Anti-Money Laundering Policy

The process of money laundering can be divided into three sequential stages:

• Placement. At this stage, funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once; this form of placement is called smurfing.
• Layering. Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered;
• Integration. Funds get back into circulation as legitimate to purchase goods and services.

IUX adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim to facilitate the process of legalizing illegally gained funds. This Policy is meant to prevent the use of the Company’s services by criminals, with the aim of money laundering, terrorist financing, or other criminal activity.

To prevent money laundering, the Company at its sole discretion, reserves the right to suspend any Client’s operation, which we believe or reasonably believe is in any way related to illegal activities or may be related to money laundering activities. IUX shall also neither accept nor pay cash under such circumstances. 

Company Procedures

IUX will make sure that it is dealing with a real person or legal entity. IUX also performs all the required measures in accordance with applicable laws and regulations issued by monetary authorities. The AML policy is being fulfilled within IUX by means of the following:

• Identifying and verifying the identity of each client;
• Identifying and verifying the identity of the ultimate beneficial owner; 
• Obtaining information on the purpose and intended nature of the business relationship;
• Undertaking ongoing due diligence;
• Monitoring of Client activity;
• Verifying that the documents, data or information are genuine and reliable;
• Record keeping.

In the case where IUX identifies that the Client provided us with any false or stolen identification documentation or information, we shall reserve and exercise the following rights as we deem appropriate:

• Request the submission of accurate and factual documents or information; or
• Refrain from opening an account, commencing a business relationship, or performing a transaction, or
• Terminate the business relationship and the client’s existing account.

If the Company reasonably believes that the transaction is in any way connected or related to illegal activities, we shall reserve the right to refuse to process such a transaction at any time.

Know Your Customer and Customer Due Diligence

The Company must establish and verify the identity of any customer for whom it acts or proposes to act. The Company reserves its right to perform Customer Due Diligence in the following circumstances:

• When establishing a business relationship;
• when there is a change in the identification information/beneficial ownership of the Customer;
• when there is a suspicion of money laundering or terrorist financing; or
• When there are doubts about the veracity or adequacy of documents, data, or information previously obtained for customer due diligence.

Because of the company’s commitment to the AML laws and regulations, each Client of the Company has to finish a verification procedure. Before IUX starts any cooperation with the Client, the Company ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any Client or counterparty are taken. The Company as well applies heightened scrutiny to Clients, who are residents of other countries, identified by credible sources as countries with inadequate AML standards or that may represent a high risk for crime and corruption, and to beneficial owners who reside in and whose funds are sourced from named countries. IUX doesn’t prescribe the period of time for submitting documents, and the KYC documents will be checked within 24 hours. The Client acknowledges that the process shall be carried out not beyond 2 business days. 

The Company reserves the right to reject any Client’s account registration if the Client fails to meet the conditions set forth by the Company or is assessed as posing an extreme risk. This decision shall be made at the Company’s sole discretion, based on its risk assessment protocols and in compliance with applicable legal and regulatory requirements.

Individual clients

IUX is obligated by law to confirm and verify the identity of each person who registers on our system and opens an account with us. During the process of registration, each client is required to provide personal information, specifically:

• full name; 
• date of birth; 
• country of origin; and 
• complete residential address. 

The following documents are required in order to verify the personal information. The Client sends the following documents (in case the documents are written in non-Latin characters: to avoid any delays in the verification process, it is necessary to provide a notarized translation of the document in English) because of the requirements of KYC and to confirm the indicated information:

• Current valid passport (showing the first page of the local or international passport, where the photo and the signature are clearly visible); or
• Driving license, which bears a photograph; or
• National identity card (showing both front and back pages);
• Documents proving the current permanent address (such as utility bills, bank statements, etc.) containing the client’s full name and place of residence. These documents should not be older than 3 months from the date of filing.

