01 Introduction
ABDFX ("we," "our," or "us") is committed to maintaining the highest standards of integrity and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. This policy outlines our firm commitment to preventing money laundering and terrorist financing activities through our services.
We comply with all applicable AML/CTF laws and regulations in the jurisdictions where we operate, including the Financial Action Task Force (FATF) recommendations and relevant local regulatory requirements.
⚖️ Zero Tolerance
ABDFX has a zero-tolerance policy toward any form of money laundering or terrorist financing activity
FATF Compliant
All operations comply with Financial Action Task Force recommendations and international standards
Continuous Monitoring
Ongoing monitoring of all transactions and client relationships to detect suspicious activity
02 Policy Objectives
The objectives of this AML Policy are clearly defined and actively enforced across all departments and operations:
Prevention
- Prevent money laundering and terrorist financing activities
- Protect the integrity of the financial system
- Block illicit funds from entering our platform
Compliance
- Ensure compliance with applicable AML/CTF laws
- Meet all regulatory reporting obligations
- Align with FATF recommendations and best practices
️ Protection
- Protect ABDFX and our clients from financial crime risks
- Safeguard the company's reputation and licence
- Shield clients from inadvertent involvement in crime
Reporting
- Establish clear procedures for identifying suspicious activities
- Ensure timely reporting to relevant authorities
- Maintain confidentiality of all reported information
03 Risk Assessment
We conduct regular, comprehensive risk assessments to identify and evaluate money laundering and terrorist financing risks associated with our business activities. Risk assessments are reviewed at least annually and whenever significant changes occur.
| Risk Category | Risk Factors Assessed | Risk Level |
|---|---|---|
| Client Risk | Geography, business type, PEP status, transaction patterns, source of wealth | High |
| Product & Service Risk | Leveraged trading, payment methods, account types, withdrawal patterns | Medium |
| Geographic Risk | Client country of residence, fund source country, sanctioned jurisdictions | High |
| Delivery Channel Risk | Online onboarding, third-party payments, remote account opening | Medium |
| Technology Risk | New payment methods, crypto channels, digital wallets | Medium |
| Operational Risk | Staff training gaps, system failures, third-party dependencies | Low - Med |
04 Customer Due Diligence (CDD)
We apply a risk-based approach to customer due diligence, scaling the level of verification to the assessed risk level of each client and relationship:
Identity Verification
Government-issued ID and proof of address confirmed
Beneficial Owner
Identification of all beneficial owners above 25%
Purpose & Nature
Understanding the business relationship and source of funds
Ongoing Monitoring
Continuous review of the relationship and transactions
4.1 Standard CDD
Applied to all clients at account opening and throughout the relationship:
- Verification of client identity using reliable, independent document sources
- Identification and verification of beneficial owners where applicable
- Understanding the nature and purpose of the business relationship
- Ongoing monitoring of the business relationship and transactions
4.2 Enhanced Due Diligence (EDD)
Additional scrutiny is applied to higher-risk clients and relationships:
Politically Exposed Persons (PEPs)
Senior approval required, source of wealth verification, ongoing enhanced monitoring
High-Risk Jurisdictions
Clients from FATF grey/black-listed countries or sanctioned regions face additional checks
Complex Ownership Structures
Full corporate structure mapping required before account approval is granted
Unusual Transaction Patterns
Clients displaying atypical behaviour are subject to immediate enhanced review
4.3 Simplified Due Diligence (SDD)
Reduced verification may apply for certain lower-risk clients where permitted by regulation, subject to ongoing monitoring and periodic review to ensure the risk profile remains acceptable.
05 Transaction Monitoring
We implement comprehensive automated and manual transaction monitoring systems to detect suspicious activities in real time and retrospectively:
Unusual transaction patterns or volumes inconsistent with the client's stated profile
Transactions that are inconsistent with the client's known business or personal activities
Rapid movement of funds in and out with little or no trading activity
Complex, structured, or layered transactions with no apparent economic purpose
Transactions involving jurisdictions identified as high-risk or sanctioned by FATF
Multiple small deposits structured to remain below reporting thresholds (smurfing)
Third-party deposits or withdrawals not matching the account holder's details
Sudden unexplained changes in trading activity, deposit amounts, or withdrawal frequency
Our transaction monitoring system uses rule-based and AI-assisted algorithms to flag suspicious patterns in real time. All flagged transactions are reviewed by our dedicated compliance team within 24 - 48 hours.
06 Suspicious Activity Reporting
All employees are trained to identify and report suspicious activities. When suspicious activity is detected, the following process is followed without delay:
Detection
Internal Report
Assessment
SAR Filing
Confidentiality
- Immediate reporting to the Compliance Officer upon detection of suspicious activity
- Full documentation of all relevant details, evidence, and transaction records
- Assessment of whether a Suspicious Activity Report (SAR) is required under applicable law
- Filing of SARs with the relevant Financial Intelligence Unit (FIU) or authority when necessary
- Strict maintenance of confidentiality - no "tipping off" of clients under investigation
It is a serious criminal offence to tip off a client or any third party that a suspicious activity report has been filed or that they are under investigation. All employees must strictly observe this prohibition.
