AML Policy

1. Company Commitment

Volnex Capital Ltd, a financial services provider registered in St. Lucia, is fully committed to combating money laundering, terrorism financing, and other illicit financial activities. This AML/CTF Policy has been designed in accordance with the Financial Action Task Force (FATF) Recommendations, relevant St. Lucian AML regulations, and applicable international standards.

Volnex offers online trading services in forex, cryptocurrencies, commodities, and indices to individual clients primarily based in the United Arab Emirates (UAE) and India. The company maintains a strong culture of compliance and financial integrity.

2. What Is Money Laundering?

Money laundering is the process of disguising the origins of illegally obtained funds to make them appear legitimate. It typically consists of the following three stages:

• Placement: Introduction of illicit funds into the financial system.
• Layering: Concealing the source through complex transactions and transfers.
• Integration: Reintroducing laundered money into the legitimate economy.

Terrorist financing involves providing funds for terrorist activities from either legal or illegal sources. Volnex strictly prohibits and actively monitors to prevent both.

3. Governance Structure

Volnex has appointed a qualified Compliance Officer based in St. Lucia to oversee all AML/CTF obligations. This officer:

• Reports directly to senior management and the Board of Directors.
• Coordinates with internal risk teams and external legal/compliance advisors.
• Ensures regulatory compliance and oversees STR submissions.

Compliance Audits:

• Internal: Quarterly compliance reviews.
• External: Annual independent assessments using certified AML tools and frameworks (e.g., Shufti Pro, ISO/IEC 27001 standards).

4. Know Your Customer (KYC) and Customer Due Diligence (CDD)

Volnex implements a strict KYC process before activating any trading account. Identity verification is conducted via Shufti Pro, a globally recognized identity verification provider.

Accepted KYC Documents (for Individual Clients):

• Valid passport, national ID, or driver's license
• Proof of address (utility bill or bank statement, not older than 90 days)

Requirements:

• All clients must provide Proof of Identity (POI) and Proof of Address (POA)
• Non-Latin script documents must be officially translated into English and notarized

Ongoing Due Diligence is conducted regularly based on customer risk classification.

5. Risk-Based Approach

Volnex follows a Risk-Based Approach (RBA) to identify, assess, and mitigate risks associated with clients and transactions.

Client Classification:

• Low Risk: UAE/India-based clients with verified documentation and consistent activity
• High Risk: Clients with mismatched details, adverse media, or PEP status

Enhanced Due Diligence (EDD) is triggered if:

• Client appears in AML/CTF databases or sanction lists
• Transactions show suspicious or inconsistent behavior
• The client is classified as a Politically Exposed Person (PEP)

6. Sanctions & Watchlist Screening

All clients are screened against global watchlists and sanctions databases at onboarding and on an ongoing basis. These include:

• FATF High-Risk and Non-Cooperative Jurisdictions
• OFAC (US)
• UN Security Council Sanctions
• EU Sanctions Lists
• UAE Central Bank & National Security Council

If a positive match is found, the account is immediately escalated for review and possible suspension.

7. Transaction Monitoring

Volnex deploys a combination of automated and manual monitoring systems to detect unusual or suspicious behavior.

• Real-time alerts for abnormal transaction patterns
• Transaction profiling compared with customer risk
• Automated escalation to compliance for Suspicious Transaction Report (STR) review

All alerts are documented and reviewed by the Compliance Officer.

8. Deposit & Withdrawal Requirements

To mitigate financial crime and fraud, Volnex enforces the following strict payment policies:

• No third-party deposits or withdrawals
• Only accounts under the same name as the Volnex account holder are allowed
• Withdrawals follow a First-In-First-Out (FIFO) method, based on original funding source
• First-time withdrawals require submission of a recent bank statement

Accepted Payment Channels:

• Cregis (regulated crypto gateway)
• Indian UPI / Local Bank Transfers
• USDT (TRC-20 network)

9. Record Keeping & Data Protection

Volnex retains all AML-related records and customer data for a minimum of seven (7) years in compliance with local and international regulations.

• Data is encrypted and securely stored
• Access is limited to authorized compliance personnel only
• Records are available for audit, investigation, and regulatory inspections
• Compliance with relevant data protection laws of St. Lucia, India, and UAE

10. Employee Training & Awareness

Volnex promotes an AML-aware culture through continuous training and awareness programs:

• Quarterly AML/CTF training provided via Shufti Pro compliance modules
• New employees receive AML training within 30 days of joining

Training topics include:

• Red flag indicators
• KYC verification steps
• STR filing process
• Regulatory obligations

All training sessions are documented and reviewed periodically.

11. Suspicious Transaction Reporting (STR)

Employees are required to report any suspicious activity immediately to the Compliance Officer.

• All internal STRs are reviewed and investigated within 24 hours
• Verified STRs are filed with the St. Lucia Financial Intelligence Authority (FIA)
• Affected accounts may be frozen, restricted, or terminated
• Full cooperation is extended to authorities during investigations

12. Policy Review

This AML/CTF Policy is reviewed annually, or upon any material change in:

• Local or international AML regulations
• Company structure or business model
• Third-party compliance technology

Review Process:

• Led by the Compliance Officer
• Reviewed by executive management
• Communicated to all relevant staff and documented internally