Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) Policy

MCX Limited
Address: The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Santa Lucia
Website: www.gamiumexchange.com

1. Introduction

MCX Limited (“the Company”) is fully committed to complying with international best practices and applicable laws regarding Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF).

This policy outlines the principles, internal controls, and procedures implemented to prevent the Company’s services from being used for criminal activities, in accordance with internationally recognized standards and the recommendations of the Financial Action Task Force (FATF).

2. Objectives

The objectives of this AML/CTF Policy are to:

• Prevent the use of MCX Limited’s services for money laundering or terrorist financing.
  
  

• Ensure proper identification and verification of customers and beneficial owners.
  
  

• Detect and report suspicious transactions to the relevant authorities.
  
  

• Maintain accurate and complete records as required by law.
  
  

• Provide ongoing training to staff regarding AML/CTF obligations.

3. Key Definitions

Money Laundering

The process of transforming proceeds from illegal activities into seemingly legitimate assets. It generally consists of three stages:

• Placement: introducing illicit funds into the financial or commercial system.
  
  

• Layering: conducting multiple transactions to obscure the origin of the funds.
  
  

• Integration: reintroducing funds back into the economy as apparently legitimate.
  
  
  

Terrorist Financing

The provision, collection, or transfer of funds intended to support terrorist activities—regardless of whether the funds originate from legal or illegal sources.

4. Risk-Based Approach (RBA)

MCX Limited applies a Risk-Based Approach in line with FATF standards:

• Assessing each customer’s risk profile prior to establishing a business relationship.
  
  

• Assigning risk levels: low, medium, high.
  
  

• Applying due diligence measures proportionate to the assessed risk.
  
  

• Conducting Enhanced Due Diligence (EDD) for higher-risk customers and jurisdictions.
  
  
  

High-risk jurisdictions include those identified by FATF or relevant authorities as having inadequate AML/CTF controls.

5. Role of the MLRO

The Company appoints a Money Laundering Reporting Officer (MLRO) (name withheld by Company policy).

Responsibilities include:

• Overseeing implementation of the AML/CTF policy.
  
  

• Reviewing and approving customer due diligence procedures.
  
  

• Assessing and investigating suspicious activities.
  
  

• Filing Suspicious Transaction Reports (STRs) with competent regulatory authorities.
  
  

• Coordinating internal and external AML/CTF audits.
  
  

• Organizing staff training and maintaining training records.

6. Customer Due Diligence (CDD/KYC)

6.1 Individual Customers

The Company collects and verifies:

• Full legal name
  
  

• Date of birth
  
  

• Nationality and country of residence
  
  

• Residential address
  
  

• Valid, unexpired identification document (passport, national ID, or driver’s licence)
  
  

• Proof of address (utility bill, bank statement, etc.) not older than 3 months
  
  
  

6.2 Corporate Customers

Required documentation includes:

• Certificate of Incorporation
  
  

• Memorandum & Articles of Association
  
  

• Certificate of Good Standing or proof of registered address
  
  

• Board Resolution authorizing account opening
  
  

• Powers of attorney or similar authorizations
  
  
  

Identification of:

• Directors
  
  

• Authorized signatories
  
  

• Ultimate Beneficial Owners (UBOs)
  
  
  

6.3 Enhanced Due Diligence (EDD)

EDD is applied when:

• Customers are from high-risk jurisdictions
  
  

• Customers are Politically Exposed Persons (PEPs)
  
  

• Transactions are complex, unusual, or inconsistent
  
  

• Corporate structures are opaque or involve multiple layers
  
  

EDD may involve additional documentation and approval from senior management and the MLRO.

7. Ongoing Monitoring & Detection of Suspicious Activities

MCX Limited continuously monitors customer activity through:

• Automated systems
  
  

• Manual review where necessary
  
  
  

A transaction is considered suspicious when it:

• Does not match the customer’s declared profile or source of funds
  
  

• Lacks a clear economic or legal purpose
  
  

• Involves patterns associated with layering
  
  

• Shows unusual size, frequency, or complexity
  
  
  

The MLRO reviews and documents all alerts and determines whether an STR must be filed.

8. No-Cash Policy

MCX Limited does not accept or disburse cash under any circumstances.
All transactions must be conducted through traceable electronic methods.

9. Record Keeping

The Company maintains:

• Customer identification records
  
  

• Transaction records
  
  

• Internal AML/CTF reports
  
  

• Suspicious Activity Reports (SARs) and supporting documentation
  
  
  

Records are retained for at least 7 years from the end of the business relationship or date of transaction.

10. Staff Training

Employees receive periodic training covering:

• AML/CTF legal obligations
  
  

• Recognition of red flags and suspicious indicators
  
  

• Internal reporting procedures
  
  

• Individual accountability and compliance requirements
  
  
  

Training is provided at least annually and whenever regulatory changes occur.

11. Reporting Suspicious Transactions

If suspicious activity is identified:

1. Staff must report internally to the MLRO immediately.
   
   

2. The MLRO conducts a documented investigation.
   
   

3. If required, an official STR is filed with the competent authority.
   
   

4. Staff must not inform the customer (anti-tipping-off requirement).

12. Internal Measures & Corrective Actions

MCX Limited reserves the right to:

• Request additional information or documentation
  
  

• Suspend transactions
  
  

• Temporarily freeze an account
  
  

• Terminate the business relationship
  
  
  

These actions may be taken when suspicious behaviour is detected or when AML/KYC requirements are not fulfilled.

13. Confidentiality & Data Protection

All AML/CTF information is treated as strictly confidential.
It is used exclusively for compliance purposes and protected under applicable data-protection standards.

14. Policy Review

This AML/CTF Policy is reviewed at least annually or when significant regulatory changes occur, ensuring continued compliance and effectiveness.