Legal Documents

ANTI-MONEY LAUNDERING (AML) POLICY
1. INTRODUCTION
Nexeraltrading Ltd (“Nexeraltrading”, the “Company”, “we”, “us” or “our”) is committed to maintaining appropriate standards for the prevention of money laundering, terrorist financing, fraud and other financial crime.
The purpose of this Anti-Money Laundering Policy (“AML Policy”) is to establish the principles and procedures applied by the Company to identify its clients, understand the nature and purpose of their relationship with the Company, monitor relevant activity and take appropriate measures where suspicious, unlawful or unusual activity is identified.
The Company takes reasonable measures designed to prevent its products and services from being used for money laundering, terrorist financing or other criminal purposes and applies identification, verification, monitoring and record-keeping procedures in accordance with applicable legal and regulatory requirements.
For the purposes of this Policy, money laundering generally refers to the process of concealing, disguising or converting the proceeds of unlawful activity so that such funds appear to originate from legitimate sources.
• Placement – introducing unlawfully obtained funds into the financial system or converting them into other forms of assets or financial instruments.
• Layering – conducting transactions, transfers or conversions intended to obscure the origin, ownership or movement of funds.
• Integration – reintroducing the funds into the legitimate economy in a form that appears to have a lawful origin.
These stages may overlap, occur in a different order, or not all be present in a particular case.
2. COMPANY AML PROCEDURES
The Company maintains procedures designed to identify and assess money laundering and terrorist financing risks associated with its clients and their activities.
• Know Your Customer (“KYC”) and customer identification procedures;
• Customer Due Diligence (“CDD”);
• Enhanced Due Diligence (“EDD”) where appropriate;
• identification and verification of beneficial owners;
• verification of source of funds and, where appropriate, source of wealth;
• sanctions and other relevant screening;
• monitoring of client activity and transactions;
• review and investigation of unusual or suspicious activity; and
• appropriate record keeping.
The extent of verification and due diligence performed may vary depending on the circumstances and the risk associated with a particular client, transaction, jurisdiction, payment method or business relationship.
The Company may request additional information or documentation at any time where reasonably necessary for compliance, security, fraud prevention or risk-management purposes.
3. KNOW YOUR CUSTOMER AND CUSTOMER DUE DILIGENCE
Before establishing or continuing a business relationship, the Company may require sufficient information and documentation to establish and verify the identity of the client.
• the client’s residential or registered address;
• nationality or jurisdiction of incorporation;
• occupation, employment or business activities;
• expected account activity;
• purpose and intended nature of the business relationship;
• source of funds;
• source of wealth, where appropriate;
• beneficial ownership;
• tax residency or other information required by applicable law;
• payment methods and financial accounts used by the client; and
• any other information reasonably required for compliance purposes.
The Company may apply enhanced scrutiny or Enhanced Due Diligence where it determines that a client, transaction or business relationship presents an increased risk.
This may include circumstances involving higher-risk jurisdictions, politically exposed persons (“PEPs”), complex ownership structures, unusual transaction patterns, sanctions exposure or other factors identified through the Company’s risk assessment.
The Company may refuse to open an account, restrict an account, delay a transaction, request additional documentation, suspend services or terminate a business relationship where satisfactory verification or due diligence cannot be completed.
4. INDIVIDUAL CLIENTS
Individual clients may be required to provide personal information including:
• full legal name;
• date of birth;
• nationality;
• country of residence;
• residential address;
• contact information; and
• any other information reasonably required for identification or verification purposes.
Documents that may be requested for identity verification include:
• a valid passport;
• a valid national identity card;
• a valid driving licence bearing a photograph; or
• another government-issued identification document acceptable to the Company.
Clients may also be required to provide evidence of their current residential address, such as:
• a utility bill;
• bank or financial institution statement;
• government correspondence;
• tax document; or
• another document accepted by the Company.
Proof-of-address documentation may be subject to recency requirements determined by the Company.
Where documents are issued in a language or script that cannot reasonably be verified by the Company, the Company may request an English translation, certified translation or other supporting documentation.
The Company may request updated documents where previously submitted information has expired, changed or is no longer considered sufficient.
5. CORPORATE CLIENTS
Where the client is a company or other legal entity, the Company may require documents and information sufficient to establish its legal existence, ownership, management and authority to operate the account.
