Anti-Money Laundering Policy

01Objective

The primary objective of this policy is to establish a robust system to prevent any money laundering activities through Trade5, and to identify, monitor, and report any suspicious transactions to the appropriate regulatory authorities.

"Know Your Customer" (KYC) is the guiding principle behind Trade5's Anti-Money Laundering (AML) measures. By implementing adequate policies, practices, and procedures, Trade5 ensures high ethical and professional standards, preventing the platform from being used, intentionally or unintentionally, by criminal elements.

These measures enable Trade5 to thoroughly understand its customers, beneficial owners, and their financial dealings, effectively managing risks. Trade5's management is fully committed to compliance with all relevant legal requirements and undertakes periodic reviews of these policies.

02Regulatory Requirements & Principal Officer

Trade5 shall designate a Principal Officer responsible for ensuring the proper discharge of all legal requirements. The Principal Officer's duties include:

• Ensuring compliance with all applicable AML guidelines and regulations.
• Acting as a central reference point for the identification and assessment of potential suspicious transactions.
• Ensuring Trade5 discharges its legal obligations to report suspicious transactions to the concerned authorities.

Customer Due Diligence (CDD)

Trade5 enforces a strict CDD process, which includes:

• Obtaining sufficient information to identify the actual beneficial owner of the account or the person on whose behalf transactions are conducted.
• Verifying the customer's identity using reliable, independent source documents, data, or information.
• Conducting ongoing due diligence and scrutiny to ensure transactions are consistent with the client's background, financial status, and risk profile.

03Client Identification (KYC)

Before opening any account with Trade5, the following measures must be taken:

• Conduct in-person or complete online KYC verification of the client.
• Identify beneficial ownership and control to determine the individuals who beneficially own or control the account.
• Collect and verify information regarding the client's background, occupation, and introducer (if any).
• Collect certified copies of valid documents showing permanent address, current address, tax identification (e.g., PAN or local equivalent), nature of occupation, financial status, and a recent photograph.

04KYC Updating Process

• Periodic Updates. Corporate clients are required to submit their annual reports to Trade5 every year. Individual clients will receive their master details periodically to confirm, revise, or provide updated information regarding their occupation and financial income.
• Non-Compliance. No account shall be opened — and existing accounts may be suspended — if the client refuses or is unable to follow the KYC requirements.
• Inconsistencies. Trade5 will actively follow up with clients if inconsistencies are found in their information until the client corrects them or provides reasonable proof.
• Reporting. Failure by a prospective client to provide satisfactory evidence of identity will be reported to the Principal Officer.

05Client Categorization

Each client is categorized into three risk levels: High Risk, Medium Risk, and Low Risk.

• Risk Parameters. Categorization is based on the nature of business activity, trading turnover, manner of making payments, and overall risk perception.
• High-Risk Clients. Includes specific high-net-worth individuals, trusts, charities, and companies with close family shareholdings. These clients require more frequent KYC updates and stringent monitoring.
• Low-Risk Clients. Generally includes clients who make payments on time and engage in standard, transparent delivery of assets.

06Transaction Monitoring & Suspicious Reporting

• Monitoring Standard Activity. Trade5 actively monitors accounts to understand the normal activities of each client, enabling the rapid identification of deviations.
• Suspicious Transactions. Any unusual activity compared to past transactions, sudden activity in dormant accounts, unusually large transactions, or complex patterns with no apparent economic purpose will be flagged.
• Reporting. All identified suspicious transactions will be reported to the appropriate regulatory enforcement authorities as laid down by applicable law. Trade5 ensures the retention of all related records as legally mandated.

07Risk Management & Internal Audit

• Risk-Based Approach. Trade5 utilizes a risk-based approach for the mitigation and management of identified AML risks, continuously monitoring and enhancing policies as necessary.
• Compliance & Audit Role. The compliance team exercises strict due diligence during onboarding. Trade5 maintains a system of concurrent audits to check KYC compliance, generate exception reports, monitor dormant client codes, and ensure staff awareness.

08Employee Training

Trade5 mandates ongoing employee training programs to ensure all staff members are fully aware of AML procedures and regulatory amendments. Training focuses on customer support, back-office, compliance, risk management, and onboarding staff. This ensures they understand the rationale behind AML obligations and remain vigilant against the platform being misused by unscrupulous elements.