Anti Money Laundering (AML) Policy
Scope of Policy
This policy applies to all officers, employees, designated producers of IQ Global and the products and services provided by IQ Global. All business units and locations within IQ Global will work together to combat money laundering. Each business unit and location has implemented risk-based procedures designed to prevent, detect and report transactions. All efforts will be documented and retained. The Anti-Money Laundering Compliance Committee is responsible for initiating suspicious activity reports (“SARs”) or other required reports and reporting to the appropriate law enforcement or regulatory authorities. Any contact from law enforcement or regulatory authorities in relation to this policy should be directed to the Anti-Money Laundering Compliance Committee.
The Committee shall:
Receive internal reports of money laundering (suspected money laundering)
Investigate reports of suspicious incidents
Report relevant suspicious incidents to the relevant authorities
Ensure adequate arrangements are in place for awareness and training of employees and consultants
Report to the Company’s management at least annually on the operation and effectiveness of the Company’s systems and controls.
Monitor the day-to-day operation of the Anti-Money Laundering Policy in relation to new product development, new client onboarding and changes in the Company’s business profile.
Information from Other Sources: We may receive information about you from other sources, such as credit history information from credit agencies, which we use to help prevent and detect fraud.
Policy
IQ Global will actively work to prevent money laundering and any activities that facilitate money laundering or the financing of terrorism or criminal activities. IQ Global is committed to complying with anti-money laundering regulations in accordance with applicable laws and requires its officers, employees and designated producers to comply with these standards in order to prevent its products and services from being used for money laundering purposes.
For the purposes of this policy, money laundering is defined as engaging in conduct designed to conceal or disguise the true origin of criminal proceeds so that the illegal proceeds appear to have come from legitimate sources or to constitute legitimate assets.
What is Money Laundering (AML)?
Criminal property can be in any form, including money or money's equivalent, securities, tangible property and intangible property. It also includes money (however acquired) used to finance terrorism.
Acquiring, using or possessing criminal property .
Knowingly participating in any way in criminal or terrorist property
Agreements to launder criminal or terrorist property
Investing criminal proceeds in other financial products
Investing criminal proceeds by acquiring property/assets
Transferring criminal property.
There is no single stage to money laundering; methods vary, from buying and reselling luxury goods such as cars or jewelry to moving money through a complex network of legal operations. Typically, the starting point is cash, but it is important to realise that money laundering is defined in terms of criminal property. This can be any conceivable form of legal property, whether it be money, rights, real estate or any other interest; if you know or suspect it was obtained directly or indirectly through criminal activity and you do not speak up, then you are also complicit in the process.
There are three stages to the money laundering process:
Placement The initial proceeds from illegal activity are deposited into a bank account.
Layering The funds are moved through the system through a series of financial transactions to obscure the origin of the cash with the aim of making it appear legitimate.
Once the money is removed from the system as seemingly “clean” funds, criminals are free to use it.
No financial sector is immune to the activities of criminals and companies should consider the money laundering risks posed by the products and services they offer.
What is Counter-Terrorism Financing (CTF)?
Terrorism financing refers to the process by which legitimate businesses and individuals choose to finance terrorist activities or organizations for ideological, political or other reasons. Therefore, companies must ensure that: (i) the client is not a terrorist organization itself; and (ii) they are not providing funds to terrorist organizations.
Terrorism financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the source or intended use of funds, which are then used for criminal purposes.
Risk-based approach
When considering the AML program within a company, the level of due diligence required should take a risk-based approach. This means that the amount of resources spent on due diligence on any risky relationship should be proportional to the degree of risk that the relationship poses.
These can be divided into the following areas:
Client risk
Different customer profiles carry different levels of risk. Basic Know Your Customer (KYC) checks can identify the risk posed by a customer. For example, a person approaching retirement who regularly deposits small sums into a savings account based on their financial details is less risky than a middle-aged person who temporarily transfers money to a savings account that does not match the customer data profile. The intensity of due diligence carried out in the last case will be higher than in the first case, as the potential threat of money laundering will be seen as greater in the second case. Corporate structures can be an example of a customer who is riskier than it appears, as criminals can use this structure to insert layers into transactions to hide the source of funds, and in this way, customers can be classified into different risk groups.
Product Risk
This is the risk posed by the product or service itself. Product risk arises from its function as a tool for money laundering.
The Joint Anti-Money Laundering Steering Group classifies products that companies typically trade into three risk levels - low risk, medium risk and high risk. Typically, pure protection contracts are classified as low risk, while unit trust investments are classified as high risk. In addition, a factor that influences the classification of risk categories is the sales process associated with the product. If product transactions are conducted on an advisory basis due to KYC, the risk will be lower than if the transaction is only executed because you know much less about the customer when executing the transaction.
Country Risk
The geographical location of the customer or the origin of the business activity has an associated risk, as countries around the world present different levels of risk.
The Company will use the four risk areas above to determine the scope of the initial and ongoing due diligence measures required.
Customer Identification Procedures
IQ Global has adopted a Customer Identification Program (CIP). IQ Global will provide notice that it will seek identification information; collect certain minimum customer identification information from each customer and record such information and the verification methods and results.
Notice to Customers
Where required by applicable law, IQ Global will inform clients that it is requesting information from them to verify their identity.
How secure is my information?
Know Your Customer (KYC)
When a business relationship is established, it is necessary for the Company to determine the nature of the business that the client expects to conduct in order to determine what may constitute normal activity in the future.
