AML / KYC Policy (draft) | SFB Market
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Legal

AML / KYC Policy

Our obligations to verify clients and prevent financial crime, in plain language.

Version 0.1 · Draft for legal review · Last updated [DATE]

This is a working draft prepared for review by SFB Market's legal counsel and the compliance officer. It is not yet in force and must not be relied on by clients.

1. Purpose

SFB Market Ltd is required by [REGULATOR] and the [AML Act] of [COUNTRY] to prevent money laundering, terrorist financing and sanctions breaches. This policy explains what that means for you.

2. Verification before trading

  • Identity: a valid passport or national ID, plus a live selfie.
  • Address: a utility bill, bank statement or government letter dated within 3 months.
  • Source of funds: requested for deposits above [USD X,XXX] cumulative, or where the pattern of deposits warrants it.

3. Ongoing monitoring

We screen all clients against sanctions and PEP lists at onboarding and continuously, and monitor transactions for unusual patterns. We may ask for further documents at any time; trading or withdrawals may be paused until they are received.

4. Deposits and withdrawals

  • Funds are accepted only from accounts and wallets in your own name.
  • Withdrawals are returned to the original funding source up to the amount deposited, before any other method is used.
  • Third-party payments are refused and returned.

5. Restricted jurisdictions

We do not onboard residents of the jurisdictions listed in Schedule A of the Client Agreement, nor anyone subject to UN, EU, UK or US sanctions.

6. Reporting

Where the law requires, we report suspicious activity to the [Financial Intelligence Unit] and may be prohibited from informing you.

7. Record keeping

Verification and transaction records are retained for at least [7] years after the relationship ends.

8. Training and oversight

All staff receive AML training annually. The Compliance Officer ([NAME]) is responsible for this policy and reports to the Board.