ANTI-MONEY
LAUNDERINGPOLICYSVOFX LTD.
Email: info@svofx.com

The Cpmpany is committed to the highest standards of the Anti-Money Laundering (AML)compliance and Anti-Terrorist Financing and requires the management, and employees tofollow the named standards.
Money laundering – the process of converting funds, received from illegal activities (such asfraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or
distort the real source of funds.
The process of money laundering can be divided into three sequential stages:Placement：At this stage funds are converted into financial instruments, such as checks,bank accounts, and money transfers, or can be used for purchasing high-value goods that canbe resold. They can also be physically deposited into banks and non-bank institutions (e.g.,currency exchangers). To avoid suspicion by the company, the launderer may as well makeseveral deposits instead of depositing the whole sum at once, this form of placement is called
smurfing.
Layering： Funds are transferred or moved to other accounts and other financialinstruments. It is performed to disguise the origin and disrupt the indication of the entitythat made the multiple financial transactions. Moving funds around and changing in theirform makes it complicated to trace the money being laundered.
Integration： Funds get back into circulation as legitimate to purchase goods and services.

AML Policy
The Company, like most companies providing services on the financial market, adheres to theprinciples of Anti-Money Laundering and actively prevents any actions that aim or facilitate theprocess of legalizing of illegally gained funds. AML policy means preventing the use of thecompany's services by criminals, with the aim of money laundering, terrorist financing or othercriminal activity.
For this purpose, a strict policy on the detection, prevention and warning of the corresponding
bodies of any suspicious activities was introduced by the company. Moreover, we has no right toreport clients that the law enforcement bodies are informed on their activity. A complex
electronic system for identifying every company's client and conducting a detailed history of all
operations was introduced as well.
To prevent money laundering, we neither accepts nor pays cash under any circumstances. Thecompany reserves the right to suspend any client's operation, which can be regarded as illegal
or, may be related to money laundering in the opinion of the staff.
Company's procedures we will make sure that it is dealing with a real person or legal entity. wealso performs all the required measures in accordance with applicable law and regulations,issued by monetaryauthorities. The AML policy is being fulfilled within us by means of thefollowing:
・Know your customer policy and due diligence・Monitoring of client activity
・Record keeping01

Know Your Customer and Due Diligence
Because of the company's commitment to the AML and KYC policies, each client of the company
has to finish a verification procedure. Before the company starts any cooperation with theclient, the company ensures that satisfactory evidence is produced or such other measures thatwill produce satisfactory evidence of the identity of any customer or counterparty are taken.
The company as well applies heightened scrutiny to clients, who are residents of othercountries, identified by credible sources as countries, having inadequate AML standards or that
may represent a high risk for crime and corruption and to beneficial owners who resides in andwhose funds are sourced from named countries.
Individual clients
During the process of registration, each client provides personal information, specifically: fullname; date of birth; origin; complete address, including phone number and city code. A client
sends the following documents (in case the documents are written in non-Latin characters: toavoid any delays in the verification process, it is necessary to provide a notarized translation of
the document in English) because of the requirements of KYC and to confirm the indicatedinformation:
A high-resolution copy of the first page of local or international passport, where the photoand the signature are clearly seen, or a copy of driver's license with the same requirements.
The indicated documents must be valid at least 6 months from the filing date.
A high-resolution copy of a receipt of utility services payment or bank statement, containing
the full client's name and the actual place of residence. These documents should not be older
than 3 months from the date of filing.
Corporate clients
In case the applicant company is listed on a recognised or approved stock exchange or when
there is independent evidence to show that the applicant is a wholly owned subsidiary or asubsidiary under the control of such a company, no further steps to verify identity will normallybe required. In case the company is unquoted and none of the principal directors or
shareholders already has an account with SVOFX, the official provides the following documents
because of the requirements of KYC:
A high-resolution copy of the certificate of incorporation/certificate;An extract from the Commercial Register, or equivalent document, evidencing theregistration of corporate acts and amendments;
Names and addresses of all officers, directors and beneficial owners of the corporate entity;
A high-resolution copy of Memorandum and Articles of Association or equivalent
documents duly recorded with the competent registry;
Evidence of the company’s registered address and the list of shareholders and directors;
Description and nature of business (including the date of commencement of the business,
products or services provided; and the location of principal business).

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This procedure is performed to establish the identity of the client and to help SVOFX
know/understand the clients and their financial dealings to be able to provide the best servicesof online trading.

Monitoring of Client Activity
In addition to gathering information from the clients, The company continues to monitor theactivity of every client to identify and prevent any suspicious transactions. A suspicioustransaction is known as a transaction that is inconsistent with the client's legitimate business or
the usual client's transaction history known from client activity monitoring. We has
implemented the system of monitoring the named transactions (both automatic and, if needed,manual) to prevent using the company's services by criminals.

Deposit and Withdrawal Equirements
All the clients' operations to deposit and withdraw funds have the following requirements:
In case of bank transfer or transfer from a bank card, the name, indicated during theregistration must match the name of the owner of the account/bank card.
Withdrawing funds from the trading account via the method, which is different from thedepositing method, is possible solely after withdrawing the sum, which is equal to the sum ofclient's deposits via the method and to the same account used for depositing.
If the account was credited in the way that cannot be used for funds withdrawal, the funds
may be withdrawn to a bank account of the client or any other way may be used, as agreed
with the Company with the help of which the Company is able to prove the identity of theaccount owner.
If the account has been credited with funds through various payment systems, funds
withdrawal shall be made on a pro rata basis commensurate to the size of each deposit. Incase of depositing via Visa/MasterCard, Wire Transfer, the withdrawal of funds, which
exceed the sum of the client's deposits, is possible via any of the following methods:
Visa/MasterCard, Wire Transfer.
In case of depositing via another method, the withdrawal of funds that exceed the sum of theclient's deposits, is possible via any available method, by the client's choice.

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