Money Laundering is the process of converting funds received from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that appear legitimate to hide or distort the real source of funds. The money laundering process can be divided into three consecutive stages:
Placement: At this stage, funds are converted into financial instruments such as checks, bank accounts, and money transfers or are used for purchasing high-value goods that can be resold. They can also be physically deposited in banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion, launderers may make multiple deposits (smurfing) instead of depositing the whole sum at once.
Layering: Funds are transferred or moved to other accounts and other financial instruments to disguise their origin and disrupt the indication of the entity that made the transactions. This makes tracking the laundered money difficult.
Integration: Funds are returned to circulation as legitimate, often through the purchase of goods and services.
Tradona Markets Ltd ("Company" or "TM") adheres to Anti-Money Laundering (AML) principles and actively prevents any actions aimed at or facilitating the legalization of illegally gained funds. The Company introduced a strict policy on detecting, preventing, and reporting suspicious activities. Moreover, the Company cannot inform clients that law enforcement bodies are investigating their activities.
Company’s Procedures
The Company ensures compliance with AML laws and regulations through:
Know Your Customer (KYC) Policy and Due Diligence
Monitoring of Client Activity
Record Keeping
Know Your Customer and Due Diligence
All clients must complete a verification process before commencing any cooperation with the Company. Enhanced scrutiny applies to clients from high-risk countries or those identified as posing a high risk of crime and corruption.
Individual Clients
Each client must provide the following during registration:
Personal Information: Full name, date and place of birth, residential and business address, phone number, and city code.
Identity Verification: Valid passport, national ID card, driver’s license, or any government-issued identification document containing:
Full name, date of birth, photo, citizenship, issue/expiry date, and holder's signature.
Validity of at least six months from the filing date.
Residential Address Verification: Recent utility bill, bank statement, credit card statement (not older than three months), or tax identification documents. If required, these must be apostilled and certified by a judge, magistrate, notary public, or similar authority.
Corporate Clients
Unquoted companies must provide:
Certificate of Registration/Incorporation.
Memorandum and Articles of Association.
By-Laws and General Information Sheet listing directors/partners and principal stockholders.
Extract from the Commercial Register or equivalent.
Certificate of Good Standing.
KYC documents for directors, shareholders, and beneficial owners (BOs).
Audited financial statements.
Additional business information as required.
Failure to submit the required verification data within a reasonable timeframe will result in account closure.
Monitoring of Client Activities
The Company monitors client activities to identify suspicious transactions inconsistent with their legitimate business or usual transaction history. Monitoring includes both automatic and manual reviews to ensure compliance and prevent the misuse of the Company’s services.
Deposit and Withdrawal Requirements
Deposits and withdrawals must originate from and be sent to the same account under the client’s name.
No deposits or withdrawals to/from third-party accounts are allowed.
Funds credited via multiple payment systems are withdrawn on a pro-rata basis.
Record Keeping
The Company retains:
Documents obtained for customer identification (KYC requirements).
Transaction data and any information related to money laundering.
Documents are kept as per the applicable AML laws/regulations and for specified retention periods.
Employee Responsibilities
This policy applies to all employees managing, monitoring, or controlling customer transactions. Employees must:
Be familiar with AML practices, measures, and procedures.
Apply the determined controls to prevent money laundering.
Independent Audit
The Company’s AML Policy is regularly reviewed for appropriateness, effectiveness, and adequacy by an independent internal audit.
Commitment to Anti-Money Laundering
Tradona Markets Ltd ensures that all business units cooperate to create a cohesive effort against money laundering. By adhering to the outlined AML Policy, the Company fosters a secure and compliant financial environment for all stakeholders.
