Anti-Money Laundering & Know Your Customer Policy

Nexora's comprehensive AML/KYC compliance framework ensuring the highest standards of financial security and regulatory adherence

1. AML/KYC Overview

Nexora Capital Markets Ltd. is committed to preventing money laundering, terrorist financing, and other financial crimes through robust Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures. This policy outlines our comprehensive approach to compliance with international regulatory standards including FATF recommendations, EU directives, and local jurisdiction requirements.

Policy Objectives

  • Verify the identity of all clients before establishing business relationships
  • Prevent the use of our platform for money laundering or terrorist financing
  • Detect and report suspicious transactions to relevant authorities
  • Maintain compliance with all applicable AML/CFT regulations
  • Protect our business and clients from financial crime exposure
  • Ensure ongoing monitoring and risk assessment of client activities

Compliance First

Full adherence to international AML/CFT standards

24/7 Monitoring

Continuous transaction surveillance and analysis

Data Security

Encrypted storage with comprehensive audit trails

2. Regulatory Framework

Our AML/KYC policy is designed to comply with:

International Standards

  • Financial Action Task Force (FATF) 40 Recommendations
  • EU 4th and 5th Anti-Money Laundering Directives (4AMLD/5AMLD)
  • Basel Committee on Banking Supervision Guidelines
  • Wolfsberg AML Principles for Correspondent Banking

Forex Broker Specific Requirements

  • MiFID II (Markets in Financial Instruments Directive)
  • CySEC (Cyprus Securities and Exchange Commission) requirements
  • FCA (Financial Conduct Authority) compliance standards
  • MetaTrader 5 platform KYC integration requirements

Regulatory Notice

This policy is regularly reviewed and updated to reflect changes in regulatory requirements. All staff members and clients are expected to comply with the latest version available on our website.

3. Know Your Customer (KYC) Procedures

KYC is the cornerstone of our AML compliance program. We implement rigorous identity verification processes for all clients before permitting any trading activity.

3.1 Customer Identification Program (CIP)

Required Documentation for Individual Clients:

✓ Primary Identification Document

  • Valid international passport
  • National ID card
  • Driver's license (government-issued with photo)
  • Must be valid for at least 6 months from submission date
  • Must show: Full name, date of birth, photograph, signature, document number

✓ Proof of Address (dated within 3 months)

  • Utility bill (electricity, gas, water, internet, phone)
  • Bank statement or credit card statement
  • Government-issued correspondence
  • Tax assessment notice
  • Mortgage statement or tenancy agreement

✓ Additional Requirements (when applicable)

  • Source of funds documentation
  • Source of wealth verification
  • Bank card verification (for deposits/withdrawals)
  • Employment verification letter
  • Tax identification number (TIN)

3.2 Corporate Client Verification

Required Documentation for Corporate Entities:

  • Certificate of Incorporation/Registration
  • Memorandum and Articles of Association
  • Extract from Commercial Register (not older than 3 months)
  • Board resolution authorizing account opening
  • Proof of registered business address
  • Ultimate Beneficial Owners (UBO) identification (holding ≥25% ownership)
  • Identity documents for all directors and authorized signatories
  • Organization chart showing ownership structure
  • Business plan and description of trading activities
  • Latest audited financial statements
  • Tax identification documents

3.3 Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to high-risk clients, including but not limited to:

High-Risk Categories:
  • Politically Exposed Persons (PEPs)
  • Family members and close associates of PEPs
  • Clients from high-risk jurisdictions
  • Non-face-to-face clients
  • Cash-intensive businesses
  • Complex ownership structures
EDD Measures Include:
  • Additional identity verification
  • Source of wealth documentation
  • Enhanced transaction monitoring
  • Senior management approval
  • More frequent customer reviews
  • Adverse media screening

3.4 Document Quality Requirements

All submitted documents must meet the following standards:

  • High-resolution color scans or photographs
  • All four corners of the document must be visible
  • No watermarks, stamps, or alterations
  • Text must be clearly legible
  • No glare or shadows obscuring information
  • Original language or certified translation if not in English

Processing Time: KYC verification is typically completed within 24-48 hours. Enhanced Due Diligence cases may require 3-5 business days. Clients will be notified of any delays or additional requirements via email.

4. Anti-Money Laundering Measures

Nexora implements comprehensive AML controls to detect and prevent the three stages of money laundering: Placement, Layering, and Integration.

