1. INTRODUCTION.

Forex Blend (“Forex Blend” or “the Company”) aims to prohibit, detect, and actively pursue the prevention of money laundering and terrorist financing activities. It is also committed to complying with all related laws, rules, and regulations with full attention without compromising any of the aforementioned illegal activities. The Company's management is committed to complying with Anti-Money Laundering ("AML") and Counter-Terrorism Financing ("CFT") in accordance with applicable laws, and places extremely high importance on disclosing any money laundering schemes and/or terrorist financing activities. Forex Blend also requires its officers, employees, introducing brokers, and affiliated companies to adhere to these standards to prevent the use of the company's products and services for money laundering and terrorist financing activities.

2. PURPOSE.

The purpose of the "AML, CFT, and KYC Policy" ("the Policy") is to provide guidance on Anti-Money Laundering ("AML"), Counter-Terrorism Financing ("CFT"), and Know Your Customer ("KYC"), which the Company follows to achieve full compliance with relevant AML and CTF legislation. This policy applies to all company officers, affiliated companies, as well as the products and services offered by the company. Any employee who does not adhere to these policies and procedures will be subject to severe disciplinary action.

3. LEGAL FRAMEWORK.

The Company is required to comply with the provisions of applicable laws on the prevention of Money Laundering and Terrorist Financing. The main objective of these laws is to define and criminalize the laundering of proceeds generated from all serious crimes with the aim of depriving criminals of the profits from their crimes. In accordance with AML and CTF laws, the Company is required to establish policies and procedures to prevent money laundering and terrorist financing activities. The AML and CFT procedures implemented by the Company are based on applicable AML and CFT laws in the United Mexican States, the recommendations of the Financial Action Task Force (FATF), as well as other documents and information.

4- DEFINITIONS

4.1- Money Laundering

Money laundering is the process of creating the appearance that large amounts of money obtained from serious crimes, such as drug trafficking or terrorist activities, originated from a legitimate source.

There are three steps involved in the money laundering process: placement, layering, and integration.

4.1.1- Placement

Placement refers to the act of introducing "dirty money" (money obtained through illegitimate and criminal means).

4.1.2- Layering

Layering is the act of concealing the source of that money through a series of complex transactions and accounting gymnastics.

4.1.3- Integration

Integration refers to the act of acquiring that money through supposedly legitimate means.

4.2- Terrorism Financing

Terrorism financing (derived from crime) is the process by which funds are provided for the financing or financial support of individual terrorists or terrorist groups.

A terrorist, or terrorist group, is one that has a purpose or activity to facilitate or carry out any terrorist action, and may involve: individuals or groups.

4.3- AML / CTF

The term AML/CTF refers to "Anti-Money Laundering and Counter-Terrorism Financing" or "Anti-Money Laundering and the fight against the financing of terrorism."

4.3.1- Anti-Money Laundering

Anti-Money Laundering ("AML") refers to a set of procedures, laws, or regulations designed to stop the practice of generating income through illegal actions.

4.3.2- Counter-Terrorism Financing

Counter-Terrorism Financing ("CTF") refers to a set of procedures, laws, or regulations designed to prevent the financing or provision of financial support to individual terrorists or terrorist groups.

4.4- Financial Action Task Force (FATF)

The Financial Action Task Force ("FATF"), also known by its French name, Groupe d'action financière (GAFI), is an intergovernmental organization established in July 1989 by a summit of the Group of Seven (G-7) in Paris, initially to examine and develop measures to combat money laundering.
In October 2001, the FATF expanded its mandate to include efforts to combat the financing of terrorism, in addition to money laundering.

The objectives of the FATF are to establish standards and promote the effective implementation of legal, regulatory, and operational measures to combat money laundering, terrorist financing, and other threats related to the integrity of the international financial system.
Starting with its own members, the FATF monitors countries' progress in implementing the FATF Recommendations; reviews money laundering and terrorist financing techniques and countermeasures; and promotes the adoption and implementation of the FATF Recommendations globally.

The Working Group was responsible for examining the techniques and trends of asset laundering, reviewing actions that had already been taken at the national or international level, and establishing measures that still needed to be taken to combat asset laundering.
In April 1990, less than a year after its creation, the FATF issued a report containing a set of Forty Recommendations, aimed at providing a comprehensive action plan necessary to combat money laundering.

