1. Commitment
Trademore Value Capital is committed to preventing its services and platforms from being used for money laundering, terrorist financing, sanctions evasion, fraud, corruption or other financial crime. We maintain controls designed to support applicable legal, regulatory and partner requirements.
2. Risk-based approach
We assess risk by considering the customer, beneficial ownership, business activity, jurisdiction, products, delivery channel, expected activity and transaction profile. Controls and review depth are proportionate to the assessed risk and may change when new information or activity emerges.
3. Customer due diligence
Before providing access to relevant services, we may verify legal existence, identity, authority, ownership and control, source of funds or wealth where appropriate, intended use, and the nature of the business relationship. Enhanced due diligence may apply to higher-risk relationships, complex structures, politically exposed persons or unusual activity.
4. Sanctions, PEP and adverse-information screening
Customers, beneficial owners, authorized persons and relevant counterparties may be screened against applicable sanctions, politically exposed person and adverse-information sources. A potential match does not determine an outcome by itself; it is reviewed and resolved through documented procedures.
5. Ongoing monitoring and escalation
We may monitor account, payment, trade and platform activity against the expected customer profile and risk indicators. Unusual activity may require clarification, supporting documents, restriction, rejection, internal escalation or reporting to a competent authority where legally required. We do not disclose confidential suspicious activity reporting.
6. Records, training and testing
Relevant customer, review, decision and transaction records are maintained for the period required by applicable obligations. Personnel with relevant responsibilities receive training, and controls may be reviewed or independently tested according to risk and business maturity.
7. Governance and cooperation
Responsibility for financial crime risk is supported by defined roles, escalation channels, access controls and management oversight. We cooperate with authorized regulators, law-enforcement bodies, financial institutions and service partners where lawful and appropriate. Questions about this public policy may be sent to [email protected].