KYC / AML Policy

Introduction

Gainlit Markets Ltd ("Gainlit Markets") is committed to the highest standards of compliance against money laundering (AML) and anti-terrorist financing (CTF).

The objective of the Company's policy against money laundering and terrorism financing is to actively prevent the risks of these matters. We have an obligation to report suspicious client activity relevant to money laundering.

Money Laundering: the process of converting funds received from illegal activities (such as fraud, corruption or terrorism) into other funds or investments that appear legitimate, in order to hide or distort the actual source of funds.

The Money Laundering Process — Three Stages

Placement

At this stage, the funds are turned into financial instruments such as cheques, bank accounts and money transfers, or they can be used to buy high-value goods that can be resold. To avoid suspicion, deposits can also be split into several smaller deposits instead of depositing the entire sum at once — this form of placement is called smurfing.

Layering

The funds are transferred or moved to other accounts and other financial instruments. This is done to disguise the origin and interrupt the indication of the entity that carried out the multiple financial transactions. Moving funds and changing their form makes it difficult to track the money that is being laundered.

Integration

The funds are re-circulated as legitimate to purchase goods and services.

Gainlit Markets Ltd adheres to the principles of anti-money laundering and actively prevents any action that targets or facilitates the legalisation process of illegally obtained funds. To prevent money laundering, the Company does not accept or pay in cash under any circumstances.

How the AML Policy Is Met

• Know your client's policy and due diligence
• Monitor customer activity
• Registry maintenance

Know Your Customer

Due to the Company's commitment to AML and KYC policies, each customer must complete a verification procedure. Before we initiate any cooperation with a client, we ensure that satisfactory evidence is presented, or other measures are taken, that produce satisfactory proof of the identity of any client or counterparty.

The Company also applies increased scrutiny to clients who are residents of countries identified by credible sources as having inadequate AML standards or as posing a high risk of crime and corruption.

Individual Clients

During the registration process, each client provides personal information, specifically: full name; date of birth; country of origin; and full residential address.

The following documents are required to verify personal information (where documents are written in non-Latin characters, a notarised English translation is required to avoid delays):

• Valid passport (showing the first page of the local or international passport, where the photo and signature are clearly visible); or
• Driving licence with photograph; or
• National identity card (showing the front and back);
• Documents proving the current permanent address (such as utility bills or bank statements) containing the customer's full name and place of residence.

These documents should not be older than 3 months from the filing date.

Corporate Clients

Where the applicant company is listed on a recognised or approved stock exchange, or where there is independent evidence that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps will normally be taken to verify the identity.

Where the company is not listed and none of the main directors or shareholders already holds an account with us, the following documentation must be provided:

• Certificate of incorporation or any national equivalent;
• Memorandum and Articles of Association and statutory declaration or any national equivalent;
• Certificate of good standing or other proof of the company's registered address;
• Resolution of the board of directors to open an account and grant authority to those who will operate it;
• Copies of powers of attorney or other authorities granted by the directors in relation to the company;
• Proof of the identity of the directors and of the final beneficiary(ies), in accordance with the individual identity-verification rules described above.

Tracking Customer Activity

In addition to collecting customer information, the Company continues to monitor the activity of each customer to identify and prevent any suspicious transactions. A suspicious transaction is one that is not consistent with the legitimate business of the customer or with the transaction history of the customer. We have implemented a transaction-monitoring system (both automatic and, if necessary, manual) to prevent criminals from using the Company's services.

Registry Maintenance

Records are kept of all transaction data and data obtained for identification purposes, as well as all documents related to money-laundering issues (such as suspicious-activity reporting files and AML account-monitoring documentation). Those records are kept for a minimum of 7 years after the account is closed.

Measures Taken

In cases of an attempt to execute transactions that the Company suspects are related to money laundering or other criminal activity, it will proceed in accordance with applicable law and report the suspicious activity to the relevant authority. The Company reserves the right to suspend the operation of any client that may be considered illegal or related to money laundering, and has full discretion to temporarily block a suspicious customer's account or terminate a relationship with an existing customer.

Contact Information

For more information you can contact us at [email protected].