KYC/AML Policy

Firm Policy

It is the policy of Sri777 LLC (“The Firm”) to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.

Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable BSA regulations and UN rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.

Know-Your-Client (KYC)

We will conduct due diligence during Account opening and from time to time afterwards in order to comply with our “know-your-client” and other legal and regulatory obligations and requirements. You must provide any information or documentation we require (“KYC Requirement”), and provide updates to such information in a timely manner. A non-exhaustive list of the information or documentation we may require from you is your passport or government issued identification document, utility bill, bank statement, proof of residence, qualified referrals, employment verification. Currently, corporations, partnerships, and firms are not allowed on the platform. We have the right to amend this list at any time at our sole and absolute discretion without prior Notice to you.

Anti-Money Laundering and Counter-Terrorist Financing

We implement processes and procedures to comply with Applicable Laws and international standards around AML/CFT, including (but not limited to):

• monitoring transactions for the purpose of identifying suspicious or illegal activity; and
• investigating and reporting suspicious activity in accordance with Applicable Laws.

Sanctions

You are prohibited from opening an Account and/or using any of the Services if you are subject to a sanctions regime (including sanctions administered or enforced by the United Nations or other relevant sanctions authorities), or have received any oral or written notice from any government or regulatory authority targeting you with sanctions, restrictions, penalties, enforcement action or investigation under any Applicable Law (including but not limited to AML/CFT, anti-corruption or economic sanction laws) (a “Sanctioned Person”).

Restricted Jurisdictions

You may not open an Account or use any of the Services if you are a person restricted from using our Services in accordance with our Restricted Jurisdiction Policy or are otherwise restricted from opening an Account and/or using any of the Services as a result of any Applicable Laws (“Restricted Jurisdiction”). We have the right to amend the Restricted Jurisdictions and the Restricted Jurisdictions Policy at any time at our sole and absolute discretion without prior Notice to you.

We may, at our sole and absolute discretion, implement controls to restrict access to the Account and the Services in any of the Restricted Jurisdictions. We may block or geo-block persons located in certain Restricted Jurisdictions from accessing or using the Website, an Account and/or the Services (including the Trading Platform). You acknowledge, agree and understand that if you are located in a Restricted Jurisdiction, you are not permitted to access or use the Website, your Account and/or the Trading Platform, even if you are located there only temporarily or for travel, and restrictions will be applied to your Account accordingly. You acknowledge that this may impact your ability to trade on the Trading Platform or monitor any existing orders or open positions or otherwise use the Services. You must not attempt in any way to circumvent any such restriction, including by use of any virtual private network to obfuscate your location.

Notwithstanding any other provision in these Terms of Service, if we determine that you are accessing the Services or the Trading Platform from any Restricted Jurisdiction, or have given false representations as to your location of incorporation, establishment, citizenship or place of residence, we reserve the right to close your Account or take all appropriate action we deem necessary.

If the jurisdiction of which you are a citizen or in which you are resident, located, incorporated, or otherwise established or based (as applicable) becomes a Restricted Jurisdiction or any change (including any change to Applicable Laws) results in your jurisdiction becoming a Restricted Jurisdictions, without prejudice to any other provision in these Terms of Service, we may immediately cease providing you with access to and use of your Account and the Services.

We are not responsible for any losses which may arise because you are not able to access or use the Website, your Account and/or the Services (including the Trading Platform) at the relevant time because of any action taken.