Anti-Money Laundering & Counter-Terrorist Financing Policy (AML/CFT)

1. Introduction

Foxtreme Markets (“the Company”), registered in Mauritius as a Global Business Company (GBC), provides forex brokerage services. We are committed to maintaining the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) compliance in line with:

  • The Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA),
  • The Financial Services Commission (FSC) AML/CFT Handbook, and
  • The Financial Action Task Force (FATF) Recommendations.

This policy sets out the framework for preventing money laundering and terrorist financing within Foxtreme Markets.

2. Objectives

The objectives of this policy are to:

  • Prevent the use of Foxtreme Markets for money laundering or terrorist financing.
  • Ensure compliance with Mauritius and international AML/CFT regulations.
  • Safeguard the Company’s integrity, reputation, and financial stability.
  • Provide employees with clear AML/CFT guidance and responsibilities.

3. Scope

This policy applies to:

  • All directors, officers, and employees of Foxtreme Markets,
  • Contractors and agents acting on behalf of the Company,
  • All products, services, and customers of Foxtreme Markets.

4. Governance & Responsibilities

  • Board of Directors: Holds ultimate responsibility for AML/CFT compliance.
  • Money Laundering Reporting Officer (MLRO): Responsible for implementing AML procedures, reviewing suspicious activities, and filing Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit (FIU).
  • Compliance Officer: Assists the MLRO in monitoring compliance.
  • Employees: Must follow this AML Policy, complete training, and report any suspicious activity to the MLRO.

5. Risk-Based Approach (RBA)

Foxtreme Markets applies a risk-based approach by assessing risks based on:

  • Geography – high-risk countries/jurisdictions,
  • Customer type – Politically Exposed Persons (PEPs), legal entities, or trusts,
  • Product/Service risk – forex trading products, payment methods,
  • Transaction profile – unusual or high-value activities.

High-risk clients are subject to Enhanced Due Diligence (EDD).

6. Customer Due Diligence (CDD)

The Company conducts CDD on all customers before establishing a business relationship.

  • Individuals:
    • Government-issued identification,
    • Proof of residential address (utility bill, bank statement),
    • Selfie verification (where applicable).
  • Corporate Clients:
    • Certificate of incorporation,
    • Company constitution and licenses,
    • Identification of Directors and Ultimate Beneficial Owners (UBOs),
    • Proof of registered office.
  • Ongoing Monitoring: All clients are continuously monitored for unusual activities.

7. Enhanced Due Diligence (EDD)

EDD is applied in situations such as:

  • Politically Exposed Persons (PEPs),
  • Clients from high-risk jurisdictions,
  • Unusually large or complex transactions.

EDD may require additional identity verification, proof of source of funds, and senior management approval.

8. Transaction Monitoring

Foxtreme Markets employs automated and manual transaction monitoring systems to detect red flags such as:

  • Multiple rapid deposits/withdrawals without trading activity,
  • Transactions structured to avoid reporting thresholds,
  • Use of third-party accounts or unusual payment methods.

Suspicious activities are promptly reviewed by the MLRO.

9. Reporting Obligations

Foxtreme Markets complies with mandatory reporting obligations:

  • Suspicious Transaction Reports (STRs) are submitted to the FIU Mauritius.
  • Threshold Reporting: All cash transactions equal to or exceeding MUR 500,000 (~USD 11,000) are reported.
  • Employees must report suspicious transactions immediately to the MLRO.

10. Record Keeping

The Company retains:

  • Customer KYC documentation,
  • Transaction records,
  • Internal and external communications,
  • Suspicious activity investigations.

All records are kept for at least 7 years from the end of the business relationship.

11. Sanctions & Screening

Foxtreme Markets screens all customers against:

  • United Nations Sanctions List,
  • OFAC (US Office of Foreign Assets Control),
  • EU and UK Sanctions Lists,
  • FSC watchlists and advisories.

Any match results in account freezing, reporting, and regulatory notification.

12. Training & Awareness

  • All employees undergo AML/CFT training at onboarding and annually thereafter.
  • Training includes updates on regulatory requirements, internal procedures, and case studies.

13. Internal Controls & Audit

  • The MLRO ensures effective internal controls are in place.
  • Independent audits are conducted annually to evaluate AML/CFT measures.
  • The Board reviews compliance reports and policy effectiveness.

14. Disciplinary Measures

Failure to comply with this policy may result in:

  • Internal disciplinary action,
  • Suspension or termination of employment,
  • Reporting to relevant authorities.

15. Policy Review

This AML/CFT Policy will be reviewed:

  • At least annually,
  • Upon regulatory changes,
  • Or when significant operational changes occur.