AML Policy

Anti-Money Laundering (AML) Policy

1. Introduction and Purpose

This Anti-Money Laundering (AML) Policy sets forth the principles and procedures adopted by Prime Trade Ltd. (“the Company”) to prevent and detect money laundering, terrorist financing, and other financial crimes.

The Company is committed to compliance with the Money Laundering (Prevention) Act of Saint Lucia, the Financial Intelligence Authority (FIA) guidelines, and international standards, including the Financial Action Task Force (FATF) Recommendations.

The purpose of this policy is to ensure that all employees, directors, and associates act in accordance with applicable laws and uphold the highest standards of transparency, integrity, and accountability.

2. Scope

This policy applies to:

  • All employees, officers, and directors of Prime Trade Ltd.
  • All clients, counterparties, and business partners engaging with the Company.
  • All financial activities conducted through the Company’s platform, including deposits, withdrawals, transfers, and trading transactions.

Compliance with this policy is mandatory and forms a core part of the Company’s operational and regulatory framework.

3. Definition of Money Laundering and Terrorist Financing

Money Laundering (ML): The process of concealing the origin of funds derived from criminal activities to make them appear legitimate.

Terrorist Financing (TF): The act of providing, collecting, or moving funds, whether from lawful or unlawful sources, intending to support terrorist acts.

Both ML and TF present legal, operational, and reputational risks to financial institutions, including Prime Trade Ltd.

4. Regulatory Framework

Prime Trade Ltd. operates under the jurisdiction of Saint Lucia and adheres to:

  • The Money Laundering (Prevention) Act, Cap. 12.20
  • The Counter-Terrorism Act
  • Guidelines issued by the Financial Intelligence Authority (FIA)
  • International AML/CFT best practices, including the FATF 40 Recommendations

The Company maintains continuous engagement with regulatory authorities and submits reports as legally required.

5. Customer Due Diligence (CDD) / Know Your Customer (KYC)

Before establishing a business relationship, the Company conducts due diligence to verify client identities and assess potential risk.

5.1 Identification Requirements

Clients are required to provide:

  • Full legal name
  • Date of birth (for individuals) or incorporation details (for entities)
  • Valid government-issued identification (passport, national ID, or company registration documents)
  • Proof of address (utility bill, bank statement, or official document)
  • Declaration of source of funds, where applicable

5.2 Enhanced Due Diligence (EDD)

Enhanced procedures are applied to:

  • Politically Exposed Persons (PEPs)
  • Clients from high-risk countries or sectors
  • Transactions of unusually large size or frequency

The Company reserves the right to decline or terminate relationships that pose significant AML/CFT risk.

6. Transaction Monitoring and Reporting

All client transactions are monitored to detect suspicious or unusual activity, including:

  • Unexplained large or rapid fund movements
  • Transactions inconsistent with the client’s known profile
  • Activities suggestive of layering or structuring of funds

Employees must report any suspicious activity to the Money Laundering Reporting Officer (MLRO) (currently To Be Appointed) immediately.

The MLRO is responsible for:

  • Assessing reports and determining potential AML/CFT violations
  • Filing Suspicious Activity Reports (SARs) with the FIA
  • Maintaining confidentiality and ensuring employees do not “tip off” clients or third parties

7. Record Keeping

All client identification records, transaction logs, and internal reports must be retained for at least five (5) years following the termination of the client relationship or completion of the transaction.

Records must be securely stored and readily available for regulatory review upon request.

8. Training and Awareness

The Company provides regular AML/CFT training to all employees to ensure they can:

  • Identify suspicious transactions
  • Follow reporting procedures correctly
  • Stay updated on regulatory changes and emerging risks

Training programs will be documented, reviewed, and updated annually.

9. Compliance Officer / MLRO

The Company appoints a Money Laundering Reporting Officer (MLRO) — currently To Be Appointed — responsible for:

  • Implementation and enforcement of this AML Policy
  • Liaising with the Financial Intelligence Authority
  • Reviewing employee compliance and maintaining records
  • Conducting periodic risk assessments and internal policy reviews

10. Internal Controls and Policy Review

The Company conducts regular audits and reviews to ensure the effectiveness of AML controls.

This AML Policy will be reviewed at least annually, or whenever significant changes occur in legislation, regulations, or business operations.

Non-compliance with this policy may result in disciplinary action, termination, or legal consequences in accordance with applicable law.

11. Conclusion

Prime Trade Ltd. is committed to a robust AML/CFT culture and preventing the misuse of its platform for illicit purpose

Adherence to this policy supports the global fight against money laundering and terrorist financing while protecting the integrity, reputation, and operational stability of the Company.