Anti-Money Laundering

The policy is based on management of compliance risks arising from customers.

Effective date： October 10, 2023

Definition

Some financial institutions implement all necessary measures based on applicable laws and regulations issued by regulatory authorities. The plan must include at least internal policies, procedures, and controls to prevent, detect, and report suspicious activities, designate compliance officers, and internal audits to test compliance. NS YTL has implemented such a plan to the extent necessary.

Money laundering refers to any transaction or series of transactions involving the concealment or disguise of the nature, source, or ownership of proceeds derived from illegal activities, including drug trafficking, terrorism, organized crime, fraud, and many other crimes. The predicate offenses for money laundering are defined by local laws.

Policy statement

The NS YTL Anti-Money Laundering (AML) policy aims to prevent money laundering by fulfilling legislative obligations, including the need for appropriate systems and control measures to mitigate the risk of the company being used to facilitate financial crime. Non-compliance with this policy may result in disciplinary action against NS YTL or its affiliated company employees, including termination.

This anti-money laundering policy sets out minimum standards to be complied with, including：

  • Appointing a Money Laundering Reporting Officer (MLRO) with sufficient qualifications and independence responsible for overseeing compliance with relevant laws, regulations, rules, and industry guidance.
  • Establishing and maintaining a risk-based approach (RBA) to assess and manage the company’s money laundering and terrorist financing risks.
  • Establishing and maintaining risk-based customer due diligence, identification, verification, and Know Your Customer (KYC) procedures, including enhanced due diligence for those customers with higher risks (such as Politically Exposed Persons (PEP)).
  • Establishing and maintaining systems and procedures based on risk to monitor ongoing customer activity.
  • Establishing and maintaining systems and procedures based on risk to monitor ongoing customer activity.
  • Procedures for reporting suspicious activities internally and, where appropriate, reporting to relevant law enforcement authorities.Maintaining appropriate records for the minimum prescribed period.
  • Providing training and awareness to all relevant staff members.

Customer identification

Prior to opening a trading account for a customer, the company ensures that the customer has provided all necessary information and completed the identity verification process. NS YTL Limited notifies them to seek identity, collect certain minimum customer identification information from each customer, record such information, and verify methods and results.

All new applications must provide the following information：

  • Name
  • Date of birth
  • Residential and business addresses
  • Passport number and issuing country
  • NS YTL will record customer verification information, which may be stored electronically or in hard copy for a period of time as required by law, including all identity information provided by the customer, methods used, and verification results, including but not limited to matching signatures of designated producers with photos provided by the customer.

Suspicious transactions

Suspicious transactions are those that lack a business or apparent lawful purpose, and are unusual for the customer or lack any reasonable explanation.

Monitoring and reporting

Monitoring based on transactional behavior will be conducted within the relevant departments of NS YTL. Monitoring of specific transactions will include, but not be limited to, transactions totaling $5,500 or more and transactions where NS YTL has reason to suspect suspicious activity. All reports will be documented.

Deposits and withdrawals

NS YTL has established strict requirements for customer transaction account deposits and withdrawals.

Only customers verified through identity verification are allowed to provide funds for transaction accounts. These methods include bank wire transfers, payment cards, etc. NS YTL requires all deposits (matching the name of the original customer) to match the customer name in our records. Third-party payments are not accepted.

Our compliance system

NS YTL declares that, in order to comply with anti-money laundering policies, transfers made by company clients can only be used for transaction operations that generate profits within the scope of services provided by the company. If any transfer is found to be associated with criminal activities or money laundering, NS YTL reserves the right to refuse processing the transfer at any stage.

Our employees undergo educational training to ensure that we have the necessary capabilities to combat money laundering and other financial crimes. We may refuse withdrawals and request further information to verify whether the requester of the withdrawal is the genuine account holder. All actions taken by the company to prevent, detect, and reduce money laundering and terrorist financing are conducted in accordance with international anti-money laundering laws, as well as specific recommendations and methodologies relevant to the remittance and currency exchange sector, including the appointment of a compliance officer, preparation of policies and procedures, and regular reviews of their effectiveness.

This material is intended for information purposes only, and does not constitute investment advice, a recommendation or an offer or solicitation to purchase or sell any securities, funds or strategies to any person in any jurisdiction in which an offer, solicitation, purchase or sale would be unlawful under the securities laws of such jurisdiction. The opinions expressed are subject to change without notice. Reliance upon information in this material is at the sole discretion of the reader. Investing involves risks.