1. Purpose and Scope

Company Information
NTW Markets Ltd. is a premier international brokerage firm specializing in Contracts for Difference (CFDs) and foreign exchange (Forex) trading services for retail and institutional clients globally.

The Company is incorporated in Saint Lucia under Company Registration Number 2025-00138 and maintains its registered office at:

Top Floor, Rodney Court Building
Rodney Village, Rodney Bay
Gros-Islet
Saint Lucia

NTW Markets Ltd. provides access to a broad range of financial instruments, including foreign exchange, commodities, indices, equities, cryptocurrencies, and other CFD products through its online trading platforms.

The Company is committed to maintaining the highest standards of integrity, transparency, anti-money laundering compliance, counter-terrorist financing controls, and financial crime prevention measures. This Anti-Money Laundering & Financial Crime Prevention Policy forms part of NTW Markets Ltd.’s overall compliance framework and applies to all directors, officers, employees, contractors, agents, and clients of the Company.

This policy establishes the framework by which NTW Markets Ltd. (“the Firm”) identifies, assesses, and mitigates the risks of money laundering (ML), terrorist financing (TF), and other forms of financial crime arising from its Forex and Contract for Difference (CFD) brokerage activities.

The Firm is committed to the highest standards of legal and regulatory compliance and requires all staff, officers, and relevant third parties to adhere to this policy.

1.1 Scope

This policy applies to:

• All employees, directors, contractors, and agents of the Firm
• All client-facing and back-office functions, including sales, onboarding, compliance, operations, and technology
• All products and services offered, including spot FX, rolling spot FX, CFDs on equities, indices, commodities, metals, and cryptocurrencies
• All payment channels: bank wire transfer, debit/credit card, and cryptocurrency
• All legal entities within the Firm’s group structure

1.2 Objectives

• Prevent the Firm’s products and infrastructure from being used as a vehicle for money laundering or terrorist financing
• Ensure compliance with applicable AML/CFT laws, regulations, and international standards (FATF Recommendations, UN Conventions)
• Establish clear responsibilities, escalation paths, and reporting obligations
• Protect the Firm’s reputation, licence, and business continuity

2. Governance and Accountability

2.1 Board of Directors

The Board holds ultimate responsibility for the Firm’s AML/CFT programme. The Board shall:

• Approve this policy and any material amendments
• Ensure adequate resources are allocated to compliance and AML functions
• Receive and review an annual AML report from the MLRO
• Foster a culture of compliance at all levels of the organisation

2.2 Money Laundering Reporting Officer (MLRO)

The MLRO is the designated senior individual responsible for day-to-day oversight of the AML programme. Responsibilities include:

• Maintaining and updating this policy
• Receiving and evaluating all internal Suspicious Activity Reports (SARs)
• Filing external SARs / Suspicious Transaction Reports (STRs) with the relevant Financial Intelligence Unit (FIU) where required
• Providing AML training and awareness to staff
• Liaising with regulators, law enforcement, and counterparties on AML matters
• Reporting to the Board on AML programme effectiveness

The MLRO must be sufficiently senior, independent, and resourced. The role must not be combined with a function that creates a conflict of interest (e.g., sales or client acquisition).

2.3 Deputy MLRO

A Deputy MLRO must be designated to act in the MLRO’s absence. The Deputy must be trained to the same standard and have equivalent access to systems and records.

2.4 Compliance Function

The Compliance team supports the MLRO and is responsible for first-line monitoring, KYC file management, transaction monitoring alerts, and staff training coordination.

2.5 All Staff

All staff are required to:

• Complete mandatory AML training upon joining and annually thereafter
• Report suspicious activity or concerns to the MLRO promptly via the internal SAR process
• Never ‘tip off’ a client or third party that a suspicious activity report has been made or that an investigation is underway
• Cooperate fully with internal and external investigations

3. Risk-Based Approach

The Firm adopts a risk-based approach (RBA) to AML/CFT, consistent with FATF Recommendation 1. Controls are calibrated to the level of ML/TF risk posed by clients, products, channels, and geographies.

3.1 Firm-Wide Risk Assessment

The Firm shall maintain a documented Firm-Wide Risk Assessment (FWRA) that evaluates:

• Client risk: residency, nationality, source of wealth, occupation, legal entity type
• Product risk: leverage, anonymity of instruments, speed of fund movement
• Delivery channel risk: online-only onboarding, crypto payment acceptance, introducer relationships
• Geographic risk: exposure to FATF high-risk and monitored jurisdictions, sanctioned countries

The FWRA shall be reviewed at least annually and following material changes to the business, product set, or regulatory environment.

3.2 Client Risk Scoring

Each client shall be assigned a risk rating — Low, Medium, or High — at onboarding and monitored on an ongoing basis. The risk rating determines the level of due diligence applied.

