ANTI-MONEY LAUNDERING POLICY

At FXM, we comply fully with all anti-money laundering laws and laws concerning the financing of terrorism. We operate on the basis of the recommendations of the FATF (Financial Action Task Force), an international initiative to combat money laundering and terrorism. We want to do our best to abide by these recommendations so that we can do our part to be a good global citizen. Please recognize that we strive to do this efficiently as possible, without compromising the convenience and ease-of-use of our deposit and withdrawal processes. We hope to help you understand our anti-money laundering policy and its importance so that you can understand why we must be thorough in our financial procedures.

Money laundering, the practice of concealing the ownership, origin, destination, or holder of money gained through illegal means, is something that FXM is committed to combating. We have enacted policies that work to fight money laundering, and we will cooperate with any and all applicable laws. After illegally gained cash proceeds are obtained through criminal activity, the proceeds are separated through a series of complex financial transactions. These transactions are intended to hide any audit trail as well as the identity of the money's source. Once the layering is successful, various schemes are employed to return the money to the financial system, appearing as ordinary business funds. FXM is committed to a robust anti-money laundering policy that fights money laundering through the implementation of the policies laid out below.

FXM collects and verifies the personal identification data of our account holders, while logging and tracking itemized statements of all the transactions that are carried out by our clients. Prior to opening an account with FXM, you will need to submit a valid form of government-issued identification: Driver's License, State ID, or Passport; a proof of residence and bank account information is also required, along with your completed account application. Additionally, FXM tracks all suspicious transactions of our clients and transactions executed under non-standard trading conditions.

  • All FXM client funds are held in separate, isolated accounts that are designated only for client deposits and withdrawals.
  • FXM monitors funding from various bank accounts outside of the account holder's home country.
  • FXM performs its actions on the basis of the anti-money laundering framework set forth by the Financial Action Task Force.
  • FXM neither accepts cash deposits nor disburses cash under any circumstances.
  • FXM does not accept third-party deposits of any kind.
  • FXM matches each deposit to the account name on file for that customer.
  • FXM reserves the right to refuse processing a transaction at any stage where it believes the transaction to be connected in any way to money laundering or criminal activity. In accordance with international law, FXM is not obligated to inform the client if suspicious activity is reported to any corresponding regulatory or legal bodies.

ACCOUNT OPENING PROCEDURES - KNOW YOUR CLIENT (KYC) CUSTOMER POLICY

Prior to opening an account, FXM shall document the identity, nature of business, income, source of assets, and investment objectives of each prospective customer.

We welcome clients from all over the globe. However, governmental restrictions, along with our company policies, prohibit FXM from opening accounts originated from the following restricted and/or OFAC sanctioned countries:

Afghanistan

Fiji

Namibia

Angola

Former Yugoslavia

Niger

Belarus

Gambia

Nigeria

Bolivia

Ghana

North Korea

Botswana

Guinea Bissau

Pakistan

Burma (Myanmar)

Guinea Conakry

Senegal

Cambodia

Iran

Sierra Leone

Central African Republic

Iraq

Somalia

Cote d'Ivoire (Ivory Coast)

Kyrgyzstan

Syria

Cuba

Lebanon

Tanzania

Democratic Republic of Congo

Lesotho

Togo

Ecuador

Liberia

Uganda

Eritrea

Libya

Yemen

Ethiopia

Mali

Zimbabwe

United States of America

  

ACCOUNT OPENING REQUIREMENTS AND FRAMEWORK:

Photo ID - The following are acceptable forms of photo identification:

  • A valid passport
  • A valid government ID, such as a Driver's License or State ID
  • A valid National Identity Card

*Please note that all photo IDs are verified through third-party compliance software.

Proof of Residence - The following are acceptable forms of proof of residence:

  • A utility or phone bill, or a bank statement
  • All proof of residences must be current and not outdated by more than 90 days

BANK ACCOUNT REQUIREMENTS

  • All FXM account holders must have a valid bank or credit card account in their name
  • The bank statement should show their name and the same registered address as their application

FUNDS WITHDRAWAL PROCEDURES

The withdrawal process at FXM detailed below, is structured around strict guidelines to make sure that funds are securely sent back to their originating source.

  • FXM customers must complete a signed paper or digital withdrawal request containing their correct account information.
  • The withdrawal form is submitted to the FXM Accounting department for processing. The Accounting department:Confirms the account balanceVerifies that there are no holds or withdrawal restrictions on the accountApproves the withdrawal request, pending approval by the treasury team
  • Confirms the account balance
  • Verifies that there are no holds or withdrawal restrictions on the account
  • Approves the withdrawal request, pending approval by the treasury team
  • The FXM treasury team reviews all withdrawal requests approved by the Accounting department, performing the following:Verifies the original funds are withdrawn via the same method of deposit and to the account holder on fileExamines the withdrawal request against the customer's deposit history to make sure there is no suspicious activityVerifies the bank account on file
  • Verifies the original funds are withdrawn via the same method of deposit and to the account holder on file
  • Examines the withdrawal request against the customer's deposit history to make sure there is no suspicious activity
  • Verifies the bank account on file
  • Withdrawal requests approved by the FXM treasury department are sent back to the accounting department, and the funds are released to the client.
  • In the event that a withdrawal is flagged for suspicious activity, the withdrawal is placed on hold, pending further investigation by FXM management staff.
  • FXM Management partners with the treasury team to see if further action needed and which, if any, relevant regulatory bodies need to be contacted.
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