KYC and Anti-Money Laundering

KYC and Anti-Money Laundering (AML) Policy

Comprehensive KYC and Anti-Money Laundering (AML) Policy

Version: July 2025

1. Commitment Statement

Scap Broker LTD (“the Company”), registered in Saint Lucia (Number 2024-00126), reaffirms its absolute commitment in the fight against money laundering, terrorist financing, and other financial crimes. Our policy complies with international best practices, including the recommendations of the FATF, the Financial Intelligence and Anti-Money Laundering Act (FIAMLA), and the guidelines of the Financial Services Commission of Saint Lucia and other relevant jurisdictions.

2. Policy Objectives

Prevent the use of the Company’s services for illicit activities.
Protect the integrity and reputation of the Company and its clients.
Comply with all applicable AML/CFT and KYC laws and regulations.
Fully cooperate with regulatory and enforcement authorities.

3. Compliance Structure

AML/KYC Compliance Officer: Accountable to senior management and the board, authorized to implement, update, and supervise the policy.
Compliance Committee: Includes representatives from legal, internal audit, and operations, responsible for periodic review and key decision-making.
Training: All staff receive mandatory annual AML/KYC training, including updates on new threats and regulations.

4. Principles and Procedures

4.1. Customer Identification and Verification (KYC)

Natural Persons:

Valid official ID (passport, ID card, driver’s license).
Recent proof of address (maximum 3 months).
Proof of ownership of payment methods (bank statement, card).
Selfie or video call for biometric verification (where applicable).

Legal Entities:

Certificate of incorporation and registration.
Articles of association and list of shareholders/ultimate beneficiaries.
Identification of legal representatives and beneficial owners.
Proof of address of the company and its representatives.

High-Risk Clients:

Enhanced due diligence, including source of funds, bank references, and ongoing monitoring.

4.2. Monitoring and Detection of Suspicious Activities

Automated and manual monitoring of unusual or structured transactions.
Periodic review of international sanction lists (OFAC, UN, EU, etc.).
Immediate reporting of suspicious activities to competent authorities.
Prohibition of anonymous accounts or unidentified third parties.

4.3. Record Keeping

All client and transaction documents and records are kept for at least 5 years after the end of the business relationship.
Records include: identification, supporting documents, transaction history, suspicious activity reports, and relevant communications.

4.4. Restrictions and Prohibitions

Opening accounts for persons under 18 is not allowed.
Prohibition of dealings with high-risk or sanctioned jurisdictions.
Cash deposits or transfers from dubious sources are not accepted.

4.5. Update and Audit

Annual review of policy and procedures.
Independent internal and external audits at least once a year.
Immediate updates upon regulatory changes or detection of new threats.

5. Red Flags

Clients avoiding providing information or submitting false documents.
Transactions lacking economic or commercial logic.
Frequent or large movements without clear justification.
Use of multiple accounts or intermediaries without apparent reason.
Transfers to/from high-risk jurisdictions.

6. Responsibility and Legal Disclaimer

Disclaimer:
Scap Broker LTD implements robust KYC and AML policies and procedures in compliance with current regulations and international best practices. However, the Company does not guarantee that all money laundering or terrorist financing attempts can be detected or prevented, given the evolving and sophisticated nature of such activities. The Company will not be held liable for losses, damages, or penalties resulting from illicit activities carried out by clients who provided false, incomplete, or fraudulent information, or who circumvented controls using undetectable methods at the time of the transaction. The client acknowledges and accepts that it is their responsibility to provide truthful and complete information, and that any omission or falsehood may lead to immediate termination of the business relationship and notification to the relevant authorities.