Depending on the nature and jurisdiction of the entity, this may include:
• Certificate of Incorporation, Certificate of Registration or equivalent document;
• Memorandum and Articles of Association, constitutional documents or equivalent;
• evidence of the registered office or principal place of business;
• register or details of directors;
• register or details of shareholders;
• ownership and control structure;
• board resolution or other evidence authorising the establishment and operation of the account;
• identification of authorised representatives or signatories;
• identification and verification of directors where appropriate;
• identification and verification of ultimate beneficial owners (“UBOs”);
• powers of attorney or other documents establishing authority to act;
• information regarding the nature and purpose of the entity’s business;
• source of funds and, where appropriate, source of wealth; and
• any other information or documentation reasonably required by the Company.
The Company may apply simplified, standard or enhanced due diligence depending on the nature of the entity and the risk associated with the business relationship, to the extent permitted by applicable requirements.
The Company may require information sufficient to identify the natural person or persons who ultimately own or control a corporate client.
6. SANCTIONS, PEP AND HIGH-RISK SCREENING
The Company may screen clients, beneficial owners, directors, authorised representatives and other relevant persons against applicable sanctions lists and other compliance databases.
The Company may also identify whether a person is a Politically Exposed Person (“PEP”), a family member or close associate of a PEP, where relevant to the Company’s compliance obligations and risk assessment.
Being identified as a PEP does not automatically prevent a person from becoming or remaining a client. However, additional due diligence, information, documentation, monitoring or approval may be required.
The Company may apply enhanced measures to clients connected with jurisdictions or activities that present an increased risk of money laundering, terrorist financing, sanctions violations, fraud, corruption or other financial crime.
7. SOURCE OF FUNDS AND SOURCE OF WEALTH
The Company may request information and supporting evidence concerning the origin of funds deposited or otherwise used in connection with an account.
Depending on the circumstances, supporting documentation may include:
• bank statements;
• employment or income records;
• business income documentation;
• investment records;
• sale agreements;
• inheritance documentation;
• tax records; or
• other evidence reasonably demonstrating the legitimate origin of funds.
Where appropriate, the Company may also request information regarding a client’s source of wealth.
Failure to provide satisfactory information or documentation may result in a deposit, withdrawal or other transaction being delayed, rejected or restricted, or in the account being suspended or terminated.
8. MONITORING OF CLIENT ACTIVITY
The Company may monitor client accounts and transactions on an ongoing basis in order to identify activity that is unusual, inconsistent with information known about the client or potentially indicative of money laundering, terrorist financing, fraud or other unlawful activity.
Monitoring may be performed through automated systems, manual review or a combination of both.
Factors considered may include, without limitation:
• transaction size and frequency;
• unusual deposit or withdrawal patterns;
• transactions inconsistent with the client’s known profile or expected activity;
• rapid movement of funds;
• attempted use of third-party payment methods;
• unusual changes in payment destinations;
• activity involving higher-risk jurisdictions;
• unexplained changes in transaction behaviour;
• apparent attempts to avoid verification or monitoring requirements; and
• other activity considered unusual or suspicious in the circumstances.
The Company is not required to disclose its internal monitoring criteria, risk models, thresholds or investigation procedures to clients.
9. DEPOSITS AND WITHDRAWALS
The Company applies controls to deposits and withdrawals in order to reduce the risk of fraud, money laundering, terrorist financing and other unlawful activity.
As a general principle:
• deposits should originate from a payment account or payment method held in the name of the client;
• withdrawals should generally be made to an account or payment method held in the name of the client;
• the Company may reject or return payments received from third parties;
• the Company may require funds to be returned to the original funding source where appropriate;
• the Company may request evidence establishing ownership or control of a bank account, payment account, card, digital asset wallet or other payment method;
• the Company may request additional information concerning the origin or destination of funds;
• withdrawal requests may be subject to identity, security, compliance and available-balance checks; and
• processing may be delayed where additional verification or review is required.
The availability of a particular deposit or withdrawal method does not create an unconditional right to use that method for withdrawals.
Where funds cannot reasonably be returned through the original funding method, the Company may permit withdrawal through another verified payment method or destination associated with the client, subject to satisfactory verification and the Company’s compliance procedures.
