This document is a template for illustrative purposes and does not constitute legal advice. Trixo Market should have it reviewed and finalised by qualified legal counsel before publication.
1. Purpose
This Anti-Money-Laundering (AML) and Know-Your-Customer (KYC) Policy sets out the principles and procedures that Trixo Market applies to prevent its services from being used for money laundering, terrorist financing or other financial crime. It reflects our commitment to operating with integrity and to meeting the standards expected by the relevant regulatory authorities.
2. Our commitment
Trixo Market is committed to the highest standards of compliance with applicable anti-money-laundering and counter-terrorist-financing laws. We maintain a risk-based AML framework that is overseen by designated compliance personnel and is reviewed regularly to keep pace with evolving regulatory requirements and emerging risks. We will not knowingly conduct business with any party engaged in illicit activity.
3. KYC & customer due diligence
Before activating an account, and on an ongoing basis thereafter, we carry out customer due diligence to verify the identity of our clients. This typically includes:
- Collecting and verifying identity information, such as government-issued identification and proof of address.
- Identifying and, where applicable, verifying any beneficial owners of corporate clients.
- Assessing the purpose and intended nature of the business relationship.
- Applying enhanced due diligence to higher-risk clients, including politically exposed persons.
We may decline to open an account, or suspend an existing account, where we are unable to complete satisfactory due diligence.
4. Ongoing monitoring
We monitor client activity throughout the relationship to identify transactions that are unusual, inconsistent with what we know about the client, or otherwise indicative of potential financial crime. Our monitoring is risk-based and may include automated and manual reviews. Where appropriate, we will request further information or documentation to understand the nature of a transaction.
5. Source of funds
Clients must ensure that all funds deposited with Trixo Market originate from legitimate sources and belong to them. We may, at any time, request evidence of the source of funds or source of wealth. Deposits and withdrawals are generally expected to be made through accounts held in the client's own name, and we may restrict third-party payments.
6. Reporting suspicious activity
Where we identify activity that we know or suspect to be linked to money laundering or other financial crime, we will report it to the appropriate authorities in accordance with our legal obligations. We are required by law to handle such matters confidentially, and we may be unable to inform a client that a report has been made or that an investigation is under way.
7. Sanctions screening
We screen clients and transactions against applicable sanctions lists maintained by the relevant authorities. We do not provide services to individuals or entities subject to applicable sanctions, or to clients located in jurisdictions where we are prohibited from operating. Where a match is identified, we will take appropriate action, which may include freezing assets and reporting to the authorities.
8. Record keeping
We retain records of client identification, transactions and due diligence for the minimum periods required by applicable law and regulation, even after the end of the business relationship. These records support our ability to respond to lawful requests from the relevant regulatory authorities and to demonstrate compliance with this policy.
9. Staff training
Our staff receive regular training on their AML and KYC obligations, including how to recognise and respond to indicators of financial crime and how to escalate concerns internally. Training is updated to reflect regulatory developments and the specific risks relevant to our business.
10. Contact
If you have any questions about this AML & KYC Policy, please contact our compliance team through our contact page.