AML and KYC Policy

1. Introduction

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy (hereinafter referred to as the “Policy”) is established by The Concept Ltd (hereinafter referred to as the “Company”), a corporation duly incorporated and existing under the laws of Saint Lucia, with Registration No. 2025-00084, and having its registered office at: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia.

The purpose of this Policy is to outline the Company’s commitment to complying with all applicable international laws and regulations concerning Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT). The Company is dedicated to preventing its services from being used to facilitate money laundering or terrorist financing activities.

2. Scope

This Policy applies to all officers, employees, and affiliated entities of the Company. It encompasses all products and services offered by the Company and extends to all jurisdictions in which the Company operates.

3. Definitions

For the purposes of this Policy:

• “Money Laundering”: refers to the process by which individuals or entities conceal the origins of illegally obtained money, typically by means involving complex financial transactions, to make it appear legitimate.
• “Terrorist Financing”: involves the solicitation, collection, or provision of funds with the intention that they may be used to support terrorist acts or organizations.
• “Customer Due Diligence (CDD)”: refers to the process of identifying and verifying the identity of the Company’s clients and understanding the nature of the business relationship.

4. Risk-Based Approach

The Company adopts a risk-based approach to AML and CFT compliance. This involves:

• Conducting regular assessments to identify and evaluate potential money laundering and terrorist financing risks associated with its products, services, customers, and geographic locations.
• Implementing appropriate measures and controls to mitigate identified risks, including enhanced due diligence for higher-risk customers and transactions.
• Continuously monitoring and reviewing the effectiveness of these measures and controls, making adjustments as necessary.

5. Customer Due Diligence (CDD)

The Company shall apply CDD measures in the following circumstances:

• Prior to establishing a business relationship with a new client.
• When there is a suspicion of money laundering or terrorist financing, regardless of any exemptions or thresholds.
• When there are doubts about the veracity or adequacy of previously obtained customer identification data.

CDD measures include, but are not limited to:

• Identifying the client and verifying their identity using reliable, independent source documents, data, or information.
• Identifying the beneficial owner(s) and taking reasonable measures to verify their identity.
• Obtaining information on the purpose and intended nature of the business relationship.
• Conducting ongoing due diligence on the business relationship and scrutinizing transactions to ensure consistency with the Company’s knowledge of the client, their business, and risk profile.

6. Enhanced Due Diligence (EDD)

For clients or transactions that are determined to be of higher risk, the Company shall apply Enhanced Due Diligence measures, which may include:

• Obtaining additional information on the client and beneficial owner(s).
• Obtaining additional information on the intended nature of the business relationship.
• Obtaining information on the source of funds or wealth of the client.
• Conducting enhanced monitoring of the business relationship.

7. Ongoing Monitoring

The Company shall perform ongoing monitoring of all business relationships to:

• Ensure that transactions are consistent with the Company’s knowledge of the client and their risk profile.
• Identify any unusual or potentially suspicious activity.
• Maintain up-to-date client information and documentation.

8. Record-Keeping

The Company shall maintain all records obtained through CDD measures, account files, and business correspondence for a minimum of five (5) years following the termination of the business relationship or the completion of an occasional transaction. These records shall be sufficient to permit the reconstruction of individual transactions so as to provide, if necessary, evidence for prosecution of criminal activity.

9. Reporting of Suspicious Activity

Employees are required to report any knowledge or suspicion of money laundering or terrorist financing to the Company’s Compliance Department without delay. The Compliance Department shall evaluate the report and, if appropriate, file a Suspicious Activity Report (SAR) with the relevant authorities in accordance with applicable laws and regulations.

10. Training

The Company shall provide ongoing AML and CFT training to all relevant employees. This training shall cover:

• The legal and regulatory framework for AML and CFT.
• The Company’s policies and procedures related to AML and CFT.
• The identification of suspicious transactions and activities.
• The procedures for reporting suspicious activity.

11. Sanctions Compliance

The Company shall establish and maintain procedures to ensure compliance with all applicable sanctions programs. This includes screening clients and transactions against relevant sanctions lists and taking appropriate action when a potential match is identified.

12. Policy Review and Updates

This Policy shall be reviewed and updated periodically to reflect changes in applicable laws, regulations, and best practices. Any material changes to this Policy shall be communicated to all relevant employees and, where appropriate, to clients.

13. Amendments

The Company reserves the right to amend this Policy from time to time. In the event of a material change, the Company will inform clients by publishing an updated version of this Policy on its website. The latest and prevailing version of the AML & KYC Policy will, at all times, be available at www.theconcepttrader.com.

14. Contact Information

For any further information or clarifications regarding this Policy, please contact the Compliance Department via email at [email protected].

Effective Date: February 14, 2025

Note: This Policy is effective as of February 14, 2025 and supersedes any prior AML & KYC policies issued by the Company.