In 2001, the development of standards in the fight against the financing of terrorism was added to the FATF's mission.
In October 2004, the FATF published a Ninth Special Recommendations, further strengthening the agreed international standards to combat money laundering and terrorist financing: the 40 + 9 Recommendations.

In February 2012, the FATF completed a comprehensive review of its standards and published the revised FATF Recommendations. This review aims to strengthen global safeguards and further protect the integrity of the financial system by providing governments with stronger tools to take action against financial crimes. They have been expanded to address new threats, such as the financing of the proliferation of weapons of mass destruction. The new standards also impose higher levels of transparency and stricter regulations to combat corruption. The 9 Special Recommendations on terrorist financing have been fully integrated with measures against money laundering. This has resulted in a stronger and clearer set of standards.

5- Procedures

The provisions of the Laws adopted by the Company introduce procedures and processes that ensure compliance with the applicable Laws related to Money Laundering and Terrorist Financing activities.

5.1- Customer categorization and identification procedures

The Company has adopted all the requirements of the applicable laws regarding customer categorization and identification and due diligence procedures as explained below:

5.1.1- Customer categorization

Customers are classified according to their risk profile into three main categories, as explained below:

a- Low-risk customers

The following types of customers are considered lower risk. It should be noted that the Company will collect sufficient information to establish whether the customer qualifies to be classified as a lower risk customer:

i- Credit or financial institutions located in another country that impose requirements superior to or equivalent to those established by the Company's regulators.

ii- Listed companies whose securities are admitted to trading on a regulated market in other countries, which are subject to disclosure requirements compatible with Community legislation.

b- Normal risk customers

All customers who are not High Risk or Low Risk will be considered Normal Risk Customers.

c- High-risk customers

Customers with the following criteria are classified as high-risk due to the following conditions:

i- Non-face-to-face customers

ii- Customer accounts in the name of a third party

iii- Accounts of politically exposed persons ("PEPs")

iv- Online betting / gaming

v- Customers from countries that inadequately apply FATF recommendations

vi- Customers whose nature carries a higher risk of money laundering and terrorist financing

vii- Any other Client that the Company itself determines is classified as such

5.1.2- Customer identification (due diligence)

a- Due diligence conditions

Customer Identification and Due Diligence procedures apply in the following conditions:

i- Establishment of a business relationship.

ii- There is a suspicion of money laundering or terrorist financing, regardless of the amount of the transaction.

iii- There are doubts about the adequacy of the customer identification data obtained previously.

iv- The lack or refusal of a customer to submit the data and information required for the verification of their identity and the creation of their economic profile, without due justification.

b- Due diligence timings

i- Customer identification and due diligence must take place before the establishment of a business relationship or the carrying out of a transaction.

ii- Verification of the customer's identity may be completed during the establishment of a business relationship if this is necessary to avoid interrupting the normal course of business and where there is limited risk of money laundering or terrorist financing. In such a situation, these procedures must be completed as soon as possible.

iii- Reviews of existing records must be carried out on a regular basis, thus ensuring that the documents, data or information retained are up-to-date.

iv- The lack or refusal of a customer to submit the data and information required for the verification of their identity and the creation of their economic profile, without due justification.

v- When a customer's account is opened, it must be closely monitored.

vi- Customer due diligence procedures will apply not only to all new customers but also at appropriate times to existing customers on a risk-sensitive basis.

vii- At frequent intervals, the Company must compare the estimated billing with the actual account.

viii- Any serious deviation must be investigated, not only for the possible action of the Company in relation to the particular account in question, but also to assess the reliability of the person or entity who has introduced the customer.

c- Due diligence procedures

The practice adhered to by the Company to comply with the requirements of the Law regarding customer identification is achieved with a risk-based approach, and is detailed below:

i- Normal customer due diligence procedure

• Customer identification and verification of the customer's identity based on information obtained from a reliable and independent source.


• For legal entities, take appropriate and risk-based measures to understand the customer's ownership and control structure.


• Obtain information on the purpose and intended nature of the business relationship.


