GrandMarkets
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GrandMarkets / en-US

AML/CTF

I. Introduction

1. Commitment to Compliance

GrandMarkets is firmly committed to combating all forms of money laundering, terrorist financing, and criminal activities. We strictly adhere to the applicable laws and regulatory requirements set forth by the relevant authorities in the Republic of Comoros.

2. Organizational Structure

GrandMarkets has designated a Money Laundering Reporting Officer (“Officer”) along with a dedicated compliance team to implement and oversee our AML/CTF policies and procedures. These measures cover, but are not limited to:

  • Client Due Diligence (CDD) requirements;
  • Record-keeping obligations;
  • Reporting procedures for suspicious activities;
  • Training of staff on AML/CTF policies and systems;
  • Vetting of employees to ensure suitability for performing AML/CTF duties;
  • Clarification of the Officer’s roles and responsibilities;
  • Establishment of an independent audit function to test our AML/CTF systems;
  • Deployment of advanced systems to monitor and address potential money laundering and terrorist financing risks.

3. Policy Modifications

GrandMarkets reserves the right to amend or update this Policy at any time without prior notice. All changes shall be effective immediately upon publication on our website and shall be binding on all clients. Clients are responsible for regularly reviewing the Policy for any updates.

II. Definitions and Interpretation

For the purposes of this Policy, the following definitions apply:

1. Applicable Laws and Regulatory Requirements:

All statutes, regulations, rules, orders, and guidelines issued by the Comoros Financial Services Authority or any other relevant authority, as amended from time to time.

2. GrandMarkets:

GrandMarkets Limited, a licensed securities trader regulated by the Comoros Financial Services Authority (Regulatory Number: L 15998/GML).

3. Politically Exposed Person (PEP):

An individual currently or formerly entrusted with prominent public functions (e.g., head of state, prime minister, ministers, senior government or judicial officials, military officials, senior executives of state-owned enterprises, or international organization officials).

4. Proceeds of Crime:

Property or economic benefits derived, directly or indirectly, from a serious offense, including any subsequent transformations of such property.

5. Terrorist Financing:

The provision, collection, or making available of funds or financial services―directly or indirectly―that are intended or known to be used, in whole or in part, for the commission of terrorist acts.

6. Customer Due Diligence (CDD):

The process by which GrandMarkets verifies the identity of its clients, identifies beneficial owners, verifies the source of funds, and understands the client’s business background before and during the establishment of a business relationship.

7. Simplified Due Diligence (SDD):

A less rigorous set of verification measures applied to low-risk clients while still ensuring a basic level of identity confirmation and information updating.

8. Enhanced Due Diligence (EDD):

A more stringent verification process applied to high-risk clients, requiring additional information, increased monitoring, and senior management approval before establishing or continuing a business relationship.

9. Reporting Officer:

The designated person within GrandMarkets responsible for collecting, assessing, and reporting any suspicious transactions or activities.

10. Suspicious Activity Report (SAR):

A report submitted by GrandMarkets to the relevant regulatory authorities when there is reasonable suspicion of money laundering, terrorist financing, or other criminal activities.

III. Policy Execution

1. Implementation

GrandMarkets implements this Policy across all its business activities. The Officer and the compliance team are tasked with ensuring that all internal procedures and controls align with this Policy and are updated in line with new risks or regulatory changes.

2. Risk-Based Approach

GrandMarkets adopts a risk-based approach in the detection and management of money laundering and terrorist financing risks. The system is regularly reviewed and updated to address emerging risks, new products, business practices, and technological developments.

IV. Customer Due Diligence (CDD)

1. Pre-Establishment of Relationship

Before establishing a business relationship, GrandMarkets will conduct comprehensive CDD, including verifying the client’s full name, date of birth, residential address, occupation, nationality, and the source of funds and wealth.

2. For Corporate Clients

For corporate entities, GrandMarkets will verify registration details, company structure, directors, and beneficial owners.

3. Third-Party Authorization

If a client uses a third-party agent, GrandMarkets reserves the right to require documentation confirming the agent’s authorization to act on the client’s behalf.

4. Insufficient Documentation

Failure to provide authentic and complete CDD documentation may result in GrandMarkets refusing or terminating the business relationship, including freezing or restricting the client’s account.

V. Customer Risk Assessment (CRA)

1. Risk Evaluation

GrandMarkets will assess each client’s risk profile by evaluating factors such as transaction volume, business nature, geographic risks, the purpose of the account, and the level of assets involved.

