Anti-Money Laundering Policy
Last updated: March 1, 2026
1. Policy Statement
ZenGuard Markets Ltd is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy outlines our procedures for detecting, preventing, and reporting money laundering and terrorist financing activities.
We comply with all applicable AML/CTF laws and regulations, including the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Money Laundering Regulations 2017, and all relevant EU directives and international standards.
2. Scope
This policy applies to all employees, officers, directors, contractors, and agents of ZenGuard Markets Ltd. It covers all business relationships, transactions, and services provided by the company.
All staff members are required to familiarize themselves with this policy and comply with its requirements. Failure to comply may result in disciplinary action and potential criminal liability.
3. Customer Due Diligence (CDD)
We conduct Customer Due Diligence on all clients before establishing a business relationship. Standard CDD measures include verifying the client's identity using reliable, independent source documents, identifying and verifying the identity of any beneficial owners, obtaining information on the purpose and intended nature of the business relationship, and conducting ongoing monitoring of the business relationship.
We do not open anonymous accounts or accounts in fictitious names. All clients must provide valid identification and proof of address before their accounts are activated.
4. Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied in situations that present a higher risk of money laundering or terrorist financing, including politically exposed persons (PEPs) and their family members or close associates, clients from high-risk jurisdictions, complex or unusually large transactions, unusual patterns of transactions with no apparent economic or lawful purpose, and any other situations where the risk of money laundering is assessed as higher than normal.
EDD measures may include obtaining additional identification documents, verifying the source of funds and source of wealth, obtaining senior management approval for the business relationship, and conducting enhanced ongoing monitoring.
5. Know Your Customer (KYC) Requirements
All clients must provide the following documentation: a valid government-issued photo identification (passport, national ID card, or driver's license), proof of residential address dated within the last 3 months (utility bill, bank statement, or government correspondence), and for corporate clients, additional documentation including certificate of incorporation, memorandum and articles of association, register of directors and shareholders, and proof of identity for all beneficial owners holding 25% or more.
We reserve the right to request additional documentation at any time to verify client identity or source of funds.
6. Transaction Monitoring
We employ automated and manual transaction monitoring systems to detect suspicious activity. Our monitoring covers all deposits and withdrawals, trading patterns and volumes, account activity and behavior changes, cross-border transactions, and transactions involving high-risk jurisdictions.
Our monitoring systems are calibrated to detect unusual patterns, including structuring (breaking large transactions into smaller ones to avoid reporting thresholds), rapid movement of funds, and transactions inconsistent with the client's profile.
7. Suspicious Activity Reporting
All employees are required to report any suspicious activity to our Money Laundering Reporting Officer (MLRO). The MLRO is responsible for evaluating internal reports and filing Suspicious Activity Reports (SARs) with the relevant Financial Intelligence Unit.
Tipping off — informing a client or any other person that a SAR has been filed or that an investigation is underway — is a criminal offense. All reports are treated with the strictest confidentiality.
8. Record Keeping
We maintain comprehensive records of all client identification documents and verification procedures, all transactions conducted through our platform, all internal and external suspicious activity reports, and all AML/CTF training records.
Records are retained for a minimum of 5 years after the end of the business relationship or the completion of the transaction, whichever is later. Records are stored securely and are accessible to relevant authorities upon request.
9. Staff Training
All employees receive AML/CTF training upon joining the company and on an ongoing basis thereafter. Training covers the legal and regulatory framework, our internal policies and procedures, how to identify suspicious activity, reporting obligations and procedures, and consequences of non-compliance.
Training records are maintained and reviewed regularly to ensure all staff are up to date with current requirements.
10. Compliance Officer
Our Money Laundering Reporting Officer (MLRO) is responsible for overseeing the implementation of this policy, receiving and evaluating internal suspicious activity reports, filing SARs with the relevant authorities, ensuring adequate AML/CTF training for all staff, conducting regular risk assessments, and reporting to senior management and the board on AML/CTF matters.
The MLRO can be contacted at compliance@zenguardmarkets.com.
11. Sanctions Screening
We screen all clients and transactions against relevant sanctions lists, including UN Security Council sanctions lists, EU sanctions lists, OFAC (US) sanctions lists, and HM Treasury sanctions lists.
Screening is conducted at the point of onboarding and on an ongoing basis. Any matches are escalated to the MLRO for further investigation and action.
12. Policy Review
This policy is reviewed at least annually or more frequently if required by changes in legislation, regulation, or business operations. Any updates to this policy are communicated to all relevant staff members.
Last reviewed: March 1, 2026 Next review date: March 1, 2027