• Constantly monitor the business relationship, including scrutiny of transactions carried out throughout the course of the relationship to ensure that the transactions being conducted are consistent with the data and information that helps the firm in relation to the customer.

ii- Simplified due diligence procedure

Simplified procedures may be applied for low-risk customers. These measures will be applied when there is no suspicion of money laundering, regardless of any derogation, exemption or threshold, and not always when a business relationship is established.

iii- Enhanced customer due diligence procedure

The Company must apply enhanced customer due diligence measures in situations that, by their nature, may present a high risk of money laundering or terrorist financing.

The Company will take specific and appropriate measures to offset the high risk by applying one or more of the following measures:

• Ensure that the customer's identity is established through additional documents, data or information.


• Apply complementary measures to verify or certify the documents supplied.


• Ensure that the first payment of operations is made through an account opened in the customer's name. This account must be with a credit institution that operates in a country that imposes requirements superior or equivalent to those established by the Company's regulators.

d- Verification procedure

The Company will follow the following verification procedure to verify the customer's identity during the establishment of the business relationship:

i- The Company will ensure that the construction of the economic profile, suitability assessment, and suitability evaluation is carried out at all times prior to the establishment of the business relationship.

ii- Customers have a grace period of fifteen (15) days to deliver their identification documents to the Company; During this 15-day period, the Company must ensure the following:

• The cumulative amount of funds to be deposited will not exceed the amount of USD 2,000.


• Funds may only come from a bank account or other means linked to a bank account in the customer's name.


• Notification/reminder emails will be sent to customers requesting customer identification documents.


• Account closure in cases where the verification procedure does not conclude after the grace period.


• The Company will not withhold any customer's funds, and accounts will not be frozen unless they are under suspicion of money laundering.

e- Other due diligence-related matters

i- Politically Exposed Persons (PEP)

Politically Exposed Persons (“PEP”) are those individuals who have been entrusted with prominent public functions in a foreign country, as well as those who have a close relationship with politically exposed persons.

The Company must adopt the following additional due diligence measures to determine if a potential customer is a politically exposed person:

• Special approval from Senior Management prior to establishing a business relationship with the customer.


• Take appropriate measures to establish the source of the customer's assets and the source of the funds related to the establishment of the business relationship or transaction.


• Conduct enhanced and ongoing monitoring of the business relationship.

ii- Anonymous or numbered accounts

The Company is prohibited from maintaining anonymous or numbered accounts. Additionally, the Company shall pay special attention to any money laundering or terrorist financing threat that may arise from products or transactions that favor anonymity. The Company will also take necessary measures to prevent its use for money laundering or terrorist financing purposes.

iii- Performance of due diligence by third parties

The Company is authorized, and may rely on third parties, to fulfill customer due diligence requirements. However, in such cases, the ultimate responsibility for meeting these requirements will remain with the Company, which depends on the aforementioned parties.

5.2- Customer account opening procedures and KYC documentation

Before accepting new customers, the company will require these customers to provide certain information and identification documents.

5.2.1- Account opening

a- Information required for account opening

All customers interested in opening an account with the Company are requested to provide certain information, which includes:

• i- Customer's personal data


• ii- Construction of the customer's economic profile


• iii- Customer suitability / appropriateness assessment

It is obvious that customer identification, including the construction of the economic profile and suitability / appropriateness assessment, will be carried out before establishing the business relationship with the customer.

b- Account opening procedure

1. The customer completes the account opening forms by filling in all required information.


2. The responsible administrator collects all initial customer information and sends it directly to Senior Management, as well as to the Anti-Money Laundering Compliance Officer for examination, review, and approval.


3. After approval, the administrator records all necessary information in the Company's software systems and communicates it to related departments.

