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.
Timing of Verification
Full verification must be successfully completed prior to any profit withdrawal or capital allocation.
Additional verification may be required at any time based on risk indicators, transaction behaviour, or regulatory requirements.
Verification Measures
To verify client identity and data accuracy, City Traders Imperium collects and validates:
A government‑issued photo identification document, such as a passport, a national ID card, or a driver’s license.
Proof of residential address, such as a utility bill, a bank statement, or government correspondence (issued within the last three months).
Liveness and identity verification checks, where applicable.
- Email & Phone number.
All documents are reviewed for authenticity, consistency, and validity through 3rd-party integration SumSub. Inconsistencies, expired documents, or suspected falsification will result in rejection or escalation to Enhanced Due Diligence (EDD).
Use of Third‑Party KYC Provider
City Traders Imperium utilises an independent, third‑party identity verification provider to conduct KYC and AML screening. The firm currently uses Sumsub to perform:
Identity verification.
Document authenticity checks.
Sanctions screening.
Politically Exposed Person (PEP) screening.
Adverse media checks,
- AML Screening.
Client data is processed securely in accordance with applicable data protection and privacy regulations. City Traders Imperium does not alter or override KYC results generated by the provider.
Prohibited Jurisdictions and Sanctions Compliance
City Traders Imperium strictly prohibits access to its services by individuals or entities that are:
Located in, resident in, or citizens of sanctioned or high‑risk jurisdictions
Subject to international sanctions, embargoes, or restrictive measures
Prohibited Jurisdictions
At a minimum, City Traders Imperium does not accept clients from, or provide services to, citizens or residents of the following countries:
Iran, North Korea, Myanmar, the Russian Federation, Belarus, Cuba, Syria.
This list is reviewed regularly and updated in accordance with sanctions imposed by local regulators, international authorities, and applicable laws.
Any attempt to circumvent jurisdictional restrictions, including the use of VPNs, false documentation, or third‑party intermediaries, will result in immediate account termination and potential reporting to relevant authorities.
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.
Verification Failure and Account Restrictions
If a client:
Fails KYC verification,
Provides misleading or fraudulent information, or
Is identified as high risk.
City Traders Imperium reserves the right to:
Suspend or terminate the account.
Withhold access to trading programs.
Block withdrawals.
Report the activity to the relevant regulatory or enforcement bodies.
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.
