Anti-Money Laundering (AML) Policy

01Money Laundering

The process of converting funds received from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that appear legitimate, in order to hide or distort the actual source of the funds.

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

Placement

Any withdrawal of funds, from your Zenexo FX account to a bank account, can only be refunded to the same bank account that the funds were originally received from or any other bank account under the client’s individual name. Please note that the processing time of withdrawals to reach your bank account substantially depends on the currency of the bank account, as well as the location and the internal policies and procedures of the recipient’s financial institution and country. Therefore, please expect the amounts withdrawn to be credited to your bank account within 2 to 7 business days.

Layering

The funds are transferred or moved to other accounts and other financial instruments. This is done to disguise the origin and interrupt the indication of the entity that carried out the multiple financial transactions. Moving funds and changing their form makes it difficult to track the money that is being laundered.

Integration

The funds are re-circulated as legitimate to purchase goods and services. Zenexo FX adheres to the principles of Anti-Money Laundering and actively prevents any action that targets or facilitates the legalization process of illegally obtained funds. The AML policy means preventing the use of the Company’s services by criminals, with the objective of money laundering, terrorist financing or other criminal activity.

02Our Commitment

To prevent money laundering, Zenexo FX does not accept or pay in cash under any circumstances. The Company reserves the right to suspend the operation of any client which may be considered illegal or, in the opinion of the staff, related to money laundering.

As part of its company procedures, Zenexo FX will ensure that a client is a real or legal person. Zenexo FX also performs all the necessary measures in accordance with the applicable laws and regulations issued by the monetary authorities.

03How the AML Policy Is Met

The AML policy is met within Zenexo FX by the following means:

• Know Your Customer policy and due diligence
• Monitoring of customer activity
• Registry maintenance

04Know Your Customer (KYC)

Due to the Company’s commitment to AML and KYC policies, each Company customer must complete a verification procedure. Before Zenexo FX initiates any cooperation with the client, the Company ensures that satisfactory evidence is presented, or other measures are taken, that produce satisfactory proof of the identity of any client or counterparty.

The Company also applies increased scrutiny to clients who are residents of countries identified by credible sources as having inadequate AML standards, or who may pose a high risk of crime and corruption, and to beneficial owners who reside in — and whose funds are sourced from — such countries.

Individual clients

During the registration process, each client provides personal information, specifically: full name; date of birth; country of origin; and full residential address. The following documents are required to verify personal information (where documents are written in non-Latin characters, a notarized translation of the document into English must be provided to avoid delays in the verification process):

• A valid passport (showing the first page of the local or international passport, where the photo and signature are clearly visible); or
• A driving licence with photograph; or
• A national identity card (showing the front and back); and
• Documents proving the current permanent address (such as utility bills, bank statements, etc.) containing the customer’s full name and place of residence. These documents should not be older than 3 months from the filing date.

Corporate clients

In the event that the applicant company is listed on a recognized or approved stock exchange, or where there is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps will normally be taken to verify the identity. Where the company is not listed and none of the main directors or shareholders already has an account with Zenexo FX, the following documentation must be provided:

• Certificate of incorporation or any national equivalent;
• Memorandum and Articles of Association and statutory declaration, or any national equivalent;
• Certificate of good standing or other proof of the company’s registered address;
• Resolution of the board of directors to open an account and grant authority to those who will operate it;
• Copies of powers of attorney or other authorities granted by the directors in relation to the company;
• Proof of the identity of the directors, in case they deal with Zenexo FX on behalf of the client (in accordance with the individual identity verification rules described above);
• Proof of identity of the final beneficiary/beneficiaries and/or the person(s) under whose instructions the signatories of the account are empowered to act (in accordance with the individual identity verification rules described above).

05Tracking Customer Activity

In addition to collecting customer information, Zenexo FX continues to monitor the activity of each customer to identify and prevent any suspicious transactions. A suspicious transaction is a transaction that is not consistent with the legitimate business of the customer, or with the transaction history of the customer as known through the tracking of customer activity. Zenexo FX has implemented a transaction-monitoring system (both automatic and, if necessary, manual) to prevent criminals from using the Company’s services.

06Registry Maintenance

Records must be kept of all transaction data and data obtained for identification purposes, as well as all documents related to money-laundering issues (e.g. suspicious-activity reporting files, AML account monitoring documentation, etc.). Those records are kept for a minimum of 7 years after the account is closed.

07Measures Taken

In cases of an attempt to execute transactions that Zenexo FX suspects are related to money laundering or other criminal activity, it will proceed in accordance with applicable law and report the suspicious activity to the regulatory authority.

Zenexo FX reserves the right to suspend the operation of any client which may be considered illegal or which may be related to money laundering in the opinion of the staff. Zenexo FX has full discretion to temporarily block a suspicious customer’s account or to terminate a relationship with an existing customer.

08Contact

For more information you can contact us at support@zenexofx.com.