you are a person or entity enlisted in the Sanctions Lists.

    

3. You are required to submit additional dates, information, and documents supporting the furnished information as per the directives of a regulatory body or law enforcement authority. We require you to certify that your Linked Bank Account is held only with a scheduled commercial bank and is compliant with all Know Your Customer (KYC) procedures mandated under the applicable laws. The company is the sole discretionary authority to refuse to grant the new subscription request, suspend or terminate the existing subscription with prior or momentary notice or refuse to process any transactions on the Authorized Online Platforms if it is unable to ensure compliance with any of the aforesaid conditions, either due to non-cooperation by the user to follow the mentioned KYC Procedural Norms or due to the details provided by the user being found enlisted on any Sanctions Lists or unreliable or unverifiable to the company’s satisfaction.

7. RISK PROFILING PROCEDURE

The company, as per the grading system of risk analysis and management, classifies the incoming users (both new and existing into the categories of Low, Medium and High Risk as per the below-mentioned parameters or limitations: –

1. Accuracy and Adequacy of verifiable identification information furnished by the user under KYC norms.
2. The socio-economic status of the user.
3. Nature of occupation of the user
4. Risk management guidelines notified by a regulatory body or law enforcement bodies (governmental or federal). You comprehend and acknowledge that to sustain the procedural integrity and coherence of risk management; the company is bound to keep your risk categorization data on a highly confidential note and henceforth abided by the law to follow non-disclosure of the same in your favour on seeking the information related to your risk categorization or grading policies. However, in case of any suspicious transaction that has already occurred or in the presence of occurring in the future, the company may have to disclose the user’s risk categorization data, source, document, or categorized information to the competent law enforcement body as deemed fit based on the circumstantial issue.

8. CUSTOMER VERIFICATION PROCEDURE

The company has a mandatory protocol to seek user details for the verification purposes of user identity at the time of New Subscription to the services, at the time of conducting any transaction or at the time of periodic updates for whatever reason, and by subscribing to the services the user expresses consent to abide the KYC procedure. The identification details so sought in different cases are as mentioned below:

1. In Case of Individuals–An Identification Document having the user’s identity and correspondence address details; one recent photograph; any other documents demonstrating the business/financial status of such individual as pre-requested by the company periodically or situationally.

    

2. In Case of Companies– A national official/governmental company search extract equivalent; Certificate of Incorporation; Memorandum and Articles of Association; Board resolution authorizing the transaction the Online Platform; Identification Documents containing identification and address details of the individual authorized to transact along with a copy of such authorization document;

    

3. In Case of Partnership Firm/Limited Liability Partnership–A national official/governmental company search extract equivalent; Registration/Incorporation Certificate; partnership deed; Identification Documents containing identification and address details of the individual authorized to transact along with a copy of such authorization document; For the verification of any User’s identity, the company may hire a licensed third-party service provider to testify the authenticity of the Identification Documents and other incidental details provided by the user. If the company finds any information so furnished by the user inadequate, insufficient, or enlisted on the Sanctions Lists to the procedural protocol described under this clause, then the company may, in its sole honorary discretion, either refuse, suspend or terminate(as deemed fit circumstantially) the registration of such User’s Subscription Account or require the KYC procedural protocol to be reconducted. Users must ensure that all copies of aforesaid Identification Documents are duly certified.

9. TRANSACTION MONITORING TERMS

1. All executed and attempted financial transactions on our Online Platforms are regular vigilance of the concerned company officials, both manually and through the use of software-based algorithms, to promptly diagnose and highlight certain kinds of transactions, including, without limitation, the following kinds of transactions:

   A.

   High-value transactions of amounts greater than USD 5,000 or its equivalent in any other currency;

    

   B. Cross-border transactions of amounts greater than 10,000 USD or its equivalent in any other currency; and

    

2. The company may periodically undertake necessary internal audits to identify and examine transactions inconsistent with any User’s risk profile determined in accordance with Risk Management Procedure, sophistication, and expected usage pattern.

    

3. The extent of monitoring shall depend on various factors, including each user’s risk profile.

    

4. The Company reserves the right to terminate the User subscription, restrict or prevent access to Online Platforms, or report to the appropriate enforcement authorities the activities of any User in respect of transactions identified as suspicious concerning our monitoring policies. Maintenance of records: the company will, as a documental protocol, maintain and preserve the following information, source record, and/or data

a: records of all the transactions executed or attempted to be executed for at least 2 years from the date of each transaction

b: records of all the transactions which are identified on suspicion or high-risk grounds for at least 3 years, including but not limited to the information about natural capital value parties involved in such transactions and their date of remittance

c: identification records of the user (including but not limited to the user’s identification document submitted by the pursuant as per the KYC procedural norms during the subsistence of and for at least three years from the date of termination/refusal/revoke/or suspension of any such user account/subscription

COMPLIANCE, DISCLOSURE, AND NOTICES

The company may periodically share the information related to the transactions identified as risky or suspicious under transaction monetary terms identification information of such users or any other mandate information as applicable by law with appropriate enforcement authorities and/or regularity bodies under consent. In order to improve the integrity and coherence of transactions on our online platform, you are encouraged/advised to report any suspicious information you are privy to or become privy to in the future regarding any suspicious transactions you may find or have areas to believe it dubious Nature of occurrence to our compliance team by writing to us on team@carlosandcompany.com To ensure agreement and compliance with the AML policy the company may from time to time require to send you notices, policy amendments, source documents or any relevant information on the correspondence address and electronic mail so provided by you concerning the KYC procedural norms of the AML policy you in return are required to share any information so requested by the company under the procedures enlisted in the AML policy and communication of  such sort can be done only on electronic medium at info@carlosandcompany.com