AML POLICY FOR KUDOTRADE

Kudotrade is dedicated to upholding the highest standards of compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. In support of government efforts to combat terrorism funding and money laundering, legislation mandates that all financial institutions collect, verify, and document identifying information for individuals opening accounts. 

Money laundering refers to the process of transforming proceeds obtained from illegal activities, such as fraud, corruption, or terrorism, into different funds or investments that appear legitimate, with the aim of concealing or distorting the true origin of the funds. 

The process of money laundering can be divided into three sequential stages: 

• Placement- During the placement phase, illicit funds are converted into various financial instruments like checks, bank accounts, or money transfers. Alternatively, they may be used to buy high-value goods that can be later resold. Another method involves physically depositing the funds into banks or non-bank entities like currency exchange services. To evade detection, the launderer might opt for multiple smaller deposits instead of a single large one; this tactic is known as smurfing. 
• Layering. Money is transferred or relocated to different accounts and financial instruments to conceal its origin and obscure the identity of the entity behind multiple financial transactions. By shifting funds and altering their form, the process becomes intricate, impeding efforts to trace the laundered money. 
• Integration. Funds get back into circulation as legitimate to purchase goods and services. 

Kudotrade upholds Anti-Money Laundering principles and proactively thwarts any efforts or facilitation of legitimizing unlawfully obtained funds. Our AML policy is centered on preventing criminals from utilizing our services for money laundering, terrorist financing, or any other illicit activities. 

To combat money laundering, Kudotrade strictly prohibits both the acceptance and disbursement of cash in any situation. The company retains the authority to suspend any client’s activities that are deemed illegal or potentially linked to money laundering, as determined by our staff.

Company Procedures 

Kudotrade ensures that it verifies the identity of individuals or legal entities it engages with. Additionally, the company adheres to all necessary measures mandated by relevant laws and regulations issued by monetary authorities. The fulfillment of the AML policy within Kudotrade is achieved through the following procedures: 

• Know your customer (KYC) and due diligence 
• Monitoring of client activity 
• Record keeping 

Know Your Customer and Due Diligence 

Due to the company’s dedication to AML and KYC policies, every client must undergo a verification process. Before initiating any business with a client, Kudotrade ensures the provision of sufficient evidence to verify their identity or implements alternative measures to obtain such evidence satisfactorily. Additionally, the company applies enhanced scrutiny to clients residing in countries identified by credible sources as having insufficient AML standards or posing a high risk for crime and corruption, as well as to beneficial owners residing in and sourcing funds from these named countries. 

Individual Clients 

As part of the registration process, every client furnishes personal details including their full name, date of birth, country of origin, and full residential address. To verify these details, the following documents are necessary: clients are required to submit the following documents. If the documents are written in non-Latin characters, a notarized translation in English is required to prevent delays in the verification process. This is done to comply with KYC requirements and to authenticate the provided information. 

See the list of required documents below; 

• Current valid passport (showing the first page of the local or international passport, where the photo and the signature are clearly visible); 
• Driving license which bears a photograph; or ● National identity card (showing both front and back pages); 
• Documents proving current permanent address (such as utility bills, bank statements, etc.) containing the client’s full name and place of residence. These documents should not be older than 3 months from the date of filing Current valid passport (showing the first page of the local or international passport, where the photo and the signature are clearly visible); 
• Driving license which bears a photograph; 
• National identity card (showing both front and back pages); and 
• Documents proving current permanent address (such as utility bills, bank statements, etc.) containing the client’s full name and place of residence. These documents should not be older than 3 months from the date of filing. 

Corporate Clients 

If the applying company is listed on a recognized or approved stock exchange, or if there is independent evidence demonstrating that it is a wholly owned subsidiary or under the control of such a company, additional identity verification steps are typically unnecessary. However, if the company is unlisted and none of the main directors or shareholders currently holds an account with Kudotrade, the following documentation must be submitted: 

• Certificate of Incorporation or any national equivalent; 
• Memorandum and Articles of Association and statutory statement or any national equivalent; 
• Certificate of good standing or other proof of registered address of the company; 
• Resolution of the board of directors to open an account and confer authority on those who will operate it; 
• Copies of powers of attorney or other authorities given by the directors in relation to the company; 
• Proof of identity of directors in case he/she will deal with Kudotrade on behalf of the Customer (according to the Individual identity verification rules described above); 
• Proof of identity of the beneficial owner(s) and/or the person(s) on whose instructions the signatories on the account are empowered to act (according to the Individual identity verification rules described above). 

Monitoring of client activity 

Apart from initial client information collection, Kudotrade maintains ongoing monitoring of each client’s activity to detect and deter any potentially suspicious transactions. A suspicious transaction is defined as one that deviates from the client’s legitimate business activities or their typical transaction patterns as observed through client activity monitoring. Kudotrade has established a system for monitoring such transactions, employing both automatic and, if necessary, manual processes to prevent the utilization of the company’s services by criminals. 

Record Keeping 

All transaction data, identification-related information, and documents concerning money laundering, such as files documenting suspicious activity reports and AML account monitoring, must be meticulously recorded and retained. These records are maintained for at least seven years following the closure of the account.

Deposit and withdrawal requirements 

All deposits and withdrawals on trading accounts held with Kudotrade follow the following strict requirements: 

• Due to AML / CTF laws, Kudotrade cannot receive or deposit funds to third parties. 
• Funds sent to Kudotrade must be from a bank account, Credit/Debit card or Alternative Payment Method (Skrill, China Union Pay, Neteller, Fasapay or others) under the same name as the trading account name with Kudotrade. 
• All funds withdrawn from a trading account must go to a bank account, Credit/Debit card or Alternative Payment Method (Skrill, China Union Pay, Neteller, Fasapay or others) under the same name as the trading account name with Kudotrade. 
• All withdrawal requests are processed on a First-in-First-Out (FIFO) basis according to the funding source of origination. For example, a deposit is made via Debit/Credit Card; then a subsequent withdrawal request is received. The amount of funds sent back to the relevant Debit/Credit Card, when a withdrawal request is received, may not exceed the original amount deposited. Any profits made in excess of the deposited amount will be transferred to a nominated bank account; which must be held in the same name as your trading account. 

Examples: 

• You deposited $100 via Credit Card and earned a profit of $1,000. Requesting a withdrawal of $1,000, you will get $100 to your Credit Card and the rest $900 to your bank account. 
• You deposited $100 via Skrill and $50 via Credit Card. Requesting a Skrill withdrawal of $120, you will get $100 to Skrill and $20 to the card. 
• All initial withdrawal requests must be verified for safety and security by provision of a bank statement; which includes account holder information and bank details. Kudotrade will not accept deposits or withdrawals made under a different name to the registered Kudotrade. 
• If a trading account was credited in a way that cannot be used for funds withdrawal, the funds may be withdrawn to a bank account under the same name as the trading account name with Kudotrade as long as the client provides satisfactory evidence of the ownership of bank account where the funds originated from as well as the destination bank account. 

Measures taken 

If Kudotrade suspects any transactions to be linked with money laundering or other criminal activities, it will act in accordance with relevant laws by reporting suspicious activities to the appropriate regulatory authority. Kudotrade maintains the right to suspend operations of any client deemed engaged in illegal activities or suspected of money laundering, as determined by staff judgment. The company also possesses the discretion to temporarily freeze suspicious client accounts or terminate existing client relationships.