Clients hereby affirm and undertake that they are aligned with all the conditions, as set out below;

• Clients must be capable of legally binding themselves to the contract under the laws applicable in their country of residence; 
• Clients must be at full age under the laws applicable in their country of residence; 
• Client must have a sound mind; 
• Clients must have full capacity to enter into the Transaction(s) and to exercise their rights and obligations; 
• Clients have not been sanctioned for financial crime reasons, violation of IUX policy, and/or abuse of IUX service;
• All the documentation and information provided to IUX during onboarding process are truthful, accurate, and complete; 
• Clients have verified and ensured that their utilization of our online trading facility does not violate any laws or regulations of any jurisdiction that applies to them.

Corporate clients

Upon opening an account with IUX, if the Client is a legal person and none of the principal directors or shareholders already has an account with IUX, the following documentation must be provided:

• Certificate of Incorporation or any national equivalent;
• Memorandum and Articles of Association and statutory statement or any national equivalent;
• Company registry search, including confirmation that the person is not in the process of being dissolved, struck off, wound up or terminated;
• Latest audited financial statements or equivalent;
• Annual report or equivalent;
• Certificate of good standing or other proof of registered address of the company;
• Resolution of the board of directors to open an account and confer authority on those who will operate it;
• Copies of powers of attorney or other authorities given by the directors in relation to the company;
• Proof of identity of directors in case he/she will deal with IUX on behalf of the Client (according to the Individual identity verification rules described above);
• Proof of identity of the beneficial owner(s) and/or the person(s) on whose instructions the signatories on the account are empowered to act (according to the individual identity verification rules described above).

Politically Exposed Person (PEP)

The Client agrees to declare their PEP status and provide copies of documents confirming such status. 

Politically Exposed Person means an individual who has been entrusted with prominent public functions; it also extends to domestic, foreign, and international organizations, their family members, and close associates.

Domestic and Foreign PEPs include

• Head of State and of government (e.g., King, President, and Prime Minister);
• Ministers and deputy or assistant ministers;
• Member of parliament of similar legislative bodies;
• Members of the governing bodies of political parties;
• Senior politicians, senior government, judicial or military officials, and senior executives of state-owned corporations (e.g, appellate courts, supreme courts, constitutional courts);
• Members of courts of auditors or of the boards of central banks;
• Ambassadors, charges d’affairs;
• Important political party officials;
• Other persons or categories of persons as may be specified by the relevant supervisory authority or regulatory body.

International organization PEPS includes

• Members of senior management, such as directors and deputy directors;
• Members of the board or equivalent functions or individuals who have been entrusted with equivalent functions, including directors, deputy directors;
• Members of the board or equivalent functions;
• Other persons or categories of persons as may be specified by the relevant supervisory authority or regulatory body.

Family members and close associates include:

• A spouse;
• A partner;
• Children and their spouses or partners;
• Parents;
• Grandparents and grandchildren; and
• Sibling.

Enhanced Customer Due Diligence

In addition to Customer Due Diligence, the Company reserves the right to request additional documentation or information from the Clients whenever we deem necessary for the ongoing monitoring of their activities. IUX may impose additional due diligence requirements on high-risk clients who meet the following conditions:

• where a higher risk of money laundering or terrorist financing has been identified;
• where, through supervisory guidance, a high risk of money laundering or terrorist financing has been identified;
• where the Client is from a high-risk country as declared by the Financial Action Task Force (FATF) or relevant authorities;
• in relation to cross-border correspondent banking and other similar relationships;
• where the Client is a politically exposed person;
• where the Client was found to provided the Company with false or stolen identification documentation or information, and the Company decided to continue our business relationship;
• in the event of any unusual or suspicious activity; or
• when the clients meet with the condition as specified in the relevant laws and regulations.

 It is understood that the clients are required to provide us with factual and accurate information.

• Occupation:
• Volume of assets;
• Annual income;
• Total cash and liquid assets;
• Intended nature of the business relationship;
• Source of income; and
• Reasons for intended or performed transactions.

Monitoring of client activity

In addition to gathering information from the Clients, IUX continues to monitor the activity of every Client to identify and prevent any suspicious transactions to ensure the regular monitoring of any transactions and other activity carried out as part of the business relationship. IUX has implemented the system to detect, prevent, and monitor the suspicious transactions (both automatic and, if needed, manual) to prevent using the Company’s services by criminals. IUX shall review all Client activities to identify transactions that deviate from the Client’s legitimate business or historical transaction patterns. A suspicious transaction is known as a transaction that is inconsistent with the Client’s legitimate business or the usual Client’s transaction history known from Client activity monitoring. 

