Anti-Money Laundering Policy

Who we must identify, what we monitor, what we are obliged to report — and why we sometimes cannot explain a restriction.

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Legal
TEMPLATE — review with counsel. An AML/CFT policy is a regulated document whose required content is set by the firm’s own supervisory regime and by national transposition of the applicable anti-money-laundering directives. It must name the firm’s Money Laundering Reporting Officer, state its actual retention periods and reflect its real risk assessment. This is a structural placeholder and must be completed, approved by compliance and adopted by the board before publication.

Our position

Premium FX Ltd operates a risk-based anti-money-laundering and counter-terrorist-financing programme. We are legally obliged to know who our clients are, to understand the source of the funds they trade with, and to report suspicion. These obligations sit above our commercial interest in opening an account, and we will decline or close a relationship where we cannot satisfy them.

Client due diligence

  1. Identify the clientFull legal name, date of birth, nationality and residential address, verified against government-issued identity documents and a recent proof of address.
  2. Verify before tradingVerification must be complete before a withdrawal can be released. We do not operate accounts for anonymous or unverified holders.
  3. Understand the source of fundsWhere the amount or pattern of deposits warrants it, we ask for evidence of how the money was earned or accumulated.
  4. Screen against sanctions and PEP listsEvery applicant is screened at onboarding and re-screened on an ongoing basis against sanctions, terrorism and politically-exposed-person data.
  5. Apply enhanced measures where requiredHigher-risk relationships — including politically exposed persons and clients connected to higher-risk jurisdictions — receive additional scrutiny and senior sign-off.

What we monitor

Third-party funding

Deposits must come from an account in the client’s own name. Payments from or to a third party are never processed.

Deposit-and-withdraw patterns

Funding an account and withdrawing with little or no trading in between is a recognised laundering typology and is investigated.

Inconsistent activity

Trading volume or deposit size materially out of line with the client’s stated circumstances triggers review.

Payment-method churn

Repeated changes of card or bank account, particularly across jurisdictions, are examined.

Reporting, and what we cannot tell you

Where we form a suspicion of money laundering or terrorist financing we are required to submit a report to the relevant financial intelligence unit. We are prohibited by law from informing the client that such a report has been made, and from any act that might prejudice an investigation. If an account is restricted for this reason we may be unable to explain why — that silence is a legal requirement, not evasiveness.

Record keeping

Identification records, transaction records and communications are retained for the minimum period required by the applicable regulation after the end of the relationship — typically several years. This obligation overrides a request for erasure, as explained in our privacy policy.

Governance and training

The programme is owned by a named Money Laundering Reporting Officer with direct access to the board, reviewed at least annually and after any material change in the firm’s risk profile. All staff receive AML training at induction and periodically thereafter, and the programme is subject to independent audit.

What we ask of you

Keep your details current, respond to document requests promptly, and fund your account only from a payment method in your own name. Most delays in onboarding and withdrawal come from documents rather than from decisions.