Anti-Money Laundering & Know Your Customer Policy

1. Introduction

DB Finser is committed to the highest standards of anti-money laundering (AML) compliance and requires its management and employees to adhere to these standards in preventing the use of its services for money laundering or terrorist financing purposes.

This policy outlines the framework that DB Finser has established to ensure compliance with all applicable laws and regulations regarding AML and Counter-Terrorist Financing (CTF). The objective is to prevent DB Finser from being used, intentionally or unintentionally, by criminal elements for money laundering or terrorist financing activities.

2. Regulatory Framework

DB Finser operates under strict regulatory supervision and complies with:

• Financial Action Task Force (FATF) Recommendations
• International Money Laundering Abatement and Anti-Terrorist Financing Act
• EU Fourth and Fifth Anti-Money Laundering Directives
• All applicable local regulations in jurisdictions where we operate

DB Finser maintains a comprehensive compliance program that includes regular risk assessments, ongoing employee training, independent audits, and the appointment of a designated Money Laundering Reporting Officer (MLRO).

3. Customer Identification Program

DB Finser implements a risk-based approach to customer identification and verification. Customers may begin trading with limited verification, but full verification is required for higher transaction volumes and access to all services.

3.1 Minimum Verification Requirements

For basic trading access with limited capital:

• Full legal name
• Email address
• Country of residence
• Date of birth

3.2 Full Verification Requirements

To access full trading capabilities and higher capital limits:

For Individual Clients:

• Government-issued photo identification (passport, national ID, driver's license)
• Proof of residential address (utility bill, bank statement dated within last 3 months)
• Source of funds documentation
• Occupation and employment information

For Corporate Clients:

• Certificate of incorporation/registration
• Memorandum and Articles of Association
• List of directors and beneficial owners (with identification for all)
• Proof of registered business address
• Resolution authorising account opening

4. Ongoing Customer Due Diligence

Customer due diligence is an ongoing process. DB Finser conducts continuous monitoring of all customer accounts and transactions to:

• Ensure transactions are consistent with the customer's known legitimate business activities
• Identify unusual or suspicious patterns of activity
• Update customer information regularly
• Monitor politically exposed persons (PEPs) and high-risk jurisdictions
• Re-verify customer identity when necessary

4.1 Enhanced Due Diligence

Enhanced due diligence measures are applied to higher-risk customers, including:

• Politically Exposed Persons (PEPs) and their families/close associates
• Customers from high-risk jurisdictions
• Customers engaged in high-risk business activities
• Customers with unusual transaction patterns

5. Transaction Monitoring

DB Finser employs sophisticated automated monitoring systems complemented by manual review processes to detect suspicious activities.

5.1 Red Flag Indicators

• Unusual transaction patterns inconsistent with customer profile
• Rapid movement of funds without apparent business purpose
• Transactions with high-risk jurisdictions
• Structuring transactions to avoid reporting thresholds
• Inconsistent trading behaviour
• Use of multiple accounts to obscure ownership

5.2 Reporting Obligations

DB Finser is obligated to report:

• Suspicious Activity Reports (SARs) to relevant authorities
• Currency Transaction Reports as required by local regulations
• International Funds Transfer Reports
• Regulator notifications as required by law

6. Record Keeping

DB Finser maintains comprehensive records in accordance with regulatory requirements:

All records are maintained in secure, encrypted systems with appropriate access controls. Records are available for regulatory inspection as required by law.

7. Employee Training

All DB Finser employees receive comprehensive AML/CTF training, including:

• Initial comprehensive AML/CTF orientation for new employees
• Annual refresher training on regulatory updates and requirements
• Specialised training for compliance officers and relationship managers
• Case studies and red flag recognition exercises
• Reporting procedures and escalation protocols

8. Sanctions Compliance

DB Finser maintains strict compliance with all applicable international sanctions programs. Our sanctions compliance program includes:

• Real-time screening against global sanctions lists
• Immediate blocking of prohibited transactions
• Mandatory reporting of blocked transactions to relevant authorities
• Regular updates to sanctions screening systems

9. Customer Responsibilities

Customers of DB Finser have the following responsibilities:

• Provide accurate and complete identification information
• Update information promptly when circumstances change
• Cooperate with ongoing due diligence requests
• Report any suspicious account activity immediately
• Understand that failure to comply may result in account restrictions or closure
• Use the trading account only for legitimate trading purposes