City Traders Imperium

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AML POLICY

INTRODUCTION

City Traders Imperium is committed to combating money laundering, terrorist financing, and other illicit financial activities. This Anti-Money Laundering (AML) Policy establishes the framework for ensuring compliance with applicable laws and regulations.

Scope

This policy applies to all employees, directors, contractors, clients, and counterparties engaging with City Traders Imperium. The firm is dedicated to preventing the misuse of its platform for money laundering or financing criminal activities.

AML Compliance Officer

City Traders Imperium has designated an AML Compliance Officer responsible for overseeing and implementing this policy. The officer’s duties include:

  • Ensuring compliance with AML laws and regulations.
  • Conducting periodic risk assessments.
  • Reporting suspicious activities to relevant authorities.
  • Providing AML training to employees.
  • Maintaining records of transactions and client due diligence.

Client Due Diligence (CDD)

City Traders Imperium implements a risk-based approach to Client Due Diligence (CDD), including:

  • Know Your Customer (KYC) Procedures: Verifying the identity of clients and their place of residence.
  • Enhanced Due Diligence (EDD): Applying additional scrutiny to high-risk clients, including politically exposed persons (PEPs) and clients from high-risk jurisdictions.
  • Ongoing Monitoring: Continuously monitoring client activity to detect unusual or suspicious transactions.

Risk Assessment

City Traders Imperium conducts risk assessments to identify and mitigate AML risks associated with its business model. This includes:

  • Assessing the risk profile of clients.
  • Evaluating the nature and size of transactions.
  • Monitoring emerging threats and typologies related to money laundering.

Suspicious Activity Reporting (SAR)

City Traders Imperium mandates the reporting of suspicious transactions to the appropriate regulatory bodies. Employees must:

  • Identify transactions that lack a clear economic or legal purpose.
  • Escalate concerns to the AML Compliance Officer.
  • Maintain confidentiality when handling SARs to prevent tipping off.

Record Keeping

City Traders Imperium retains AML-related records for a minimum of five years, including:

  • Client identification documents.
  • Transaction histories.
  • Internal reports on suspicious activities.
  • Training and compliance audit records.

Employee Training and Awareness

All employees receive AML training to ensure:

  • Awareness of money laundering risks and red flags.
  • Understanding of their role in AML compliance.
  • Ability to recognize and report suspicious activities.

Compliance Audits

City Traders Imperium conducts periodic internal and external audits to ensure the effectiveness of AML controls and regulatory compliance.

Sanctions and Penalties

Non-compliance with AML policies may result in disciplinary actions, including termination of employment, regulatory penalties, or criminal prosecution.

Policy Review

This policy is reviewed and updated annually or as necessary to reflect regulatory changes and evolving risks.

Conclusion

City Traders Imperium is dedicated to upholding the highest standards of financial integrity. This AML Policy is essential to maintaining a secure and transparent trading environment while protecting the firm from financial crime risks.