AML/CFT Policy
Our commitment to preventing money laundering, terrorist financing, and financial crime in compliance with Mauritius and international regulations.
Contents
1. Introduction and Policy Statement
1.1. Purpose
Vertex1 Brokers Limited ("Vertex", "the Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT). The purpose of this Policy is to prevent the Company's systems and services from being used for money laundering, terrorist financing, or proliferation financing.
1.2. Regulatory Framework
This Policy is drafted in strict compliance with the laws of the Republic of Mauritius, specifically:
Financial Intelligence and Anti-Money Laundering Act 2002
Financial Intelligence and Anti-Money Laundering Regulations 2018
United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019
FSC AML/CFT Handbook
1.3. Scope
This Policy applies to all employees, officers, directors, and appointed agents (Including Introducing Brokers) of Vertex. Failure to comply with this Policy may result in disciplinary action and criminal prosecution.
2. Governance and Oversight
2.1. Board of Directors
The Board has ultimate responsibility for the Company's AML/CFT compliance. The Board approves this Policy and ensures that adequate resources (technology and human capital) are allocated to combat financial crime.
2.2. MLRO
The Company has appointed a designated Money Laundering Reporting Officer (MLRO) and Deputy MLRO approved by the FSC. They receive internal disclosures, decide on STR filings, and liaise with the FSC and FIU.
2.3. Compliance Officer
The Compliance Officer is responsible for day-to-day implementation, including management of our technological compliance stack (Sumsub and InTouch) and conducting regular audits.
3. Risk-Based Approach (RBA)
Vertex applies a Risk-Based Approach to compliance. We do not treat all clients equally; resources are focused where the risks are highest.
3.1. Risk Scoring
Every client is assigned a Risk Score (Low, Medium, High) upon registration. This score is calculated dynamically based on:
Residency in jurisdictions identified by the FATF as high-risk or non-cooperative.
Legal entity structure, occupation, and political exposure (PEP status).
High-volume cryptocurrency deposits or complex ownership structures.
3.2. Technology Integration
We utilize InTouch intelligence data to automate this risk scoring process, ensuring that risk ratings are updated in real-time as global sanctions lists or client circumstances change.
4. Know Your Customer (KYC) & Due Diligence
Vertex utilizes Sumsub as its primary technology partner for identity verification. We generally do not accept physical documents via email; all verification is conducted digitally to ensure authenticity.
4.1. Standard Due Diligence (SDD)
For low-to-medium risk Retail Clients, we apply SDD measures:
Identification & Verification Process
Collection of Full Name, Residential Address, Date of Birth, and Nationality.
Automated OCR and forensic analysis of a Government-issued ID (Passport, National ID, Driver's License) to detect forgeries or tampering.
A 3D facial scan to confirm the applicant is a real human and matches the photo on the ID (preventing deepfakes and spoofing).
Verification via utility bill, bank statement, or Sumsub Geolocation services (where strictly regulated).
4.2. Enhanced Due Diligence (EDD)
For High-Risk clients, Politically Exposed Persons (PEPs), or clients from high-risk jurisdictions, EDD is mandatory. This includes:
- Source of Funds (SoF): Evidence showing the origin of the specific funds being deposited (e.g., bank statement showing salary, sale of property).
- Source of Wealth (SoW): Evidence showing how the client accumulated their total wealth over time.
- Senior Management Approval: The account cannot be activated without written sign-off from the Compliance Officer.
5. Screening and Sanctions (InTouch)
Vertex integrates InTouch to perform rigorous screening of all clients and beneficial owners against global watchlists.
5.1. Sanctions Screening
Before account activation and on a daily ongoing basis, all client databases are screened against:
5.2. PEP Screening
InTouch screens for Politically Exposed Persons (PEPs), their family members, and close associates.
- Domestic PEPs: Subject to EDD.
- Foreign PEPs: Subject to EDD and enhanced monitoring.
- International Organization PEPs: Assessed on a risk basis.
5.3. Adverse Media
The system scans global news outlets for negative press involving the client (e.g., allegations of fraud, arrest records). Positive hits are reviewed manually by the Compliance Team.
6. Transaction Monitoring
Monitoring is continuous. Vertex employs automated systems to detect suspicious patterns in trading and financial activity.
6.1. Red Flags
The system generates alerts for behavior such as:
Multiple deposits just below reporting thresholds.
Rapid deposit and immediate withdrawal request without significant trading activity (indicative of layering).
Attempting to use the brokerage account as a bank account to transfer funds between different payment methods.
Trading volume that is inconsistent with the client's declared income or Source of Wealth.
6.2. Crypto-Specific Monitoring
For deposits made via USDT/USDC, we utilize blockchain analytics to screen the source wallet. If funds originate from "Mixers," Darknet Markets, or Sanctioned Addresses, the deposit will be rejected and frozen pending investigation.
7. Reporting of Suspicious Transactions
7.1. Internal Reporting
Any employee who suspects money laundering must immediately file an Internal Disclosure Report to the MLRO. Failure to report is a criminal offence.
7.2. External Reporting (STR)
If the MLRO determines that the suspicion is substantiated, they must file a Suspicious Transaction Report (STR) with the Financial Intelligence Unit (FIU) via the goAML platform.
- Timing: The STR must be filed as soon as is reasonably practicable.
- Tipping Off: It is a criminal offence to inform the client or any third party that an STR has been filed or that an investigation is underway. Vertex enforces strict "No Tipping Off" protocols.
Warning: Tipping off a client or third party about an STR filing or investigation is a criminal offence under Mauritius law.
8. Record Keeping
In accordance with the FIAMLA 2002, Vertex maintains records of:
- All KYC/CDD documentation (ID copies, Sumsub reports, InTouch screening results).
- All Transaction records (Deposits, Withdrawals, Trade History).
- All Internal and External STRs.
8.1. Retention Period
Records are retained for a minimum of seven (7) years from the date the business relationship ends or the transaction is completed.
8.2. Format
Records are stored digitally in a secure, retrievable format (Fynxt CRM/Cloud Storage) and are available to the FSC or FIU upon request.
9. Training and Awareness
9.1. Employee Training
All employees undergo initial AML/CFT training upon hiring and refresher training at least annually. Training covers:
- • Recognizing Red Flags
- • The use of Sumsub and InTouch tools
- • Reporting procedures and Tipping Off
9.2. Testing
The Compliance Officer conducts annual testing to ensure staff understanding of the AML obligations.
End of AML/CFT Policy • Vertex1 Brokers Limited