AML Policy

Introduction

Delcamp Global Markets Inc LTD (hereinafter referred to as the “Company”) is authorized and regulated by the Mwali International Services Authority (M.I.S.A.), under an International Brokerage and License number BFX2024041. The Company is incorporated in Fomboni, Island of Mohéli, Comoros Union, with registration number HT00324013. The registered address is Bonovo Road, Fomboni, Island of Mohéli, Comoros Union.

The Company does its utmost to ensure the privacy, confidentiality and security of its clients are preserved both throughout their interaction with the company and afterwards, to the fullest extent achievable by the Company. At the same time, the Company is obliged to follow certain requirements as set out by the local regulator for preventing and suppressing money laundering activities. As of such, the Company is obliged to follow strict Anti-Money Laundering (AML) and Counter Terrorism Financing procedures while it is also required to obtain certain verification information as well as documentation.

The Company determines the identity of the beneficial ownership of all its clients’ accounts and does not open or maintain such accounts, unless it is satisfied of this requirement, as stipulated in the AML Policies and the legislative requirements. It has established procedures to obtain appropriate evidence of client identity and maintains adequate records of client identity and transactions involved in such a manner as to assist, if necessary, in the investigation of criminal offences.

The Company has established policies and procedures to detect and prevent transactions related to money laundering, ensuring compliance with relevant legislation issued by its regulator.

The Company is committed to preventing its involvement in money laundering activities and does not knowingly accept assets or engage in business relationships where there is reasonable cause to believe the assets were acquired illegally or represent the proceeds of criminal activity and shall promptly report suspicious transactions relating to any account to the Supervisory Authority. Where there is suspicion that the source of funds may be criminal or that a client may be involved in criminal activity, the Company shall follow established procedures for assessing the evidence and determine what course of action should be pursued.

The Company is vigilant in ensuring the prevention of its involvement or misuse in money laundering activities and is not knowingly accepting assets or entering business relationships where there is reasonable cause to believe that such assets may have been acquired illegally or may represent the proceeds of criminal activity.

The Company shall maintain records of reports made by its staff and those submitted to the Supervisory Authority. To verify the identity of any client, the Company requires the customer to provide identification documents (e.g., passport, ID card, driver’s license). The Company reserves the right to request any additional documentation deemed necessary at any point during the business relationship.

The Company shall:

• Obtain information on the purpose and nature of the business relationship when establishing a new business relationship.
• Adequately identify and verify the identity of any natural person conducting a transaction, including information such as the person’s name, address, national identity card, social security document, passport, or other applicable official identification document.
• Adequately identify the beneficial owner of any legal entity conducting a

transaction with the Company and take reasonable measures to identify and verify its ownership and control structure. This includes obtaining information such as:

• The customer’s name, legal form, head office address, and identities of
• The principal owners, beneficiaries, and control
• Provisions regulating the authority to bind the entity and verifying that any person claiming to act on behalf of the customer is authorized to do so and identifying those persons.

• Have appropriate risk management systems to determine if a customer or beneficial owner is a politically exposed person (PEP). If so, the Company shall:
  • Adequately identify and verify the PEP’s identity as outlined in this
  • Obtain the approval of senior management before establishing a business relationship with the PEP.
  • Take reasonable measures to establish the source of funds and
  • Conduct regular enhanced monitoring of the business

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