Market Equity is committed to the perfect standards of Anti-Money Laundering (AML). The members of the Management Board and all in the company are required to stick to those standards to shield Market Equity Inc. and its reputation from being misused for hiding/concealing money laundering and/or terrorist financing or other illegal purposes. Market Equity Inc. will examine its AML policy, procedures, goals, and objectives on an ongoing basis and maintain an honest program. Market Equity has implemented clear rules and regulations detailed within the AML and operations procedure manuals and which must be complied with by all Market Equity’s staff.

Policies and Procedures

Market Equity has developed Policies and Procedures outlining its general AML standards and principles. Detailed documents confirm that these standards are implemented in day-to-day business. All policies and policy-related documents are published on our policy platform in order to be accessed by all staff at any time, they’re subject to an annual review cycle to substantiate their conformity with AML regulations.

Prohibited Business Relationships

Market Equity must refuse to open an account /  or close an existing account/terminate a deal if Market Equity cannot verify the true identity of the client and/or UBOs and/or the nature of the business or formal requirements concerning the identification of the client and/or UBOs aren’t met. Market Equity must not Accept assets that are known or suspected to be the proceeds of criminal activity. Enter into/maintain business relationships with individuals or entities known or suspected to be a terrorist or criminal organization or member of such or listed on sanction lists. Maintain anonymous accounts, accounts for shell banks, or pay-through accounts. Enter relationships with clients operating in prohibited industries. Research and Filing of Suspicious Activity Reports (SARs) / Suspicious Transaction Reports (STRs). Suspicious activities must be properly handled and escalated internally to FIU. Regular AML training ensures that staff is reminded of their duty to timely report any suspicious activity to the AML Officer.

Management and Controls of AML Risk

Market Equity maintains a comprehensive set of measures to spot, manage and control its AML risk. These measures are

Controls

A robust and strict KYC program

A training and awareness program for Market Equity Inc. staff

Processes to substantiate staff reliability

Controls

Adherence to the group-wide AML/AFC program has to be reviewed regularly to ensure that the Company’s efforts are successful. The Compliance Manager/AML Officer is obliged to conduct appropriate controls.

KYC Program

Market Equity has implemented a strict KYC program to substantiate all its customers (natural or legal persons or legal structures, correspondent banks) are subject to adequate identification, risk rating, and monitoring measures. This program has been implemented globally and throughout all business divisions KYC includes not only knowing the clients and entities the Bank deals with (either one transaction or ongoing relationship), or renders services to, but also the Ultimate Beneficial Owners (UBOs), Legal Representatives and Authorized Signatories as appropriate.

The program includes strict identification requirements, name screening procedures, and also ongoing transaction monitoring, and regular review of all existing business relationships.

Special safeguards are implemented for business relationships with politically exposed persons (PEPs) and clients from countries or industries deemed high risk.

Training Program

Market Equity implements a comprehensive AML/AFC educational training program to confirm that each staff, individuals responsible for transaction processing and/or initiating and/or establishing business relationships, undergo AML awareness training.

The training is customized to the business to substantiate that staff is aware of different possible patterns and techniques of money laundering which may occur in their everyday business. Training also covers the overall duties arising from applicable external (legal and regulatory), and internal requirements and also the resulting individual duties which must be adhered to within the everyday business and also as typologies to acknowledge hiding/ money laundering or financial crime activities.

Record Retention

All data obtained consistent with client identification and AML security measures must be documented. Records must be kept for a minimum of Ten years, notwithstanding potentially longer retention periods under local civil or commercial law.