The Company may refuse, delay, reverse where legally and operationally possible, or otherwise restrict a deposit or withdrawal where it reasonably considers that further verification, compliance review, fraud investigation or other checks are required.
The Company does not accept physical cash deposits or make physical cash payments.
10. THIRD-PARTY PAYMENTS
Unless expressly approved by the Company following appropriate verification, the Company does not accept deposits made on behalf of a client by an unrelated third party and does not process withdrawals to unrelated third parties.
Where the name of the payer, payment account holder or intended recipient differs from the registered client, the Company may:
• request additional information or documentation;
• reject or return the payment;
• delay the transaction pending verification; or
• take any other action reasonably required for compliance or security purposes.
The Company may make exceptions where legally permissible and adequately documented, including certain corporate structures, authorised representatives or other circumstances accepted by the Company following appropriate due diligence.
11. RECORD KEEPING
The Company maintains records relating to client identification, verification, due diligence, account activity, transactions and compliance reviews as required for legal, regulatory, security and risk-management purposes.
Such records may include:
• identification and verification documents;
• KYC and due diligence information;
• beneficial ownership information;
• source-of-funds and source-of-wealth documentation;
• transaction and payment records;
• compliance reviews and internal assessments; and
• records relating to suspicious or unusual activity.
Records will be retained for the period required under applicable legal and regulatory requirements and the Company’s record-retention policies.
The Company may retain relevant records following termination or closure of an account where required or permitted for legal, regulatory, dispute-resolution, fraud-prevention, security or compliance purposes.
12. SUSPICIOUS ACTIVITY
Where the Company identifies activity that it reasonably suspects may involve money laundering, terrorist financing, fraud, sanctions violations or other criminal activity, the Company may take such action as it considers necessary or as required by applicable law.
Such action may include:
• requesting additional information or documentation;
• delaying or rejecting transactions;
• restricting deposits or withdrawals;
• temporarily restricting or suspending account activity;
• terminating the business relationship; and
• making reports or disclosures to competent authorities where required or permitted by law.
Where prohibited by applicable law, the Company will not inform a client that a suspicious activity report, investigation or similar disclosure has been made or is being considered.
13. CLIENT RESPONSIBILITIES
Clients are responsible for providing information and documentation that is complete, accurate, current and not misleading.
Clients must promptly notify the Company of material changes to information previously provided, including changes relating to:
• name;
• residential or registered address;
• contact information;
• ownership or beneficial ownership;
• authorised representatives;
• payment information; or
• other information relevant to the Company’s KYC or compliance procedures.
Clients must not use their accounts for unlawful purposes or knowingly permit another person to use an account in a manner that breaches applicable law or this Policy.
The Company may require KYC or due diligence procedures to be repeated periodically or whenever circumstances reasonably justify further verification.
14. ACCOUNT RESTRICTION AND TERMINATION
The Company reserves the right, subject to applicable law and contractual obligations, to refuse, restrict, suspend or terminate an account or business relationship where:
• required verification cannot be satisfactorily completed;
• requested information or documentation is not provided;
• information provided appears false, misleading or inconsistent;
• suspicious or unusual activity is identified;
• sanctions or other legal restrictions apply;
• the Company reasonably suspects fraud, money laundering, terrorist financing or other unlawful activity; or
• continuation of the relationship would expose the Company to unacceptable legal, compliance or financial-crime risk.
The Company may take such measures without prior notice where prior notice is prohibited by law or where immediate action is reasonably necessary for compliance, fraud prevention or security purposes.
15. POLICY REVIEW AND AMENDMENTS
The Company may review and amend this AML Policy from time to time to reflect changes in applicable laws, regulatory requirements, business operations, risk assessments, payment methods or compliance procedures.
The current version of this Policy will be made available through the Company’s website or other designated communication channel.
Any amendments to this Policy will become effective in accordance with the applicable Client Terms, legal or regulatory requirements, and any notice requirements applicable in the circumstances.
16. COMPANY INFORMATION
Nexeraltrading Ltd
Registered Address:
P.B. 1257 Bonovo Road
Fomboni, Comoros
Operational Address:
Carrera #71-21, Torre B
Bogotá, Cundinamarca
Colombia
Effective Date: 28 August 2026