AML / KYC Policy

1. Purpose & Scope

2. Legal & Regulatory Framework

• Our AML / KYC operations comply with applicable UK legislation, anti-money laundering directives, and international standards such as those from the Financial Action Task Force (FATF).
• The Company may be required to cooperate with regulatory and law enforcement authorities and provide documentation or information in response to lawful requests.
• This Policy is integral to our User Agreement, and in case of conflict, provisions of this Policy prevail when related to AML / KYC matters.

3. Definitions & Key Terms

• Client / User: Any individual or legal entity registering or using XInvest services.
• Beneficial Owner: The person(s) who ultimately own or control the account, directly or indirectly.
• KYC: Know Your Customer — the process of identifying and verifying clients.
• AML: Anti-Money Laundering — measures to prevent laundering of illicit funds.
• Suspicious Transaction: Any transaction or behavior that raises doubts about its legitimacy or intention.
• Enhanced Due Diligence (EDD): Additional scrutiny applied to higher-risk clients or transactions.

4. Customer Due Diligence (KYC)

4.1 Account Registration & Basic Verification

• A valid government-issued photo identity document (passport, national ID, driver’s license).
• Proof of address (e.g. utility bill, bank statement, dated within the last 3 months).
• A selfie or photograph holding the identity document to confirm identity.

4.2 Enhanced Verification / EDD

• Bank statements / evidence of source of funds
• Tax returns, salary slips, audited financials
• Corporate documentation if the account is under a legal entity
• Additional identity or background checks

5. Transaction Monitoring & Suspicious Activity

• All user accounts and transactions are subject to continuous monitoring using automated systems and manual review.
• Transaction patterns, deposit/withdrawal frequency, volume, and behavior inconsistent with normal usage may trigger flags.
• Suspicious transactions may include:
•   • Large deposits or withdrawals with little or no trading activity
•   • Transfers from or to accounts not in the client’s name
•   • Transactions with no clear economic rationale
•   • Activity from high-risk or sanctioned jurisdictions
•   • Inability or refusal to provide requested documents
• If suspicious activity is detected, the Company may:
•   • Temporarily suspend account operations
•   • Block or freeze funds
•   • Close or restrict accounts
•   • Cancel pending transactions
•   • Request additional documentation or explanations
•   • Report to relevant regulatory or law enforcement entities

6. Non-Trading Transactions, Deposits & Withdrawals

• Deposits and withdrawals must be made via methods registered to the account holder (i.e. bank accounts, cards, e-wallets in the client’s name).
• Third-party funding (funds from accounts not in the client’s name) is prohibited unless approved under special conditions.
• The Company may refuse or reverse transactions suspected of violating this policy.
• Transactions involving currency conversion may incur fees; exchange rates will be determined by the Company.
• Withdrawal requests must comply with legal, KYC, and AML checks before processing.
• The Company may set minimum/maximum deposit or withdrawal amounts per payment method, and may limit withdrawals if suspicious behavior is discovered.

7. Record Keeping & Data Retention

• The Company maintains records of all identity documents, transaction histories, client communications, and AML-related investigations for a minimum period as required by law (often 5–7 years).
• Records are stored securely, with controlled access and encryption to preserve confidentiality.
• These records may be made available to regulatory authorities, auditors, or investigations upon legitimate request.

8. Reporting & Cooperation

• The Company will file Suspicious Activity Reports (SARs) with the appropriate authorities when a transaction or behavior is believed to involve money laundering, terrorist financing, or financial crime.
• Internal escalation processes ensure that compliance and senior management are informed promptly of AML risks.
• Whistleblower protection policies ensure employees or users who report concerns in good faith are protected from retaliation.

9. Risk Assessment & Compliance Review

• The Company conducts ongoing risk assessments, reviewing exposure to various AML risks, including client base, products offered, geography, and transaction types.
• Periodic internal audits, policy reviews, and control testing are carried out to ensure effectiveness and compliance.
• Policies and procedures are updated regularly to reflect changes in laws, regulations, and industry best practices.

10. Client Obligations & Responsibilities

• Provide accurate, complete, and current information at all times
• Respond promptly to requests for additional verification or clarification
• Not use the platform for illegal or fraudulent activity
• Accept that non-compliance may lead to restrictions, account suspension, or termination
• Not dispute or reverse transactions initiated under this Policy without valid reason

11. Consequences of Non-Compliance

• Delays or refusal of deposits/withdrawals
• Freezing or liquidation of positions
• Account suspension or permanent closure
• Loss of bonuses or funds related to suspicious activity
• Legal or regulatory consequences as required by law

12. Updates & Revisions

• This Policy may be updated from time to time. Substantial changes will be communicated to clients.
• Continued use of the platform after changes constitutes acceptance of the updated policy.
• Clients are encouraged to review the policy periodically.