Stage 1: Placement

The initial entry of illicit funds into the financial system. Criminals may deposit funds in multiple small installments to avoid detection (structuring/smurfing).

Our Controls: Deposit pattern analysis, velocity checks, source of funds verification, and automated structuring detection.

Stage 2: Layering

Complex layers of financial transactions designed to obscure the audit trail and origin of funds. May involve multiple accounts, jurisdictions, or instruments.

Our Controls: Transaction path analysis, circular trading detection, unusual trading patterns monitoring, and cross-border transaction scrutiny.

Stage 3: Integration

Laundered funds re-enter the legitimate economy appearing as legal wealth. The funds are now difficult to distinguish from legitimately acquired assets.

Our Controls: Lifestyle consistency checks, wealth source validation, beneficial ownership verification, and ongoing monitoring of account activity.

4.1 Sanctions & PEP Screening

All clients are screened against:

Sanctions Lists:

  • OFAC (US Office of Foreign Assets Control)
  • EU Consolidated Sanctions List
  • UN Security Council Sanctions
  • HM Treasury (UK) Financial Sanctions
  • National sanctions lists

PEP & Risk Databases:

  • Politically Exposed Persons (PEPs)
  • Adverse media screening
  • Law enforcement watchlists
  • Financial crime databases
  • Terrorism financing lists

Continuous Monitoring: Screening is not a one-time event. All clients are subject to ongoing screening with real-time alerts for any status changes.

4.2 Restricted Jurisdictions

Nexora does not accept clients from the following high-risk jurisdictions:

  • Countries subject to OFAC sanctions (Iran, North Korea, Syria, Cuba, etc.)
  • FATF blacklisted jurisdictions
  • India and United Arab Emirates (regional restrictions)
  • United States (regulatory restrictions)
  • Belgium (regulatory restrictions)
  • Countries under international embargoes

This list is subject to change based on regulatory developments and is reviewed quarterly.

5. Transaction Monitoring

Nexora employs sophisticated automated systems combined with manual oversight to monitor all client transactions in real-time for suspicious patterns and anomalies.

5.1 Automated Monitoring Systems

Red Flag Indicators:

Unusual Transaction Patterns

Sudden spikes in trading volume, deposits inconsistent with client profile, or transactions outside normal behavior patterns

Structuring (Smurfing)

Multiple deposits just below reporting thresholds, designed to avoid detection and regulatory reporting requirements

Round-Tripping

Circular fund movements with no apparent economic purpose, deposits followed immediately by withdrawals

Third-Party Payments

Deposits from or withdrawals to accounts not in the client's name, or payments from unexpected jurisdictions

High-Risk Jurisdictions

Transactions involving countries with weak AML controls, high corruption indices, or known for financial crime

Excessive Chargebacks

Multiple disputed transactions, frequent payment reversals, or patterns suggesting fraud or identity theft

5.2 Risk-Based Transaction Thresholds

Standard Monitoring

  • • Deposits exceeding $10,000 in 24 hours
  • • Cumulative deposits over $25,000 in 30 days
  • • Withdrawals exceeding $15,000 in 7 days
  • • Trading volume 5x above historical average

Enhanced Monitoring (EDD Clients)

  • • Any deposit exceeding $5,000
  • • Cumulative deposits over $15,000 in 30 days
  • • All withdrawal requests reviewed manually
  • • Trading volume 2x above historical average

5.3 Deposit & Withdrawal Controls

Name Matching Requirement

All payment methods must be registered in the client's verified name. Third-party payments are strictly prohibited unless pre-approved with supporting documentation.

Same-Method Withdrawal Policy

Withdrawals must be processed through the same payment method used for deposit, up to the deposited amount. This anti-laundering measure ensures fund traceability.

Example: If $1,000 deposited via Visa, first $1,000 of withdrawal must return to the same Visa card. Profits may be withdrawn via alternative verified methods.

Multiple Payment Method Pro-Rata Rule

When deposits are made via multiple payment methods, withdrawals are processed proportionally to the deposit amounts until all original deposits are returned to their source.

6. Suspicious Activity Reporting (SAR)

When our monitoring systems or staff identify suspicious transactions, we are legally obligated to file a Suspicious Activity Report (SAR) with relevant Financial Intelligence Units (FIUs) and regulatory authorities.