5.2.2- KYC Documentation

Before accepting new customers and allowing them to trade with the Company, the following documents must be obtained for customer identity verification:

a- Natural Persons

The identification documents required from natural persons (individual customers) to efficiently implement the Company's KYC procedures are as follows:

i- Proof of Identity

A valid government-issued proof of identity (passport, national identification card, driver's license, ...) which must include the customer's full name, customer's date of birth, customer's photograph, and validity status (expiration date and/or issue date + Validity Period). Additionally, it is ESSENTIAL that the customer takes a photograph where they can be seen holding this identity document along with their face, also known as a selfie.

ii- Proof of Residence/Address

A recent proof of address in the person's name (bank statement, utility bills, phone bills, ...) which must include the customer's full name, customer's residential address, and date of issue (must not be more than 6 months old).

b- Legal Entities

A different identification procedure is followed for Legal Entities (corporate clients) interested in opening an account with the Company. These documentation requirements are presented below:

i- Incorporation Documents

The form and name of corporate documents may vary depending on the country of incorporation and/or the legal form of the company. However, the required government-issued corporate documents must include the corporation's name, date and place of incorporation, registered office address, directors and authorized signatories, ownership structure / shareholding (names of shareholders and percentage of ownership), registered corporate activities.

These documents may include, but are not limited to, certificate of incorporation or certificate of registration, certificate of registered office, certificate of directors and secretary, certificate of registered shareholders, memorandum and articles of association,

ii- Documents of directors and beneficial owners

Personal identification and KYC documents are required from:

• Directors of legal entities


• The ultimate beneficial owners of the legal entity with 10% or more beneficial ownership.

These identification documents include proof of identity and proof of residence.

iii- Board Resolution

Resolution from the board of directors of the legal entity for the account opening and granting authority to those who will operate it.

5.3- Record-keeping procedures

The Company must retain the information and documents listed below for use in any investigation or analysis of potential money laundering or terrorist financing by national authorities.

The retention of documents/data, other than the original documents or their certified true copies kept in printed form, may be done in other forms, such as electronic format, provided that the Company can retrieve the relevant documents/data without undue delay and present them at any time, to the competent authorities, upon request. A faithful translation is attached in case the documents/data are in a language other than English.

• a- The name and address of customers and copies or records of official identification documents (such as passports, identity cards, or driver's licenses).


• b- The name and address (or identification code) of counterparties.


• c- The account details from which the funds were paid.


• d- The form and destination of the payment made by the company to the customer.


• e- Business correspondence.


• f- For customer due diligence, a copy of the reference checks is required for a period of at least 5 years after the business relationship with the customer has ended.


• h- For commercial relationships and transactions, supporting evidence and records for a period of at least five years following the completion of the transactions, or at the end of the commercial relationship.

5.4- Reporting suspicious transactions

A suspicious transaction is one that is inconsistent with the known legitimate business or personal activities of a customer or with the normal business of the specific account, or generally with the economic profile that the Company has created for the customer.

The Company ensures that adequate information is maintained at all times and knows enough about its customers' activities to timely recognize that a transaction or series of transactions is unusual or suspicious.

5.4.1- Examples of suspicious transactions

Examples of what might constitute suspicious transactions/activities related to money laundering and terrorist financing include, but are not limited to:

• a- Transactions with no discernible purpose or unnecessarily complex.


• b- Use of foreign company accounts, or group of companies with complicated ownership structures, not justified based on the customer's needs and economic profile.


• c- Large volume of transactions and/or money deposited or credited to an account, when the nature of the customer's business activities does not seem to justify such activity.


• d- There is no visible justification for a customer to use the services of a particular financial organization.


• e- Frequent transactions in the same financial instrument without apparent reason and under conditions that seem unusual.


• f- Frequent small purchases of a particular financial instrument by a customer who settles in cash, and then the total number of financial instruments is sold in a cash settlement transaction, or with the proceeds transferred with the customer's instructions to a different account than their own.


• g- Frequent small purchases of a particular financial instrument by a customer who settles in cash, and then the total number of the financial instrument is sold in a cash settlement transaction or with the proceeds transferred, with the customer's instructions, to an account other than their usual account.


• h- Transactions that do not conform to prevailing market conditions, especially regarding the size and frequency of the order.


• i- The settlement of any transaction, mainly large ones, in cash and/or through a third party who did not give the order.


• j- The settlement of any transaction but mainly large transactions in cash and/or the settlement of the transaction by a third party different from the customer who gave the order.


• k- The transfer of funds to and from countries or geographical areas that do not apply or inadequately apply the FATF Recommendations on money laundering and terrorist financing.


• l- Reluctance to provide complete personal information when establishing a business relationship, i.e., regarding the nature and purpose of their business activities, anticipated account activity, previous relationships with financial organizations, names of their officers and directors, or business address.


