At Broxley, we are committed to maintaining the highest standards of integrity and compliance in the financial industry. Our Anti-Money Laundering (AML) and Know Your Customer (KYC) policies are designed to prevent illegal activities, ensure transparency, and promote trust between Broxley and its clients. These policies comply with international regulations and are regularly updated to address emerging threats and requirements.

Anti-Money Laundering (AML) Policy

1. Comprehensive AML Framework

Broxley has implemented a robust AML framework to detect, prevent, and mitigate risks associated with money laundering and terrorist financing. This framework includes policies, procedures, and internal controls to monitor transactions, verify client identities, and ensure compliance with applicable regulations. Our team undergoes regular training to stay informed about the latest trends and methods in financial crime prevention.

2. Appointment of an AML Officer

To oversee the implementation of our AML program, Broxley has designated a dedicated AML Compliance Officer. This officer is responsible for monitoring transactions, conducting investigations into suspicious activities, and liaising with regulatory authorities. The AML Officer ensures that all AML processes are effectively enforced and updated as required by law.

3. Risk-Based Approach

Broxley employs a risk-based approach to identify and mitigate potential money laundering risks. Clients are categorized into risk levels based on factors such as geographic location, transaction history, and business type. Enhanced due diligence (EDD) is applied to high-risk clients to ensure all transactions are legitimate and compliant.

4. Transaction Monitoring

Our transaction monitoring system uses advanced algorithms to analyze client activity in real time. The system flags unusual patterns, such as large or frequent transactions that deviate from the client’s profile. These alerts are reviewed by our compliance team to determine if further action is required.

5. Suspicious Activity Reporting (SAR)

If suspicious activity is detected, Broxley files a Suspicious Activity Report (SAR) with the relevant regulatory authority. SARs are treated with the highest level of confidentiality, and clients involved in such reports are notified only if permitted by law.

6. Sanctions and Watchlist Screening

Broxley screens all clients and transactions against international sanctions lists, such as those maintained by the United Nations, OFAC, and the EU. Clients found on these lists are immediately restricted from using our services, and relevant authorities are informed.

7. Enhanced Due Diligence (EDD)

For high-risk clients, Broxley conducts EDD procedures, which include verifying the source of funds, identifying beneficial owners, and closely monitoring transactions. EDD is also applied to Politically Exposed Persons (PEPs) and clients from high-risk jurisdictions.

8. Record-Keeping Requirements

Broxley retains records of client transactions, identification documents, and communications for a minimum of five years. These records are securely stored and made available to regulatory authorities upon request. This ensures that we comply with legal obligations and maintain transparency in our operations.

9. Employee Training and Awareness

Our employees receive regular training on AML policies, regulatory requirements, and the latest money laundering techniques. This ensures that all staff members are equipped to identify and report suspicious activities effectively.

10. Correspondent Banking Relationships

Broxley evaluates the AML policies of financial institutions with whom we establish correspondent banking relationships. This ensures that our partners adhere to similar standards and do not engage in activities that could expose us to financial crime risks.

11. Prohibited Transactions

Transactions involving shell companies, anonymous accounts, or jurisdictions with lax AML regulations are strictly prohibited. Any such activities detected are immediately reported to regulatory authorities.

12. Client Education

We believe in empowering our clients with knowledge about AML policies. Broxley provides resources to help clients recognize fraudulent schemes and understand the importance of compliance.

13. Automated Screening Tools

Our platform integrates advanced screening tools to automate the detection of suspicious activities. These tools analyze transaction patterns, monitor account activity, and cross-check data against international watchlists.

14. Independent Audits

Broxley conducts regular independent audits of its AML program to identify weaknesses and implement improvements. These audits ensure that our policies remain effective and compliant with evolving regulations.

15. Politically Exposed Persons (PEPs)

Clients identified as PEPs undergo rigorous scrutiny to ensure their activities are legitimate. This includes verifying the source of their wealth and closely monitoring transactions to mitigate risks.

16. Cooperation with Regulatory Authorities

Broxley actively cooperates with regulatory authorities in investigations related to money laundering or financial crime. This includes providing transaction records, client information, and other relevant data.