4. Customer Due Diligence (CDD) and Know Your Customer (KYC)

4.1 Standard CDD — All Clients

Before establishing a business relationship or executing any transaction, the Firm shall verify the identity of every client. Standard CDD requires:

For individuals:

• Full legal name (matching government-issued ID)
• Date of birth
• Residential address (proof of address document not older than 3 months)
• Nationality and country of tax residence
• Source of funds declaration and supporting evidence
• Purpose of the trading account

For legal entities (corporate clients):

• Full legal name, registered number, and registered address
• Certificate of incorporation / equivalent constitutional documents
• Identity and verification of all directors
• Identity and verification of all Ultimate Beneficial Owners (UBOs) holding 25% or more
• Proof of the entity’s business and source of funds
• Authorised signatory list and resolution authorising the account

4.2 Simplified CDD

Simplified CDD may be applied only where the Firm has assessed the client as low risk AND the client is subject to equivalent AML regulation (e.g., a regulated institutional counterparty). A documented rationale must be retained.

4.3 Enhanced Due Diligence (EDD)

EDD is mandatory for all High-risk clients, including but not limited to:

• Politically Exposed Persons (PEPs) — current and former — and their close associates and family members
• Clients resident in or connected to FATF high-risk, monitored, or sanctioned jurisdictions
• Clients depositing via cryptocurrency from unhosted/self-hosted wallets
• Clients with complex or unusual ownership structures (trusts, nominees, offshore shells)
• Clients whose source of funds or wealth cannot be readily verified

EDD measures shall include one or more of:

• Senior management approval prior to account activation
• Certification of source of wealth (payslips, tax returns, sale proceeds, audited accounts)
• Adverse media and negative news screening
• Enhanced ongoing transaction monitoring thresholds
• More frequent periodic review (minimum annual)

4.4 Ongoing Monitoring and Periodic Review

CDD is not a one-time event. The Firm shall:

• Monitor client transactions on an ongoing basis to ensure they are consistent with the Firm’s knowledge of the client
• Conduct periodic reviews — at least every 12 months for High-risk clients, 24 months for Medium, 36 months for Low
• Re-verify client information if material changes occur (change of address, corporate restructure, significant change in trading pattern)
• Update risk ratings when new information is obtained

5. Sanctions Screening

The Firm operates a zero-tolerance policy toward sanctions violations. No business relationship or transaction may be established with any individual, entity, vessel, or country subject to applicable financial sanctions.

5.1 Screening Scope

The Firm shall screen all clients, UBOs, directors, introducers, and counterparties against:

• United Nations Security Council (UNSC) consolidated sanctions list
• OFAC (US Office of Foreign Assets Control) SDN and blocked persons lists
• HM Treasury / UK Financial Sanctions list (if UK-nexus)
• EU Consolidated Sanctions list
• Any applicable domestic sanctions regime

5.2 Screening Process

• Screening shall occur at onboarding and at minimum daily thereafter via automated batch matching
• All potential matches shall be reviewed by the Compliance team within 24 hours
• True matches shall result in immediate account freeze and escalation to the MLRO
• The MLRO shall determine whether to report to the relevant authority (e.g., OFAC, OFSI) and freeze or reject the transaction
• False positives shall be documented with a clear rationale for clearing

5.3 Correspondent and Payment Channel Screening

The Firm shall not maintain correspondent relationships with shell banks. Payment processors and acquirers shall be assessed for sanctions exposure as part of third-party due diligence.

6. Transaction Monitoring

The Firm operates a transaction monitoring programme designed to detect patterns of activity consistent with money laundering, terrorist financing, fraud, or market manipulation.

6.1 Monitoring Approach

Transaction monitoring shall be conducted through a combination of:

• Automated rule-based alerts (thresholds, velocity, pattern rules)
• Manual review by the Compliance team
• Periodic behavioural analysis of client portfolios

6.2 Red Flag Indicators — Forex/CFD Context

The following patterns shall trigger escalation to the MLRO for review:

• Deposits immediately withdrawn with minimal or no trading activity (layering indicator)
• Round-trip transactions: deposit in, trade a small number of offsetting positions, withdraw
• Deposits from third parties not in the client’s name
• Multiple small deposits just below reporting thresholds (structuring / smurfing)
• Inconsistency between declared source of funds and actual deposit amounts
• Rapid escalation in deposit volumes without explanation
• Use of multiple unrelated cryptocurrency wallets to fund a single account
• Requests to transfer profits to a different payment method or beneficiary than the one used to deposit
• Trading losses consistently absorbed without complaint (suggesting P&L outcome is irrelevant to the client)
• IP addresses, device IDs, or contact details shared across multiple ostensibly unrelated client accounts

6.3 Alert Handling

• All alerts shall be reviewed and resolved within 5 business days
• The Compliance analyst shall document the investigation and outcome
• Escalations to the MLRO shall occur where suspicion cannot be dispelled
• The MLRO shall decide whether to file an external SAR/STR within the timeframe mandated by local law
• Accounts under active investigation may be restricted or suspended pending resolution

7. Suspicious Activity Reporting

7.1 Internal Reporting

Any member of staff who knows or suspects — or has reasonable grounds to suspect — that a person is engaged in money laundering or terrorist financing must submit an internal SAR to the MLRO promptly and without delay.