• m- Providing minimal, difficult, or expensive information for the Company to verify.


• n- Providing unusual or suspicious identification documents that cannot be easily verified.


• o- Frequent or large transactions by a customer with no record of past or present employment experience.


• p- The introduction of a customer through a foreign financial organization, or a third party whose country(ies) or geographical area(s) of origin do not apply or inadequately apply the FATF Recommendations on money laundering and terrorist financing.


• q- The use of an address that is linked to persons involved in cash transactions, particularly when that same address does not correspond to the declared occupation (e.g., student, unemployed, self-employed, etc.)


• r- Shared address for individuals involved in cash transactions, particularly when the address is also a business location and/or does not seem to correspond to the stated occupation (e.g., student, unemployed, self-employed, etc.).


• s- The customer's declared occupation is not commensurate with the level or size of the executed transactions.


• t- Use of general nomination documents in a way that restricts the control exercised by the company's board of directors

5.4.2- Suspicious Transaction Reporting Procedure

The procedure for reporting a suspicious transaction of a customer is as follows:

• a- Reports from Company employees from different departments are evaluated by the AML Compliance Officer.


• b- If deemed necessary, the Compliance Officer will notify the relevant Money Laundering Authorities.


• c- After the report is submitted, the customer's account(s) in question, as well as any other connected accounts, are closely monitored by the Compliance Officer.


• d- After submitting the report, the Company adheres to the instructions given by the relevant Money Laundering Authorities, particularly regarding whether to resume or suspend a particular transaction, or keep a particular account active.


• e- Electronic transactions executed for the customer are compared and evaluated against the anticipated account billing, the usual billing of the customer's activities/operations, and the data and information stored for the customer's economic profile.


• f- Significant deviations are investigated and findings are recorded in the respective customer file.


• g- Operations that are not justified by the available information about the customer are thoroughly examined to determine if suspicions of money laundering or terrorist financing arise. If this were the case, a report would be sent respectively to the Compliance Officer and then to the relevant Money Laundering Authorities.

5.5- Daily/Monthly Procedures of the AML Compliance Officer

The procedure that the AML compliance officer must follow daily/monthly is as follows:

• i. Receive a daily report from staff members on any suspicious transactions.


• ii. Examine the reports sent (if any).


• iii. Inform Senior Management and advise on the need to take any of the following actions.


• iv. Stop transactions if reports are in process.


• v. Inform the customer of the reasons why their transaction has been cancelled.


• vi. Collect transaction information if it has already been executed.


• vii. Report the suspicious transaction to the relevant authorities according to the law.

6- Education and Personal Training

The Company ensures that its employees are fully aware of their legal obligations in accordance with anti-money laundering and terrorist financing laws through a comprehensive employee education and training program.

The training program aims to educate employees on the latest developments in the prevention of money laundering and terrorist financing, including practical methods and trends used for this purpose.

The training program ensures that Company employees are fully aware that they can be personally liable for not reporting information or suspicions about money laundering or terrorist financing. The timing and content of the training provided to employees in various departments is adjusted according to the needs of each department.

The frequency of training may vary depending on changes in legal and/or regulatory requirements, employee obligations, and any other changes in the financial system.

The structure of the training program will be consistent with the needs, as well as the various functions, of new employees, existing employees, and the different departments of the Company.

Continuous training is provided at regular intervals to ensure employees are reminded of their duties and responsibilities and kept informed of any developments.

Any personal information collected about the client, such as name, address, date of birth, and contact details, will be kept in Forex Blend strictly for business purposes. Other information, such as client transactions, copies of passports, and proof of address, will remain confidential and will be shared only between our account services and compliance departments. Additionally, Forex Blend may inquire about the client's creditworthiness, which will also remain confidential within our client files. Such information may be maintained physically or electronically with strict access procedures.

Forex Blend may share client information with internal departments or affiliated offices that perform marketing, back-office, and customer service functions to conduct normal business operations. Each employee within Forex Blend has signed a Confidentiality Agreement as client information is required to be kept confidential.

Any questions or additional information about our privacy policy can be directed to our Customer Service Department at [brand email]