### Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) Policy

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#### 1. *Introduction*

Ziggurah is committed to ensuring full compliance with local and international laws and regulations related to combating money laundering and terrorist financing. This policy aims to provide a comprehensive framework to ensure that the company's services are not used to facilitate money laundering or terrorist financing.

#### 2. *Customer Identity Verification (KYC) Policy*

2.1 *Verification process*:

- All new customers are required to provide official identification documents to verify their identity.

- Customers must provide proof of current residential address.

- The authenticity of the documents submitted is verified through approved verification tools.

2.2 *Monitoring activities*:

- All transactions are monitored to check for suspicious activities.

- Any activities that exceed the normal trading limit are investigated.

#### 3. *Report suspicious activities*

3.1 *Internal procedures*:

- Employees must report any suspicious activity immediately to the Compliance Officer.

- Suspicious activity reports (SARs) are submitted to the relevant authorities in accordance with applicable laws.

3.2 *Cooperation with the authorities*:

- The company fully cooperates with legal and regulatory authorities in any investigations related to money laundering or terrorist financing.

#### 4. *Training and awareness*

4.1 *Employee training*:

- All employees undergo periodic training on anti-money laundering and counter-terrorism financing policies and procedures.

The training includes identifying indicators that may indicate suspicious activities and how to deal with them.

4.2 *Periodic updates*:

- AML/CFT policies and procedures are updated periodically to ensure compliance with the latest laws and regulations.

#### 5. *Enhanced due diligence (EDD) procedures*

5.1 *When necessary*:

- Enhanced Due Diligence (EDD) procedures are applied to high-risk clients or large transactions.

- This includes gathering additional information about the client and sources of funds.

5.2 *Continuous monitoring*:

- High-risk accounts are monitored periodically to ensure that there are no suspicious activities.

#### 6. *Record keeping*

6.1 *Time period*:

- All identity verification and transaction records are kept for a minimum of five years.

- Records must be available to the appropriate authorities upon request.

#### 7. *Risk assessment*

7.1 *Risk Analysis*:

- The company conducts a periodic analysis of the risks associated with money laundering and terrorist financing.

- Control policies and procedures are modified based on the results of the risk analysis.

#### 8. *International Compliance*

8.1 *Compliance with international regulations*:

- The company adheres to all international regulations and standards related to combating money laundering and terrorist financing.

- Internationally imposed sanctions and financial restrictions are complied with.

#### 9. *Review and audit*

9.1 *Internal audit*:

- Anti-money laundering and terrorist financing policies and procedures are subject to periodic internal review.

- Processes are improved based on the results of reviews.

9.2 *External audit*:

- The company undergoes external audits to ensure full compliance with policies and procedures.

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Ziggurah ensures strict compliance with this policy to ensure that its platform is not used for any illegal or suspicious activities, and is committed to maintaining the highest standards of transparency and integrity in all its operations.

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*Effective date*: 01/04/2024

To contact us / admin@fxeet.com