AML Policy

This policy applies to all S D STAR FX LTD personnel, designated producers, and the range of products and services offered by S D STAR FX LTD. Every segment and location within S D STAR FX LTD collaborates to create a unified effort against money laundering. Each of these units and locations has established risk-based procedures designed to reasonably prevent, detect, and report suspicious transactions. All endeavors will be thoroughly documented and retained. The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (SARs) and other mandatory reports to relevant law enforcement or regulatory agencies. Any communication from law enforcement or regulatory agencies related to this Policy will be directed to the AML Compliance Committee.

The committee is tasked with:

• • Receiving internal reports of (suspected) money laundering
• • Investigating reports of suspicious events
• • Reporting relevant suspicious events to the appropriate authorities
• • Ensuring the effectiveness of staff and adviser awareness and training arrangements
• • Providing an annual report to the firm's governing body on the performance and efficiency of the firm’s systems and controls.
• • Monitoring the daily operation of anti-money laundering policies in relation to the development of new products, taking on new customers, and changes in the firm’s business profile.

Policy S D STAR FX LTD is committed to actively preventing money laundering and any activity that facilitates money laundering, or the funding of terrorist or criminal activities. S D STAR FX LTD is dedicated to AML compliance in accordance with applicable laws and mandates its officers, employees, and designated producers to adhere to these standards to prevent the use of its products and services for money laundering purposes.

Money laundering, for the purpose of this Policy, generally refers to engaging in actions designed to obscure or conceal the true origins of unlawfully obtained proceeds, making them appear to have legitimate origins or constitute lawful assets.

What is Money Laundering? Money laundering involves the conversion of criminally obtained money or assets (criminal property) into "clean" money or assets with no apparent connection to their criminal origins. Criminal property can take various forms, including money or money’s worth, securities, tangible property, intangible property, or any funds used to support terrorism.

Money laundering activities include:

• • Acquiring, using, or possessing criminal property
• • Handling the proceeds of crimes such as theft, fraud, and tax evasion
• • Involvement in any way with criminal or terrorist property knowingly
• • Engaging in arrangements to facilitate the laundering of criminal or terrorist property
• • Investing the proceeds of crimes in other financial products
• • Investing the proceeds of crimes through the acquisition of property/assets
• • Transferring criminal property

Money laundering encompasses a series of stages, ranging from the initial disposal of proceeds into a bank account (placement) to a sequence of financial transactions to disguise the origin of the cash, making it appear legitimate (layering) and finally allowing criminals to use the funds as they see fit (integration).

Counter-Terrorist Financing (CTF) Terrorist financing refers to legitimate businesses or individuals providing funds for terrorist activities or organizations due to ideological, political, or other reasons. Firms must ensure that their customers are not terrorist organizations themselves and that they are not facilitating funding for terrorist organizations. Terrorist financing may not involve the proceeds of criminal activity, but rather concealing the origin or intended use of funds, which will later be employed for criminal purposes.

Risk-Based Approach A risk-based approach should be employed when determining the level of due diligence required in anti-money laundering procedures. This means allocating resources based on the magnitude of risk posed by a specific relationship.

The risk-based approach includes the following areas:

• • Customer Risk
• • Product Risk
• • Country Risk

Due diligence should match the risk of the product, customer, and country.

Customer Identification Program S D STAR FX LTD has adopted a Customer Identification Program (CIP) that requires collecting minimum customer identification information, recording it, and verifying the information.

Monitoring and Reporting Monitoring will occur within the appropriate business units of S D STAR FX LTD, including transactions aggregating $5,000 or more and transactions where suspicious activity is suspected.

Suspicious Activity Signs of suspicious activity often called 'red flags,' may include unusual concern about the firm's compliance with government reporting requirements, transactions that lack a rational business purpose, and unexplained or sudden extensive account activity.

Reporting a Suspicion Any suspicions regarding money laundering must be reported as soon as possible in writing.

Investigation Upon notification, an investigation will be initiated to determine if a report should be made to law enforcement or regulatory agencies. Investigations will include reviewing available information such as payment history, birthdates, and addresses.

Freezing of Accounts If funds are believed to derive from criminal activity or fraudulent instructions, the account must be frozen.

Language The official language of the Company is English, and clients should refer to the English version of the Company’s Website and terms and conditions for all information and disclosures about the Company. Translations or information in other languages are for informational purposes only and do not have any legal effect. The Company is not responsible for the correctness of information in translated versions.