AML Policy

Anti-Money Laundering and Counter-Terrorist Financing Compliance

Last Updated: January 1, 2025

1. Introduction

ThorForex ("the Company") is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. We have established a comprehensive AML framework in accordance with international standards and applicable laws and regulations. This policy outlines our commitment to detecting, preventing, and reporting money laundering and terrorist financing activities.

2. Scope and Applicability

This AML Policy applies to all operations, employees, and clients of ThorForex. It covers all products and services offered by the Company, including but not limited to Forex and CFD trading. We are committed to ensuring that our services are not used to disguise illicit funds or finance illegal activities.

3. AML Compliance Officer

The Company has appointed an AML Compliance Officer responsible for overseeing the implementation and enforcement of this policy. The AML Compliance Officer has the authority to make decisions regarding client acceptance, transaction monitoring, and reporting of suspicious activities. Contact details for the AML Compliance Officer are available upon request.

4. Customer Due Diligence (CDD)

We conduct thorough due diligence on all clients before establishing a business relationship. This includes:

  • Identification and Verification: Collecting and verifying government-issued identification (passport, national ID, driver's license), proof of address (utility bill, bank statement), and other relevant documents.
  • Beneficial Ownership: Identifying the ultimate beneficial owners of corporate clients and understanding the ownership and control structure.
  • Purpose of Account: Understanding the intended nature and purpose of the business relationship.

We apply Enhanced Due Diligence (EDD) for higher-risk clients, such as politically exposed persons (PEPs) or clients from high-risk jurisdictions.

5. Ongoing Monitoring

We continuously monitor client transactions and account activity to detect unusual or suspicious patterns. Monitoring includes:

  • Reviewing transactions against expected activity profiles.
  • Identifying complex, unusually large, or abnormal transaction patterns.
  • Updating client information and risk assessments periodically.

6. Suspicious Transaction Reporting

If the Company suspects or has reasonable grounds to suspect that funds are the proceeds of criminal activity or related to terrorist financing, we will file a Suspicious Activity Report (SAR) with the relevant financial intelligence unit (FIU) promptly. All employees are required to report any suspicious activity to the AML Compliance Officer immediately.

7. Record Keeping

We maintain all records related to client identification, transaction data, and SARs for at least five years (or longer as required by local regulations). These records are securely stored and accessible only to authorized personnel.

8. Risk-Based Approach

We adopt a risk-based approach to AML compliance. This means we allocate resources and apply controls proportionate to the level of risk posed by a client, product, or geographic area. Higher-risk scenarios receive enhanced scrutiny and due diligence.

9. Employee Training

All employees receive regular training on AML/CTF policies, procedures, and regulatory obligations. Training covers how to recognize red flags, reporting mechanisms, and the consequences of non-compliance. We maintain records of training sessions and attendance.

10. Compliance with Sanctions

We screen all clients and transactions against international sanctions lists (e.g., OFAC, UN, EU). We do not establish relationships with individuals or entities appearing on such lists, and we block any transactions that may violate sanctions.

11. Prohibition on Anonymous Accounts

We do not permit anonymous or numbered accounts. All clients must be properly identified and verified before accessing our services. We also prohibit transactions with shell banks or unregulated financial institutions.

12. Confidentiality

All information related to AML compliance, including SAR filings, is treated as confidential and is shared only on a need-to-know basis with relevant authorities or as required by law.

13. Independent Audit

The Company's AML program is subject to periodic independent audits to assess its effectiveness and compliance with applicable laws. Audit findings are reported to senior management and the Board of Directors.

14. Contact Information

If you have any questions about our AML Policy or wish to report suspicious activity, please contact us:

ThorForex
International Financial Centre, 8th Floor
London, United Kingdom
Email: aml@thorfx.com
Phone: +1 234 567 890