6.1 SAR Triggers

A SAR must be filed when there are reasonable grounds to suspect:

  • Money laundering or terrorist financing activity
  • Attempts to evade AML reporting requirements
  • Transactions with no apparent lawful purpose
  • Client refuses to provide required information
  • Inconsistencies between stated occupation and transaction patterns
  • Use of multiple accounts to fragment transactions
  • Client exhibits unusual concern regarding AML procedures

6.2 SAR Filing Process

1

Detection & Documentation

Suspicious activity identified through automated alerts or manual review. All evidence is collected and documented.

2

Internal Review

Compliance officer investigates and determines if activity meets SAR criteria. Supporting documentation gathered.

3

SAR Submission

Report filed with appropriate authorities within regulatory deadlines (typically 30 days from detection).

4

Ongoing Monitoring

Enhanced monitoring continues. Client may be subject to account restrictions or closure depending on risk assessment.

Tipping Off Prohibition

It is a criminal offense to inform a client that a SAR has been filed regarding their account ("tipping off"). All SAR filings are strictly confidential and protected by law.

7. Risk Management Framework

Nexora employs a risk-based approach to AML compliance, allocating resources proportionate to the level of money laundering and terrorist financing risk.

7.1 Client Risk Assessment

Low Risk

  • • Verified EU/UK residents
  • • Low transaction volumes
  • • Stable employment
  • • Standard CDD applied

Medium Risk

  • • Non-face-to-face onboarding
  • • Moderate transaction volumes
  • • Complex business structures
  • • Enhanced monitoring

High Risk

  • • PEPs and associates
  • • High-risk jurisdictions
  • • Large transaction volumes
  • • EDD mandatory

7.2 Ongoing Due Diligence

Customer due diligence is not a one-time event. We conduct periodic reviews:

  • Low-risk clients: Annual review of KYC documents
  • Medium-risk clients: Semi-annual review and transaction analysis
  • High-risk clients: Quarterly review with enhanced scrutiny
  • Trigger events: Immediate review upon significant changes in client circumstances, transaction patterns, or risk profile

7.3 Independent Audits

Our AML program undergoes annual independent audits by qualified external auditors. Audit findings are reviewed by senior management and the board, with remediation plans implemented for any identified deficiencies. Internal compliance reviews are conducted quarterly.

8. Staff Training & Awareness

Comprehensive Training Program

All employees, officers, and relevant third parties receive mandatory AML/KYC training appropriate to their role and responsibilities.

Initial Training

New employees complete AML training within 30 days of joining, covering regulatory requirements, internal policies, red flag indicators, and reporting procedures.

Ongoing Training

Annual refresher training for all staff, with specialized training for compliance, customer service, and management teams.

Training Topics Include:

  • Money laundering typologies and trends
  • Terrorist financing indicators
  • KYC documentation requirements
  • Transaction monitoring and red flags
  • SAR filing procedures
  • Data protection and confidentiality
  • Sanctions screening obligations

9. Record Keeping & Data Retention

Retention Policy

In compliance with regulatory requirements, Nexora maintains comprehensive records of all AML/KYC activities:

Customer Identification Records

Retained for 5 years after account closure: ID documents, proof of address, source of funds documentation, beneficial ownership information

Transaction Records

Retained for 5 years: All deposits, withdrawals, trades, internal transfers, and payment instructions with full audit trail

Compliance Documentation

Retained for 7 years: SARs, internal investigations, risk assessments, audit reports, training records, correspondence with regulators

Data Security & Privacy

All AML/KYC records are stored securely with:

  • 256-bit AES encryption for data at rest and in transit
  • Access controls limited to authorized compliance personnel
  • Complete audit trails of all data access and modifications
  • Regular security assessments and penetration testing
  • Compliance with GDPR and data protection regulations

For more information, please refer to our Privacy Policy.

Policy Updates & Review

This AML/KYC Policy is reviewed annually or more frequently in response to regulatory changes, emerging risks, or audit findings. The current version is effective as of the date of last update shown on this page.

Last Updated: January 2026 |Version: 2.1

AML Compliance Contact

For questions regarding our AML/KYC procedures, or to report suspicious activity:

Email: compliance@nxorafx.com

General Support: support@nxorafx.com

Phone: +1-758-572-0245 (24/7)

All compliance inquiries are treated confidentially and will be responded to within 2 business days.