ANTI-MONEY
LAUNDERING POLICYANTI- MONEY LAUNDERING POLICY
Notesco Limited (operating under the trade name “FXGiants”) is a company incorporated under
the laws of Bermuda, with registration number 51491 (hereinafter “the Company” or “We” or“Our”).
The Company encourages at all times high standards of business and personal conduct. For thispurpose, the Company sets the appropriate anti- money laundering framework to detect any riskof failure by the Company to comply with its obligations and puts in place adequate measures andprocedures designed to minimise such risks pursuant to the international anti- money laundering
applicable regulations.
With this policy, the Company wishes to provide an outline of the established rules for theapplication of ‘Know Your Customer’ (KYC) principles and the conduct of due diligence checks
on prospective clients and transactions, the company’s regulatory requirements for theestablishment of a business relationship and the responsibility for the reporting of suspicioustransactions to the relevant competent authorities should a money laundering activity is identified.
Money Laundering: Money laundering is a process by which criminals attempt to conceal thetrue origin and ownership of the proceeds of their criminal activities. Money laundering enables
criminals to maintain control over their illicit proceeds and ultimately to provide legitimate coverfor the illegal source of the illicit proceeds. This means that proceeds from criminal activities isconverted into assets that gives it an appearance of legitimate money.
There is no specific method of laundering money. Despite the variety of methods employed, thelaundering process is accomplished in three basic stages which may comprise transactions by thelaunderers that could alert a financial institution to criminal activity:
Placement: is the physical deposit of criminal proceeds derived from illegal activity i.e.
entering the collected cash into the financial circuits (payment in cash, exchange of bills,
manual exchange, travelers’ checks, casino checks, etc.).

Layering: is the separation of criminal proceeds from their source by creating complex
layers of financial transactions designed to disguise the audit trail and provide anonymity
i.e. transfer between accounts, drawing of checks, foreign transactions etc.

Integration: is the provision of apparent legitimacy to the proceeds of crime. If thelayering process has succeeded, integration places the laundered proceeds back into theeconomy in such a way that they appear as normal (business) funds or other assets i.e.
investing funds in lawful investments (stores, leisure activities, real estate, but also
companies of all types, etc.

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The Company’s approach on the prevention of money laundering: The Company has
established and maintains procedures and systems sufficient to ensure compliance with thefollowing requirements:

To ensure compliance with applicable anti-money laundering laws, regulations anddirectives issued by the competent authorities.
To apply customer due diligence (CDD) measures, also known as “Know Your Customer‟(KYC) measures, using a risk-based approach, in respect of all customers, business
relationships and transactions;
To conduct ongoing monitoring of business relationships, including paying special
attention to complex, unusual or large transactions with no apparent economic/lawful
purpose, and relationships and transactions with persons in high-risk jurisdictions;
To stop acting and terminate any existing business relationship whenever unable to apply
CDD or ongoing monitoring;
To maintain records, including records of all prescribed CDD measures and all transactions
and related correspondence, for at least 5 years after the termination of the contractual
relationship with the customer;
To set a complete education and training program that enables the Company’s employees
to recognise and deal with transactions and other activities which may be related to money
laundering;
To report suspicious transactions or activities to competent authorities

For the establishment of and during the business relationship with the Company, thefollowing CDD measures may apply:

Identification of the customer and verification of the customer's identity on the basis of
documents, data or information obtained from a reliable and independent source such as
passport/government identity document, proof of residential address i.e. utility bill or bankstatement;
Identification of the beneficial owner and implementation of reasonable measures to verify
that person's identity so that the Company is satisfied that it knows who the beneficialowner is, including, as regards legal persons, trusts, companies, foundations and similar
legal arrangements, taking reasonable measures to understand the ownership and control
structure of the customer;
assessment and, as appropriate, the collection of information on the purpose and intended
nature of the business relationship;conduct of ongoing monitoring of the business relationship including scrutiny oftransactions undertaken throughout the course of that relationship to ensure that thetransactions being conducted are consistent with the Company’s knowledge of thecustomer, the business and risk profile, including where necessary the source of funds andensuring that the documents, data or information held are kept up-to-date.

2The information on this policy is given in a summary form and in no way should be considered asa legal binding document or part of the Company’s Terms and Conditions and other binding
policies. This policy has been designed to give an insight to the Company’s customers as to theimplemented rules by the company for the prevention of money laundering and it has been listed
only for information purposes.
For any further queries and clarifications in relation to the Company’s Anti- Money Laundering
policy and procedures please address to support@FXGiants.com.

28 August 2020 – v.2020/001
Copyright © 2020 Notesco Limited. All Rights Reserved

Notesco Limited
Email: support@fxgiants.com | Web: www.FXGiants.com

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