(AML) Policy for ZEX Markets.

1. Scope of Policy
This Anti-Money Laundering (AML) policy applies to all officers, employees, appointed producers, and the products and services offered by ZEX Markets. It is applicable to all business units and locations within ZEX Markets, ensuring a cohesive approach to combating money laundering and terrorist financing activities.

2. Objectives
– To prevent the use of ZEX Markets for money laundering activities.
– To comply with all applicable AML laws and regulations.
– To detect and report suspicious activities promptly.
– To maintain a robust AML program that includes effective internal controls, procedures, and staff training.

3. AML Compliance Committee Responsibilities
The AML Compliance Committee is tasked with ensuring the effectiveness of the AML policy. The committee’s responsibilities include:
– Receiving and evaluating internal reports of suspected money laundering.
– Investigating and documenting suspicious events.
– Reporting relevant suspicious activities to the appropriate authorities.
– Ensuring staff and advisor awareness through regular training programs.
– Providing annual reports to the company’s governing body on the effectiveness of AML systems and controls.
– Overseeing the development of new products, customer onboarding, and changes in the company’s business profile to ensure compliance with AML policies.

4. Policy Statement
ZEX Markets is committed to preventing money laundering and the financing of terrorism. All officers, employees, and appointed producers must adhere to this policy to prevent the misuse of ZEX Markets’ products and services.

5. Definition of Money Laundering
Money laundering involves disguising the origins of illegally obtained funds to make them appear legitimate. It can involve the transfer of criminal proceeds into “clean” money or assets. Money laundering activities can include:
– Placement: Introducing illegal profits into the financial system.
– Layering: Concealing the source of the funds through complex transactions.
– Integration: Reintroducing the laundered money into the economy as legitimate funds.

6. Counter-Terrorist Financing (CTF)
CTF refers to measures taken to prevent and combat the funding of terrorist activities. ZEX Markets is committed to ensuring that it does not facilitate terrorist financing and that its customers are not involved in such activities.

7. Risk-Based Approach
ZEX Markets adopts a risk-based approach to AML, focusing resources where the risk is greatest. The approach includes:
– Customer Risk: Assessing the risk profile of each customer and adjusting due diligence measures accordingly.
– Product Risk: Evaluating the risk associated with the products and services offered.
– Country Risk: Considering the geographical location and origin of business activities.

8. Customer Identification Program (CIP)
The CIP is designed to verify the identity of customers. ZEX Markets will:
– Collect and verify customer identification information as required by law.
– Notify customers of the need for identification information.
– Maintain records of the information used to verify identity.

9. Know Your Customer (KYC)
ZEX Markets employs KYC procedures to understand the nature of the customer’s business and the expected pattern of transactions. This includes:
– Obtaining information on the customer’s business and transaction activities.
– Monitoring ongoing business relationships to ensure they align with the customer’s profile.
– Investigating any unexplained or suspicious activity.

10. Source of Funds
ZEX Markets ensures that the source of funds for each transaction is legitimate. This involves:
– Identifying the origin of the funds.
– Recording the source of funds information.
– Conducting additional due diligence if necessary.

11. Reporting Suspicious Activity
ZEX Markets maintains vigilance for suspicious activities. If a suspicious activity or red flag is detected:
– Additional due diligence will be conducted.
– The activity will be reported to the AML Compliance Committee.
– A Suspicious Activity Report (SAR) may be filed with the appropriate authorities.

12. Investigation
Upon receiving a report of suspicious activity:
– The AML Compliance Committee will initiate an investigation.
– Results of the investigation will be documented and kept confidential.
– Relevant information will be reported to law enforcement or regulatory agencies as required.

13. Freezing of Accounts
ZEX Markets will freeze accounts known to derive from criminal activities. Accounts may also be frozen if the account holder is suspected of being involved in fraudulent activities.

14. Training and Awareness
ZEX Markets provides regular AML training to all relevant employees. Training includes:
– Understanding money laundering and terrorist financing risks.
– Recognizing red flags and suspicious activities.
– Procedures for reporting suspicious activities.

15. Record Keeping
ZEX Markets maintains records of:
– Customer identification information.
– Transactions and due diligence activities.
– Reports of suspicious activities.
Records are kept for a minimum of five years or as required by law.

16. Compliance and Review
The AML Compliance Committee will regularly review and update the AML policy to ensure its effectiveness. Compliance with this policy is mandatory, and failure to adhere to it may result in disciplinary action.

ZEX Markets is committed to upholding the highest standards of integrity and compliance to combat money laundering and terrorist financing effectively.