2. High-Risk Criteria

Clients will be deemed high risk if they:

  • Conduct large cash transactions or complex high-value transactions that are difficult to verify;
  • Execute single large transactions or multiple rapid transactions;
  • Are based in or operate through high-risk jurisdictions;
  • Qualify as Politically Exposed Persons (PEPs);
  • Have unclear or unverifiable sources of funds;
  • Employ overly complex structures to evade regulatory scrutiny.

3. Right to Refuse

GrandMarkets reserves the right to refuse or discontinue business with high-risk clients if their risk cannot be adequately mitigated.

VI. Simplified Due Diligence (SDD)

1. Application to Low-Risk Clients

For clients with low money laundering and terrorist financing risks, GrandMarkets may apply a simplified due diligence process that ensures basic identity verification and periodic updating of client information.

2. Ongoing Monitoring

Even under SDD, GrandMarkets reserves the right to conduct additional due diligence or transition to enhanced measures if risk circumstances change.

VII. Enhanced Due Diligence (EDD)

1. Application to High-Risk Clients

For high-risk clients, GrandMarkets will implement EDD measures that include:

  • Collecting extensive information regarding the source of funds, source of wealth, and business operations;
  • Conducting in-depth verification of beneficial owners and cross-checking against independent sources;
  • Increasing the frequency of client reviews and requiring periodic updates of relevant documents;
  • Mandating that initial payments be conducted via a bank account in the client’s name;
  • Monitoring transactions for patterns aimed at circumventing regulatory thresholds.

2. Immediate Action on Suspicion

If there is any indication of money laundering, terrorist financing, or other serious offenses, GrandMarkets may immediately terminate the business relationship and report the matter to the appropriate regulatory authorities.

VIII. Verification Measures

1. Methods of Verification

GrandMarkets will use multiple verification methods including document verification, electronic checks, face-to-face interviews, and third-party independent confirmations.

2. Additional Information

If information provided by the client is insufficient or questionable, GrandMarkets reserves the right to request additional documents or information, and may restrict or terminate the business relationship if the required information is not provided.

3. Remote Verification

For remote or electronic onboarding, additional checks (e.g., requiring the first payment through a client-named bank account) will be implemented to mitigate the risk of identity fraud.

IX. Reporting, Record Keeping, and Information Retention

1. Suspicious Activity Reporting

GrandMarkets requires that any suspicious transactions or unusual activities be reported internally to the Officer promptly (typically within 2 working days). The Officer will investigate and, if necessary, submit a Suspicious Activity Report (SAR) to the relevant regulatory authorities.

2. Record Keeping

All documents related to client identification, CDD, transaction records, and SARs shall be maintained securely for a minimum of 7 years following the termination of the business relationship.

3. Confidentiality of Reports

Reports submitted to regulatory authorities are essential for compliance and are protected under law. GrandMarkets shall not be held liable for any consequences arising from such reporting.

X. Internal Audit and Training

1. Internal Audit

GrandMarkets will conduct an annual internal audit of its AML/CTF policies, procedures, and systems to ensure they meet current regulatory standards and effectively manage emerging risks.

2. Training Program

All relevant employees will receive regular AML/CTF training covering:

  • Applicable laws and regulatory obligations;
  • Client due diligence and record-keeping procedures;
  • Identification and reporting of suspicious activities;
  • Prevention of “tipping-off” and maintaining confidentiality;
  • Internal escalation and reporting protocols.

Focused training will also be provided to front-line, back-office, managerial staff, and the Officer to ensure comprehensive understanding of AML/CTF responsibilities.

3. Monitoring Training Effectiveness

The effectiveness of the training programs will be regularly evaluated through testing, monitoring compliance, and ensuring that any gaps are addressed promptly.

XI. Language and Amendments

1. Official Language

The official language of this AML/CTF Policy is English. Any translations provided are for informational purposes only; in case of discrepancies, the English version shall prevail.

2. Right to Amend

GrandMarkets reserves the right to modify, update, or supplement this Policy at any time without prior notice. All amendments become effective immediately upon publication on the GrandMarkets website and are binding on all clients. Clients are responsible for regularly reviewing the Policy.

XII. Final Interpretation

1. Interpretation and Priority

All terms, interpretations, and revisions of this Policy shall be construed in a manner that preserves and protects the legal rights and interests of GrandMarkets.

2. Final Authority

GrandMarkets retains the final right of interpretation of this AML/CTF Policy.

Disclaimer:

This AML/CTF Policy does not constitute operational or investment advice. Clients are advised to fully understand and accept the risks associated with money laundering and terrorist financing. GrandMarkets shall not be liable for any losses arising from non-compliance with this Policy, Force Majeure, system failures, or other factors beyond its reasonable control.