Suspicious Transaction Reports (STR)

IUX is responsible for channeling all internal suspicious transaction reports received from the employees. Upon receiving any internal suspicious transaction, we shall submit the STR to the relevant regulatory body, authorities, and Payment Gateway entities to evaluate the grounds of suspicion. Once it is confirmed, the Company shall initiate legal action in compliance with applicable laws and regulations. In case there are no reasonable grounds, we shall document and file the decision. It is understood that IUX is not obliged to notify the client or any person involved in the transaction that the STR has been submitted to the relevant regulatory body, authorities, and Payment Gateway entities. However, if the ground of suspicion has been confirmed and IUX decides to initiate legal action, we shall formally notify the client in writing. In this regard, the Company shall maintain all STRs and any other supporting documentation as confidential except for disclosure required under regulatory and legislative orders of the appropriate supervisory body.

Record keeping

Records must be kept of all relevant records, including any accounts, files, and business correspondence and documents relating to transactions, and information obtained for the purpose of identification and verification, as well as all documents related to money laundering topics (e.g., files on suspicious activity reports, documentation of AML account monitoring, etc.). Those records are kept for a minimum of 7 years after the account is closed. In situations where the records relate to ongoing investigations or transactions that have been the subject of suspicious transaction reporting, they should be retained for a minimum of 7 years after it is confirmed that the case is closed/decided/adjudicated.

Deposit and withdrawal requirements

All deposits and withdrawals on trading accounts held with IUX have the following strict requirements:

• Due to AML / CTF laws, IUX cannot receive or deposit funds to third parties.
• Funds sent to the IUX Market must be from a bank account, credit/debit card, or Alternative Payment Method (Skrill, China Union Pay, Neteller, Fasapay, or others) under the same name as the trading account name with IUX.
• All funds withdrawn from a trading account must go to a bank account, credit/debit card, or Alternative Payment Method (Skrill, China Union Pay, Neteller, Fasapay, or others) under the same name as the trading account name with IUX.
• All withdrawal requests are processed on a First-in-First-Out (FIFO) basis according to the funding source of origination. For example, a deposit is made via debit/credit card, and then a subsequent withdrawal request is received. The amount of funds sent back to the relevant debit/credit card, when a withdrawal request is received, may not exceed the original amount deposited. Any profits made in excess of the deposited amount will be transferred to a nominated bank account, which must be held in the same name as your trading account.

Examples:

1. You deposited $100 via credit card and earned a profit of $1,000. Requesting a withdrawal of $1,000, you will get $100 to your credit card and the rest, $900, to your bank account.
2. You deposited $100 via Skrill and $50 via credit card. Requesting a Skrill withdrawal of $120, you will get $100 to Skrill and $20 to the card.

• All initial withdrawal requests must be verified for safety and security by provision of a bank statement, which includes account holder information and bank details. IUX will not accept deposits or withdrawals made under a different name from the registered IUX.
• If a trading account was credited in a way that cannot be used for funds withdrawal, the funds may be withdrawn to a bank account under the same name as the trading account name with IUX as long as the client provides satisfactory evidence of the ownership of the bank account where the funds originated from as well as the destination bank account.

Measures Taken

In cases of an attempt to execute transactions that IUX suspects are related to money laundering or other criminal activity, it will proceed in accordance with the applicable law and report suspicious activity to the regulating authority. IUX reserves the right to suspend any client’s operation, which can be regarded as illegal or may be related to money laundering in the opinion of the staff. IUX has complete discretion to temporarily block the suspicious client account or terminate an existing client relationship.

Annual Review

IUX is committed to acting in compliance with the relevant AML laws and regulations. To ensure its effectiveness, IUX has a commitment to review its Policy periodically, aiming to implement best practices for preventing the misuse of our services for money laundering and terrorist financing. These reviews and assessments are conducted on a regular basis and at least annually. 

In this regard, IUX reserves the right to review and/or amend its Policy at its sole discretion, whenever it deems fit or appropriate.