AML & KYC Policy

Ark Stone Trading is committed to maintaining the highest standards of Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance. This comprehensive policy establishes our framework for identifying, assessing, and mitigating financial crime risks, including money laundering, terrorist financing, and sanctions violations.

Our AML/KYC program is designed to comply with all applicable international standards, including the Financial Action Task Force (FATF) recommendations, and the regulatory requirements of all jurisdictions in which we operate. We maintain a zero-tolerance approach to financial crime and actively work to prevent our platform from being used for illicit purposes.

All clients must undergo comprehensive KYC verification before gaining access to our trading platform. Our KYC procedures include:

• Identity Verification: Collection and verification of government-issued identification documents, including passports, national ID cards, and driver's licenses.
• Address Verification: Confirmation of residential address through utility bills, bank statements, or official government correspondence.
• Beneficial Ownership Identification: For corporate clients, identification of ultimate beneficial owners and persons with significant control.
• Source of Funds Verification: Documentation and verification of the origin of client funds and wealth.
• Ongoing Due Diligence: Continuous monitoring and periodic re-verification of client information to ensure accuracy and detect changes in risk profile.

We implement a risk-based approach to AML/KYC compliance, tailoring the intensity of our due diligence procedures to the assessed risk level of each client. Our risk assessment considers:

• Client Risk Profile: Assessment of client type, jurisdiction, business activities, and transaction patterns.
• Geographic Risk: Evaluation of jurisdictions associated with higher money laundering or terrorist financing risks.
• Product Risk: Analysis of the inherent risk characteristics of specific trading products and services.
• Transaction Risk: Monitoring of transaction patterns, volumes, and anomalies that may indicate suspicious activity.

High-risk clients are subject to enhanced due diligence (EDD) procedures, including additional documentation, source of funds verification, and more frequent monitoring.

We maintain sophisticated transaction monitoring systems designed to detect suspicious activity and potential financial crime. Our monitoring procedures include:

• Real-Time Monitoring: Continuous analysis of client transactions against established behavioral baselines and risk indicators.
• Suspicious Activity Reporting (SAR): Prompt reporting of suspected money laundering or terrorist financing to relevant financial intelligence units and regulatory authorities.
• Currency Transaction Reporting: Reporting of large cash transactions as required by applicable regulations.
• Threshold Monitoring: Tracking of cumulative transaction volumes and flagging of unusual patterns or sudden changes in client behavior.

We maintain comprehensive sanctions screening procedures to ensure compliance with international sanctions regimes and prevent engagement with sanctioned individuals, entities, and jurisdictions.

• Multi-List Screening: Screening of all clients against multiple international sanctions lists, including OFAC SDN, EU sanctions lists, UN consolidated lists, and other relevant databases.
• Ongoing Screening: Continuous re-screening of existing clients to detect any changes in sanctions status.
• Sanctions Compliance: Strict adherence to all applicable sanctions regulations and immediate blocking of transactions involving sanctioned parties.
• Restricted Jurisdictions: Absolute prohibition of services to clients located in or originating from jurisdictions subject to comprehensive sanctions regimes, retail derivative marketing bans, or unmitigated compliance risks. Please review our official Restricted Jurisdictions Policy for detailed country listings and onboarding rules.

We maintain comprehensive records of all client information, transactions, and compliance activities in accordance with applicable regulatory requirements. Our record-keeping procedures include:

• Client Documentation: Secure retention of all KYC documents, identification records, and beneficial ownership information.
• Transaction Records: Detailed documentation of all client transactions, including transaction details, parties involved, and amounts.
• Compliance Records: Maintenance of all AML/KYC compliance activities, risk assessments, and monitoring reports.
• Retention Period: Records are retained for a minimum of five to seven years following account closure, in accordance with regulatory requirements.

We recognize that effective AML/KYC compliance requires a strong compliance culture throughout our organization. We maintain comprehensive training and awareness programs for all employees:

• Initial Training: All new employees receive mandatory AML/KYC training covering regulatory requirements, company policies, and practical procedures.
• Ongoing Training: Regular refresher training and updates on emerging risks, regulatory changes, and best practices.
• Role-Specific Training: Specialized training for employees in compliance-sensitive roles, including client-facing staff and transaction monitoring personnel.
• Awareness Programs: Continuous communication of compliance expectations and recognition of suspicious activity indicators.

Ark Stone Trading is unequivocally committed to maintaining the highest standards of AML/KYC compliance. Our commitment includes:

• Regulatory Cooperation: Full cooperation with regulatory authorities and financial intelligence units in all investigations and inquiries.
• Continuous Improvement: Regular review and enhancement of our AML/KYC procedures to address emerging risks and regulatory developments.
• Zero Tolerance: Strict enforcement of compliance policies with appropriate disciplinary measures for violations.
• Transparency: Transparent communication with clients regarding our compliance requirements and procedures.

For questions or concerns regarding this AML/KYC Policy, please contact our Compliance Department at compliance@arkstonetradingpartners.com.