Internal SARs shall be submitted via [the Firm’s designated secure reporting channel] and shall include:

• The identity of the person(s) concerned (client, counterparty, colleague)
• The nature of the suspicious activity and the information or evidence on which the suspicion is based
• The date(s) of the relevant activity
• Any other relevant details

7.2 MLRO Review

The MLRO shall review each internal SAR and determine whether:

• There are reasonable grounds to suspect ML/TF — in which case an external SAR/STR shall be filed with the relevant FIU, and
• The transaction or relationship should be suspended pending the outcome of the report

7.3 Tipping Off Prohibition

No person within the Firm — including the MLRO — shall disclose to a client or any third party that:

• A SAR has been or is being made
• An investigation is underway by the Firm, law enforcement, or a regulator

Any question from a client about account restrictions shall be handled using a neutral explanation only (e.g., ‘routine compliance review’). Breaching the tipping-off prohibition is a serious disciplinary and potentially criminal matter.

7.4 Non-Retaliation

No employee shall be subject to any adverse employment consequence for making a good-faith report of suspicious activity, even if the suspicion proves unfounded.

8. Record Keeping

The Firm shall maintain records sufficient to reconstruct individual transactions and to permit the identification of any client, counterparty, or transaction should a regulatory or law enforcement inquiry arise.

8.1 Records to be Retained

Note: Local law may require longer retention periods. The Firm shall apply the longer period where obligations conflict.

8.2 Accessibility

Records shall be stored securely and be retrievable promptly upon request by regulators, law enforcement, or the MLRO. Records shall not be destroyed, altered, or concealed.

9. Training and Awareness

9.1 Mandatory Training

All staff must complete AML training:

• At induction (within 30 days of joining)
• Annually thereafter
• Upon any material change to this policy or applicable law

Training shall cover: the legal and regulatory framework; types of money laundering and terrorist financing; the Firm’s KYC, transaction monitoring, and SAR procedures; the tipping-off prohibition; and personal liability for non-compliance.

9.2 Role-Specific Training

Additional training shall be provided to roles with elevated exposure:

• Onboarding and compliance staff: in-depth CDD, EDD, and PEP procedures
• MLRO and Deputy MLRO: SAR filing, FIU liaison, regulatory engagement
• Senior management and Board: strategic ML/TF risk, governance obligations

9.3 Training Records

Completion records shall be maintained for all training undertaken. The MLRO shall report training completion rates to the Board annually.

10. Third-Party Relationships and Introducers

10.1 Introducers and Referring Agents

Where the Firm receives client introductions from third-party introducers (IBs), the Firm retains full AML/CFT responsibility for all clients introduced to it. The Firm shall:

• Conduct due diligence on the introducer before entering any agreement
• Confirm the introducer is subject to equivalent AML regulation or satisfies the Firm’s own standards
• Not rely on the introducer’s KYC without obtaining a written representation and spot-checking files
• Include AML obligations in all introducer agreements
• Reserve the right to conduct independent CDD on any introduced client

10.2 Payment Processors and Liquidity Providers

Material third-party service providers shall be subject to periodic due diligence reviews assessing their AML programme, regulatory standing, sanctions posture, and reputation.

10.3 Cryptocurrency Counterparties

Where the Firm accepts or sends cryptocurrency, it shall:

• Apply Travel Rule compliance procedures where required by applicable law
• Use blockchain analytics tooling to screen wallet addresses for high-risk flags (darknet exposure, mixer usage, sanctions links)
• Decline transactions from unhosted wallets unless EDD has been completed

11. Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who is or has been entrusted with a prominent public function, including heads of state, senior politicians, senior government and judicial officials, senior military officers, and executives of state-owned enterprises.

11.1 PEP Identification

PEP screening shall be conducted at onboarding and on an ongoing basis for all clients, UBOs, and directors using a recognised commercial PEP database.

11.2 PEP Acceptance

The Firm shall not automatically reject PEPs. Where a client is identified as a PEP:

• EDD shall be applied in full (see Section 4.3)
• Senior management approval is required before the relationship is established or continued
• Source of wealth must be established and corroborated
• The relationship shall be subject to enhanced ongoing monitoring and annual review at minimum

Former PEPs shall be treated as PEPs for a minimum of 12 months following the end of their public function, or longer if risk factors remain elevated.

12. Policy Maintenance and Review

This policy shall be reviewed and updated:

• Annually by the MLRO
• Following any material change in the Firm’s business, products, or geographic footprint
• Following issuance of new AML guidance by FATF or applicable authorities
• Following any internal or external audit finding that identifies a deficiency

All amendments shall be approved by the Board and communicated to all relevant staff within 10 business days of approval.

13. Definitions