07 Record Keeping
We maintain comprehensive, secure records in strict accordance with regulatory requirements. All records are stored securely and accessible to authorised personnel and regulators upon request:
| Record Type | Retention Period | Format |
|---|---|---|
| Client Identification & Verification Documents | 7 years from account closure | Encrypted digital & physical |
| Transaction Records | Minimum 5 years from transaction date | Encrypted digital |
| CDD & EDD Documentation | 7 years from end of relationship | Encrypted digital |
| Suspicious Activity Reports (SARs) | 7 years from date of filing | Restricted access, encrypted |
| Employee Training Records | 5 years from completion | Digital HR system |
| Compliance Reports & Risk Assessments | 7 years | Encrypted digital |
| Sanctions Screening Results | 7 years | Automated system logs |
08 Employee Training
All ABDFX employees receive mandatory AML/CTF training. Training is role-specific, regularly updated, and completion is tracked and recorded:
Onboarding Training
All new employees complete AML/CTF induction before commencing client-facing duties
Annual Refresher
Mandatory yearly refresher training covering regulatory updates, case studies, and procedure changes
Role-Specific Training
Tailored modules for compliance, operations, sales, and technology teams based on their exposure
Regulatory Updates
Prompt briefings issued to all staff when material regulatory changes or typologies are identified
Red Flag Recognition
Practical training on identifying suspicious behaviours, transactions, and client patterns
Non-Compliance Consequences
Clear communication of disciplinary and legal consequences for failure to comply with AML obligations
09 Compliance Officer
ABDFX has designated a qualified and experienced Compliance Officer (CO) who holds overall responsibility for the AML/CTF programme:
Compliance Officer - ABDFX
For all AML-related inquiries, suspicious activity reports, or compliance questions: compliance@abdfx.com
10 Sanctions Compliance
ABDFX maintains strict compliance with all applicable international sanctions programmes and screening obligations:
Regular Screening
All clients and transactions are screened against current international sanctions lists
Transaction Blocking
Transactions involving sanctioned individuals, entities, or jurisdictions are immediately blocked
Authority Reporting
All blocked transactions are reported to relevant authorities as required by applicable law
System Updates
Sanctions screening systems are updated in real time as new designations are published
Sanctions Lists Monitored
UN Sanctions
United Nations Security Council consolidated sanctions list
EU Sanctions
European Union consolidated list of sanctioned persons and entities
OFAC / SDN
US Office of Foreign Assets Control Specially Designated Nationals list
UK Sanctions
His Majesty's Treasury financial sanctions implementation list
FATF Lists
FATF high-risk and other monitored jurisdictions - grey and black lists
Local Regulators
Applicable local and regional regulatory sanction and watch lists
11 Third-Party Relationships
We conduct rigorous due diligence on all third-party relationships, including technology providers, payment processors, and business partners:
Initial Due Diligence
- Assessment of third-party AML/CTF controls and policies
- Review of regulatory status and compliance history
- Sanctions and adverse media screening
Contractual Requirements
- AML/CTF compliance obligations embedded in all contracts
- Right to audit third-party compliance controls
- Breach notification and termination provisions
Ongoing Monitoring
- Regular review of third-party relationships and performance
- Periodic re-assessment of the relationship risk profile
- Prompt action on any identified compliance deficiencies
Reliance on Third Parties
- Where third-party CDD reliance is permitted, formal agreements in place
- Ultimate responsibility for AML compliance remains with ABDFX
- Records obtained from third parties retained per policy
12 Regulatory Reporting
ABDFX maintains open, transparent, and proactive communication with all relevant regulatory authorities:
Timely Submissions
All required regulatory reports, returns, and filings are submitted accurately and on time
Regulatory Cooperation
Full cooperation with all regulatory inquiries, audits, and examinations without delay
Prompt Notification
Material compliance issues are reported to relevant authorities promptly upon identification
Regulatory Updates
Regular monitoring of regulatory developments to ensure our controls remain current and effective
13 Policy Review and Updates
This AML Policy is reviewed and updated on a regular basis to ensure it remains current, effective, and compliant:
Annual Review
Full policy review conducted annually by the Compliance Officer and senior management
Triggered Review
Immediate review triggered by regulatory changes, significant incidents, or new business activities
✅ Effectiveness Testing
Regular testing of AML controls to ensure they function as intended and remain proportionate
Lessons Learned
Integration of lessons from internal incidents, regulatory feedback, and industry typologies
Best Practices
Continuous alignment with evolving FATF guidance and industry best practice standards
Staff Communication
All material policy updates are promptly communicated to relevant staff with updated training where required
14 Contact Information
For questions about this AML Policy, to report suspicious activities, or for any compliance-related inquiries, please contact us:
⚖️ Compliance Officer
compliance@abdfx.comFor AML policy and compliance inquiries
General Support
support@abdfx.comFor general account and service support
Phone Support
+1 (800) 000-0000Available during business hours
Registered Address
Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia
If you suspect any suspicious activity or have concerns about potential money laundering or terrorist financing, please report it immediately to our Compliance Officer at compliance@abdfx.com. Your cooperation is essential to maintaining the integrity of our financial system and protecting all clients.