AML & KYC Policy
LiquiTrade Limited (the “Company”) has established an Anti‐Money Laundering and Know Your
Customer Policy (hereinafter ‐ the “AML & KYC Policy”), in an attempt to maintain the best compliance
practices in conjunction with applicable laws and regulations relating to anti‐money laundering in all
countries where we operate.
AML & KYC Policy covers the following areas:
Internal Controls
Compliance Officer
Customer Verification Procedures
Monitoring of Transactions
Customer due diligence
AML Program Audit
Internal Controls
We have designed a structured system of internal controls in order to comply with applicable AML &
KYC laws and regulations, some of which are outlined in this Policy including, but not limited to, our
Customer Verification Procedures, filling Suspicious Activity Reports (“SARs”), as well as other
requirements and audits.
Compliance Officer
The Compliance Officer is the person, duly authorized by the Company, whose responsibility is to
develop and enforce the effective implementation of the AML & KYC Policy. The Compliance Officer is
required to report any violations of the AML & KYC procedures and is responsible for collecting and filing
All employees receive a full AML & KYC training, along with a job‐specific guidance. Training is conducted
at least once a month to ensure that trainees are informed and act in compliance with all applicable
laws and regulations. New employees receive relevant training within thirty (30) days of their start date
and before they could perform any compliance related duties. Training program is updated regularly to
reflect current laws and regulations. Compliance Officer maintains the training logbook, which is
available for verification during the annual third party review.
Customer Verification Procedures
The Company establishes its own customer verification procedures within the standards of AML & KYC
frameworks. In order to open an account, customer’s identity and place of residence need to be verified
and checked against sanctions and watch lists, including the Office of Foreign Assets Control (“OFAC”)
and Politically Exposed Persons list (“PEP”). In addition, certain groups of assets are limited to investors
with “qualified” status only. In order to open an account for an individual customer, the following
information needs to be verified:
Email address;
Mobile phone number;
Full name;
Date of birth;
Proof of identity (government identity card, driver’s license, passport);
Proof of residential address (utility bills, bank statement, official government letter); and
Additional information or documentation if requested.
Based on the information collected during the KYC process the Company have a right, at its own
discretion, to restricts or refuse service to a particular client.
Monitoring of Transactions
The Company uses customer transaction monitoring as a risk‐assessment and suspicious activity
detection tool. If a transaction is inconsistent with a customer’s known personal activities or personal
habits, this transaction may be considered suspicious. Data and transaction monitoring tools are used to
identify uncommon patterns of customer’s activity. After review and investigation, it is Compliance
Officer’s decision whether to file a SAR or not.
Once a SAR is filed with a relevant agency, a copy of filing documentation is maintained onsite. SAR filing
is confidential and only the Company’s employees involved in the investigation and reporting process
will be aware of its existence.
All records are retained for eight (8) years and are available upon official request by an authorized
examiner, regulator, or law enforcement agency.
Customer Due Diligence
The Company use risk based approach to select a sample of its clients for an additional verification.
We use proprietary risk assignment algorithms to reflect many aspects of customer characteristics and
behavior, including but not limited to:
account balances;
value and pattern of transactions;
consistency of data provided during customer verification process;
unusual behavior
history of devices and IP addresses used to enter the site;
origin and destination of external transfers
Sample of clients identified as high risk ones and a strata of stochastically selected clients are regulary
submitted for extended due diligence. Such due diligence involves:
verification of identity documents’ validity with issuing authorities
verification of facial similarity of photo and that in the documents
Verification of supporting documents though independent checks
checks of selected data against watchlists
AML Program Audit
The Compliance Officer is responsible for conducting AML & KYC review on periodic basis.
In addition, annual independent test of the AML & KYC procedures is done by a qualified third party. In
order to achieve segregation of duties, the Compliance Officer is not involved in such independent test.