1. PURPOSE

‍The purpose of this Anti-Money Laundering (AML) and Know Your Customer (KYC) policy is to outline FHXMarkets Ltd.'s commitment to preventing money laundering, terrorist financing, fraud, and other financial crimes in compliance with applicable legal and regulatory requirements.This policy is designed to ensure that all users of our platform are properly identified, transactions are monitored for suspicious activities, and the integrity of our services is upheld. By implementing robust AML and KYC procedures, FHXMarkets Ltd. aims to foster a secure and transparent environment for all users and stakeholders.

‍2. INTRODUCTION

‍At FHXMarkets Ltd., we are dedicated to adhering strictly to international trade standards, complying with relevant legislation to combat money laundering and counter-terrorism financing. Our Compliance Department monitors adherence to these requirements, ensuring all processes meet FATF recommendations and internal AML/KYC standards. This policy is mandatory for all employees, officers, directors, and third-party agents involved in financial transactions, customer onboarding, and account management.The Compliance Department ensures:

• Document Verification: All client documentation is accurate, current, and compliant with applicable legal standards.
• Standardization with International AML Protocols: All company operations consistently meet global anti-money laundering requirements.
• Mandatory Compliance: All employees, customers, and third-party agents must adhere to these AML/KYC standards.

3. KNOW YOUR CUSTOMER RULES FOR CLIENTS

3.1 Adherence to KYC PolicyAt FHXMarkets Ltd., we prioritize the security and integrity of our platform and comply with mandatory Know Your Customer (KYC) verification requirements. All clients must provide the following documentation:Individuals:

• Government-issued ID
• Proof of address
• Selfie

Businesses:

• Certificate of incorporation or registration
• Directors’ ID and proof of address
• Ownership structure and UBO information

FHXMarkets Ltd. may request additional documents or a KYC questionnaire at its discretion. Clients agree to provide any requested information promptly.

‍3.2 Submission of Documents; Process and LevelsClients must submit required documents during registration or upon request to access full services. Failure to provide complete information may result in limited access or denial of services.Clients must also keep their information accurate and current and notify FHXMarkets Ltd. of any updates.FHXMarkets Ltd. uses a multi-tiered verification process:

‍3.2.1 Default Level – Registered

‍Basic registration required.

‍3.2.2 Level 1 – VerifiedDocuments required:

• Proof of Identity (Passport, National ID, Driving License, Residence Permit, plus selfie)
• Proof of Address (Utility bill, bank statement, or government-issued document not older than 3 months)

Access: Basic trading features and withdrawals.

‍3.2.3 Level 2 – Verified+Documents required:

• Proof of Funds (Bank statements, income proof, or lawful source-of-funds documentation)

Access: Higher limits and extended features.

‍3.3 RISK ASSESSMENTFHXMarkets Ltd. categorizes clients as low, medium, or high risk based on:

• Nature of business
• Country/geographic risk
• Transaction patterns

3.3.1 Nature of the BusinessFHXMarkets Ltd. evaluates industry risks and may apply Enhanced Due Diligence (EDD) where required.

‍3.3.2 Country/Geographic RiskFHXMarkets Ltd. follows FATF and international guidance to evaluate jurisdiction risk. Services may be restricted for high-risk jurisdictions.

‍3.3.3 Transaction PatternsMonitoring includes:

• Baseline behavior
• Detection of unusual or suspicious patterns
• Automated alerts
• EDD for suspicious activities
• Filing STR/SAR reports where required

3.4 CLIENT CATEGORIZATIONFHXMarkets Ltd. applies CDD and EDD based on risk level:

• Low-risk clients (review every 2 years)
• Medium-risk clients (review every 2 years)
• High-risk clients (review annually)

4. ANTI-MONEY LAUNDERING (AML) MEASURES

4.1 Transaction MonitoringFHXMarkets Ltd. uses automated and manual systems to detect:

• Unusual patterns
• Threshold breaches
• Structuring or layering

Clients may be contacted for clarification or documents.

‍4.2 Internal Review ProcessSteps: initial assessment → EDD → escalation if necessary.

‍4.3 Reporting Suspicious ActivitiesFHXMarkets Ltd. files STR/SAR reports when needed.

‍4.4 Information SharingFHXMarkets Ltd. may share information with authorities or financial institutions as required by law, in accordance with data protection regulations (including GDPR).Records are retained for at least 5 years.

‍5. CLIENT OBLIGATIONS TO PREVENT ILLICIT ACTIVITIES

‍Client obligations include:

1. Compliance with laws and prevention of illicit activity
2. Verification of the origin of funds
   • FHXMarkets Ltd. may investigate, suspend, or close accounts if suspicious activity is detected
3. Prohibition of third-party funding
4. Restricted jurisdictions
   • FHXMarkets Ltd. does not serve FATF-blacklisted jurisdictions and does not accept U.S. persons

6. SUSPICIOUS ACTIVITY MONITORING AND ACCOUNT RESTRICTIONS

‍FHXMarkets Ltd. may:

• Refuse suspicious transactions
• Restrict or suspend accounts
• Request information
• Not disclose internal AML/CFT procedures to clients
• Pursue legal action when appropriate

7. POLICY SCOPE AND COMPANY DISCRETION

1. Policy as a Framework:This policy outlines FHXMarkets Ltd.’s AML/KYC standards. Internal procedures may expand upon or modify these guidelines.‍
2. Integration with Client Agreement: Compliance with this policy is mandatory. Failure to comply may result in immediate termination of the business relationship at the discretion of FHXMarkets Ltd.

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