European and national AML/CFT requirements apply to a wide range of companies and entities across various sectors, including investment firms such as JustMarkets. The purpose of this document is to describe main AML (Anti-Money Laundering) and CFT (Combating the Financing of Terrorism) principles that the Company adheres to according to the existing AML policy and procedures.

AML Policy

JustMarkets diligently upholds AML/CFT principles, preventing any actions aimed at facilitating the legalization of unlawfully acquired funds and utilization of Company’s services for other illicit activities. In pursuit of these objectives, our Company has implemented a stringent AML Policy and procedures for detecting, preventing, and promptly notifying relevant authorities of any suspicious activities. The Company is bound by strict regulations and is prohibited from informing clients if law enforcement agencies have been alerted to their activities.

To fortify our defences against money laundering, JustMarkets does not accept or disburse cash under any circumstances.

We retain the right to suspend any client operation that is considered suspicious, either due to its illegality or its association with money laundering, as determined by our dedicated staff. Our commitment to these measures underscores our unwavering dedication to maintaining the integrity of our services and safeguarding against financial misconduct.

Procedures

JustMarkets verifies the authenticity of individuals and legal entities with a thorough commitment to compliance with applicable laws and regulations set by relevant authorities. Our adherence to the AML principles includes, but is not limited to, the following measures:

• Client identification and due diligence
• Monitoring of Clients’ activities
• Recordkeeping and its updates

Client identification and due diligence

In alignment with our dedication to AML policies the company is not allowed to maintain anonymous accounts and has to conduct due diligence and verification of the identity of its clients, including the verification of the beneficial owner. When dealing with natural persons or legal entities established in countries identified as a high-risk of crime and corruption or in the other circumstances of High Risk clients, the Company shall apply enhanced due diligence measures including, but not limited, to the following:

• Obtaining information on source of funds and/or wealth
• Requires that first payment is made through a credit or financial institution that operates in EEA area
• Requesting documents certified as true copies

Natural person

During registration each Client provides personal information and information for constructing the economic profile. For the purposes of identify verification the Client should provide full page colour scan copy in high resolution of the following documents:

• government issued identification document that contains name, date of birth, photo, expiration date, signature (International Passport, EU national ID card)
• document for the proof of residence dated within the last 6 (six) months confirming the residence address of the person indicated in the application (Utility bill, Bank statement)

The image of the document must be a photo image or scan copy in high resolution without blurs/ light reflections/ shadows, free of watermarks or modifications and with all information clearly readable.

The above are general guidelines and the Company may request additional or subsequent documentation, information or measures, including but not limited to:

• to verify bank card used to deposit funds
• to provide source of funds

Legal person

For identification and verification purposes at minimum the following documentation and information must be obtained by the Company:

• Certificate of Incorporation
• Certificate of Good Standing or Incumbency Certificate (up to 6 months)
• Certificate of Registered Office or Incumbency Certificate
• Memorandum and Articles of Association or Incumbency Certificate
• Document confirming the authorised representatives of the Company – Directors and persons authorised to operate the specific business relationship
• Certificate of Shareholders
• Information about ownership structure and beneficial ownership
• Taxpayer number and tax residence country
• Description of business (including business start date, products or services offered, principal place of business, number of staff etc)
• Contact details of the legal entity and its authorized person

The Company may request further information and documentation at its own discretion.

Monitoring of Clients’ activities

The Company is required to have a full understanding of the normal and reasonable account activity of its clients and have controls and means of identifying suspicious transactions which fall outside the regular activity, are complex or unusual, or without obvious economic purposes and rationale. In addition to collecting information from our clients, JustMarkets maintains continuous monitoring of each client’s activity to detect and mitigate any potentially suspicious transactions and to prevent the use of its services for any illicit activity, including trading or financial fraud.

Furthermore, JustMarkets reserves the right to request additional information from clients if suspicions arise or if an investigation into their activities reveals any form of illicit or prohibited conduct.

Deposit and Withdrawal

The company adheres to the following principles when handling deposits and withdrawals:

• In all instances the identity of the payment account owner must correspond to the owner of the trading account, which means that:
• • We do not accept deposits from third parties.
  • Withdrawals from a Client’s trading account are permitted only to accounts that are owned by the same person.
• When using electronic payment systems, fund withdrawals from the trading account are only permissible through the same system and account that was initially used for the deposit.
• If funds have been credited to a trading account via multiple payment systems, withdrawals will be proportionate to the size of each deposit. Any profits earned can be transferred to the account from which the corresponding deposit originated, provided that such a transfer is feasible.
• If the account was credited in a manner incompatible with fund withdrawal, the funds can be withdrawn to the client’s bank account or through an alternative method as agreed with the Company.
• If the payment account initially used for deposit becomes inaccessible, the Company reserves the right to withdraw funds to an alternative account specified by the Client subject to the account ownership verification. If an account is inaccessible due to closure, written confirmation from the responsible institution stating the reasons for the account closure is necessary.

Additional guidelines for deposit and withdrawal procedures can be found in the Client Agreement (Terms And Conditions) and subsequent Deposit Canceling and Refund Policy.

Recordkeeping and its updates

As part of its monitoring procedures the Company should ensure that the information and documentation obtained for the client identity and economic profile remain completely updated through the business relationship. However, it is the client’s responsibility to inform the Company about any changes in information provided to the Company.

Failure or refusal by the Client to submit timely updated and/or valid information and/or documentation may conclude in the termination of the business relationships by the Company.

All records obtained from clients are kept for 5 years from the date the relationship terminates or from the date of last transaction.