AML/CFT Policy

Trade Aviator Limited Anti-Money Laundering ("AML") and Counter-Financing of Terrorism ("CFT") Policy is designed to prevent money laundering and hinder the risk of Trade Aviator Limited and its services from being used to facilitate or perpetrate financial crime, terrorist financing and illegal activities.

• Client: Any person or entity having a business relationship with the Company to receive specialized services based on their specific needs.
• AML: Anti-Money Laundering.
• CFT: Counter Financing of Terrorism.
• Money Laundering (ML): The concealment of the origins of illegally obtained money, typically by means of transfers, transactions, or the process by which criminals attempt to conceal the origin of property and assets that are the proceeds of criminal or illegal activities.
• Know Your Customer (KYC): Businesses obtaining and verifying customer identities, preservation of records, and mandatory disclosure of transactions to authorized statutory bodies.
• Terrorism Financing: Both legitimate and illegitimate money characterized by concealment of the origin or intended criminal use of funds.
• Politically Exposed Persons (PEPs): Individuals in high-ranking public roles who pose a higher risk for potential involvement in bribery, corruption, or money laundering.

This AML/CFT Policy sets out the procedures, standards, and the principles adopted by TRADE AVIATOR LIMITED to prevent, detect and report money laundering activities, illegal activities, terrorist financing or funding and other related financial crimes, in compliance with applicable laws and regulations.

This Policy applies to:

• All the directors, officers, employees, and management of the Organization
• Agents, consultants, and contractors acting on behalf of the Organization
• All products, services, customers, and business relationships relating to the Organization

Trade Aviator Limited understands that it has a vital role in preventing criminals or persons or entity from using their services to facilitate money laundering, perpetrate fraud and terrorist financing. TRADE AVIATOR LIMITED maintains a zero-tolerance approach to money laundering, fraud, terrorist financing and is committed to:

• Conducting business with integrity and transparency
• Identifying, assessing, and managing AML/CFT risks
• Reporting suspicious transactions promptly to the appropriate authorities
• Complying with relevant statutory authorities and regulations

The Organization shall comply with all applicable AML/CFT laws and regulations, including but not limited to:

• Economic and Financial Crimes Commission Act (EFCC)
• Central Bank of Nigeria (Anti-Money Laundering and Combating the Financing of Terrorism in Banks and Other Financial Institutions in Nigeria) Regulations
• Money Laundering (Prevention and Prohibition) Act
• Terrorism (Prevention and Prohibition) Act
• Regulations and Guidelines issued by relevant regulators
• International standards, including FATF Recommendations

Individuals can be identified by their government-issued ID such as national identity cards, driver's licence, international passport, NIN, or other identification document and utility bills stating their current address. Companies must be identified by their Memorandum and Articles of Association or Incorporation Certificate from Corporate Affairs Commission (CAC).

The Company, in upholding its KYC policies, shall undertake the following:

• Verification of the status of business names, incorporated trustees and companies registered with the Corporate Affairs Commission (CAC)
• Establishing and maintaining a risk-based approach to Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), including customer identification, verification and KYC procedures
• Issuing a KYC compliance form to all customers
• Conduct due diligence for higher-risk customers, businesses or transactions including Politically Exposed persons (PEP), cross border transactions and business relationships
• Reporting any suspicious illegal activities and transactions to the relevant statutory authorities

Trade Aviator Limited has established a Know-Your-Customer (KYC) policy to ensure that the identities of all customers are verified and ascertained. This includes:

• Proof of Identity: Valid international Passport, Valid Driving License, National ID, Voter's Card
• Proof of Address: Bank statements, utility bills (water, gas, electricity), telephone landline bills, Tax Statement dated within the previous three to six calendar months
• Bank Account Verification: Bank Statement showing Name, Account Number and SWIFT/BIN/Sortcode, or valid Bank Verification Number (BVN)
• Business Accounts: Company's Name, Registration Number, Tax Identification Number, verifiable with the Corporate Affairs Commission (CAC)

Trade Aviator Limited shall monitor the financial activities of its customers. Users will be classified as high-risk, medium-risk or low-risk and KYC records will be periodically updated:

• High-Risk Users: Every 6 months
• Medium-Risk Users: Every 2 years
• Low-Risk Users: Every 4 years

The business will actively not accept high-risk customers identified as follows: customers with complex ownership structures with potential to conceal underlying beneficiaries, untraceable source of funds for large transactions, unusual transactions with no apparent lawful purpose, and money sent or received from businesses known to have high level of criminality or terrorist activity.

Trade Aviator Limited has established a strong governance structure, including:

• Appointment of a Money Laundering Reporting Officer (MLRO)
• Implementing internal controls to prevent money laundering, terrorist financing and financial crimes
• Regular and frequent audits to assess compliance effectiveness

The Company shall keep the record of all customers' identification for at least six years after the closure of the account or the severance of relations with the customer.

Records of all identity checks will be maintained for at least six (6) years after the termination of the business relationship or from the date when the transaction was completed.

If the company notices any illegal transaction, it shall draw up a report on the identity of the principal and beneficiaries, take appropriate action to deter the laundering of proceeds of criminal conduct, and send a copy of the report to the Nigerian Financial Intelligence Unit (NFIU).

To ensure effective AML/CFT compliance, Trade Aviator Limited will organize at least one AML/KYC training session for their employees every quarter, provide ongoing compliance education to employees, and promote awareness among users regarding AML/CFT obligations.

Board of Directors:

• Approve and oversee the AML/CFT Policy
• Ensure adequate resources for effective AML/CFT compliance
• Review periodic AML/CFT reports

Compliance Officer (MLRO):

• Implement and monitor compliance with this Policy
• Receive and investigate internal suspicious activity reports
• File statutory reports with relevant authorities
• Provide AML/CFT guidance and training

Employees:

• Comply fully with this Policy
• Remain vigilant and report suspicious activity
• Undergo compliance education regularly.

Trade Aviator Limited is prohibited from transacting with individuals, entities, companies and countries that are on prescribed sanctions lists. We will screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists.

Trade Aviator Limited does not provide services to:

• Businesses involved in illegal activities such as money laundering, terrorism financing, human trafficking, and drug trafficking
• Shell banks or anonymous accounts
• Entities associated with sanctioned individuals or groups
• High-risk industries including unregulated gambling and weapons manufacturing
• Unlicensed money services businesses (MSBs) and unregistered payment processors
• Ponzi schemes, scams, pyramid schemes and other fraudulent financial organizations

"Politically exposed persons" means natural persons who are or have been entrusted with a prominent public function or office by a state or country, a community institution or an international body, or a family member or known close associate of such a person.

Individuals who hold or have held a high political profile or public office can pose a higher money laundering risk as their position makes them vulnerable to corruption, fraud, money laundering or illegal activities. Enhanced Due Diligence Checks have been specifically designed for dealing with PEPs, high-risk or high-net worth customers and large transactions.

A breach of the AML/CFT policy is a severe offence and could lead to thorough investigations, imposition of fines and criminal sanctions which can lead to imprisonment.

For questions, observations, or concerns regarding our AML/CFT Policy, please contact us

Email: support@usetradeaviator.com