17. Use of Artificial Intelligence (AI)

We leverage AI and machine learning technologies to enhance our AML efforts. These systems analyze vast amounts of data to detect anomalies and predict potential risks with greater accuracy.

18. Cross-Border Transactions

Additional checks are implemented for cross-border transactions, particularly those involving high-risk jurisdictions. This includes verifying the legitimacy of the transaction and ensuring compliance with international regulations.

19. Zero Tolerance Policy

Broxley enforces a zero-tolerance policy for money laundering. Clients found engaging in such activities face immediate account termination and legal consequences.

20. Continuous Improvement

Our AML policies are regularly reviewed and updated to address new threats and comply with changes in international regulations. This commitment to continuous improvement ensures the effectiveness of our program.

Know Your Customer (KYC) Policy

1. Purpose of KYC

The KYC policy is designed to verify the identity of our clients and ensure their activities align with legal and ethical standards. This process helps prevent fraud, identity theft, and other financial crimes.

2. Client Identification

All clients are required to provide valid identification documents, such as a government-issued ID, passport, or driver’s license, during the account registration process. These documents are verified to confirm the client’s identity.

3. Proof of Address

Clients must submit proof of address, such as a utility bill or bank statement issued within the last three months. This helps verify the client’s residency and prevents unauthorized access to our services.

4. Beneficial Ownership Disclosure

For corporate clients, Broxley requires disclosure of all beneficial owners to ensure transparency. This includes submitting documents that identify the individuals who ultimately own or control the entity.

5. Document Authentication

All submitted documents are carefully reviewed for authenticity. Broxley employs advanced verification tools to detect forged or tampered documents. Accounts with falsified documentation are immediately suspended.

6. Risk Profiling

Clients are assigned a risk profile based on their personal information, transaction history, and geographic location. This profile helps Broxley apply appropriate levels of scrutiny and tailor its monitoring efforts.

7. Periodic KYC Reviews

To ensure information remains accurate and up to date, Broxley conducts periodic reviews of client accounts. Clients may be asked to re-submit identification documents or confirm their details as part of this process.

8. Verification During Withdrawals

Additional verification steps are implemented during withdrawal requests to ensure funds are released to the rightful account holder. This includes reconfirming the client’s identity and verifying the destination account details.

9. Geographic Restrictions

Broxley prohibits accounts from jurisdictions identified as high-risk or under international sanctions. Clients from these regions are restricted from accessing our platform to maintain compliance.

10. Politically Exposed Persons (PEPs)

Accounts belonging to PEPs undergo enhanced due diligence to mitigate risks associated with their position. This includes verifying the legitimacy of their transactions and monitoring for unusual activity.

11. Dormant Account Reviews

Accounts with prolonged inactivity are reviewed to ensure compliance with KYC standards. Clients may be required to verify their identity before reactivating a dormant account.

12. Source of Funds Verification

Broxley requires clients to declare and verify the source of their funds for large deposits or transactions. Supporting documentation, such as salary slips or bank statements, may be requested.

13. KYC for Corporate Accounts

Corporate clients must provide detailed information about their business operations, including incorporation documents, board resolutions, and shareholder details. This ensures transparency and compliance.

14. Ongoing Monitoring

All client accounts are continuously monitored to detect changes in behavior or transaction patterns that may indicate potential risks. Unusual activity is flagged for further review.

15. Automated KYC Systems

Broxley employs automated systems to streamline the KYC process. These systems verify documents, cross-check information against watchlists, and assign risk scores to clients.

16. Educational Resources

Broxley provides clients with resources to understand the importance of KYC compliance. This includes guidance on submitting accurate documentation and recognizing fraudulent schemes.

17. Cross-Border KYC Compliance

Clients engaging in cross-border transactions are subject to additional KYC requirements to ensure compliance with international laws and regulations.

18. Third-Party Verification

In some cases, Broxley collaborates with trusted third-party providers to assist in the verification process. These providers adhere to the same rigorous standards as Broxley.

19. Repeated Verification

Clients may be required to undergo re-verification periodically or when there are changes to their account information. This ensures that all records remain accurate and compliant.

20. Continuous Improvement

Broxley’s KYC policies are regularly reviewed and enhanced to address emerging threats and align with evolving regulations. This commitment ensures that our platform remains secure and compliant.