Once an ongoing business relationship is established, any routine business conducted for that client can be assessed against the client's expected pattern of activity. Any unexplained activity can then be examined to determine if there is any suspicion of money laundering or terrorist financing.
Information about the client's income, occupation, source of wealth, trading habits and the economic purpose of any transaction is usually collected during the course of providing advice. Personal information such as nationality, date of birth and address is also obtained at the beginning of the relationship. This information should also take into account the risk of financial crime (including anti-money laundering and counter-terrorist financing). For high-risk transactions, it may be necessary to verify the information provided by the client.
Source of Funds
When a transaction occurs, the source of funds, i.e. how, from where and by whom the payment was made, must always be determined and recorded in the client file (this is usually achieved by retaining a copy of the cheque or direct debit mandate).
Identification
The standard identification requirements for individual clients depend on the client’s circumstances and the type of product being traded, i.e. the risk level of the product (whether it is a low-risk, medium-risk or high-risk product). Taking into account low-risk and medium-risk products, the following information is required as identification criteria:
The client’s full name, and
Their residential address
IQ Global does not restrict the time within which clients can submit verification documents, but submission of verification documents is a mandatory requirement for clients to withdraw funds.
IQ Global commits to review submitted documents within 24 hours of receipt.
Monitoring and Reporting
Trade monitoring will be conducted within the appropriate business unit of IQ Global. Monitoring of specific transactions includes, but is not limited to, transactions totaling $5,000 or more and transactions where IQ Global has reason to suspect suspicious activity. All reports will be documented.
Suspicious Activity
There are indications of money laundering activity. These are often referred to as 'red flags.' If red flags are identified, additional due diligence will be conducted before proceeding with the transaction. If no reasonable explanation can be determined, the suspicious activity should be reported to the Anti-Money Laundering Compliance Committee.
Examples of suspicious activity or red flags include:
The client expresses unusual concerns about the company's compliance with government reporting requirements and the company's anti-money laundering policy, particularly regarding his or her identity, business type and assets, or is unwilling or refuses to disclose any information about business activities, or provides unusual or suspicious identification or business documents.
The client desires to engage in transactions that lack business sense or obvious investment strategy or are inconsistent with the client's stated business strategy.
The information provided by the client to identify the legitimate source of funds is false, misleading or incorrect.
Upon request, the client refuses to identify or fails to indicate any legitimate source of its funds and other assets.
The client lacks concern for risk, commissions, or other transaction costs.
The client acts as an agent for undisclosed reasons but refuses or is unwilling to provide information without a legitimate business reason, or otherwise avoids the person or entity.
The client has difficulty describing the nature of its business or lacks general knowledge of its industry.
The client attempts to deposit currency frequently or in large quantities, insists on trading only in cash equivalents, or requests exemptions from the company's policy regarding cash and cash equivalent deposits.
The client opens multiple accounts in one or more names for no apparent reason and makes multiple inter-account or third-party transfers.
The client's accounts experience unexplained or sudden large amounts of activity, especially accounts with little or no previous activity.
The client's accounts have multiple wire transfers to unrelated third parties that are inconsistent with the client's legitimate business purposes.
The client's accounts have wire transfers with no apparent business purpose from or to countries identified as money laundering risks or bank secrecy havens.
The customer's account shows large or frequent wire transfers, immediately withdrawn by check or debit card, without any apparent business purpose.
The customer deposits funds to purchase a long-term investment and shortly thereafter makes a request to close the position and transfer the proceeds out of the account.
The customer requests that the transaction be processed in this manner to avoid the company's normal documentation requirements.
Know Your Customer - Identify Basis for Suspicion
Suspicious transactions are usually inconsistent with the customer's known legitimate business or personal activities or the normal business of that type of customer. Therefore, the first key to identifying suspicious transactions is to understand the customer's business well enough to recognize whether a transaction or series of transactions is unusual.
When determining whether a transaction from a regular customer is suspicious, you must consider the following questions:
Is the size of the transaction consistent with the customer's normal activities?
Is the transaction rational in terms of the customer's business or personal activities?
Have the customer's trading patterns changed?
Suspicious circumstances
Issues that should raise your suspicion include:
Customers who are unwilling to provide proof of identity;
Customers who are overly dependent on referrals (who may hide behind referrals and avoid revealing their true identity or business to you);
Business requests related to cash, such as asking if investments can be made in cash, suggesting that investments can be made in cash;
Investment funds whose source is unknown;
When the amount of available funds is inconsistent with the customer's other circumstances (i.e., the source of wealth is unclear). For example, students or young people may have a lot of money to invest;
The transaction does not seem reasonable in the customer's business or personal activities. If a customer changes the way they trade with you without a reasonable explanation, you should be cautious in this regard;
Changes in trading patterns;
When customers who trade internationally do not seem to have any good reason to do business with the countries in question (for example, why do they hold funds in specific countries where funds are flowing to or from? Does their situation make it reasonable for them to hold funds in these countries?);
The client is unwilling to provide you with normal personal or financial information for no apparent or reasonable reason. (Care should be taken not to treat all long distance relationships as suspicious, as most are for genuine reasons. Suspicion is usually based on cumulative issues, not independent ones)
Money launderers may provide convincing arguments to explain the reasons for their transactions. These arguments should be questioned to determine whether the transaction is suspicious.
Reporting suspicions
If, for whatever reason, we suspect that a client or anyone they represent may be conducting (or attempting to conduct) a transaction involving the proceeds of any crime, this must be reported in writing as soon as possible.
An internal report must be filed regardless of whether any business has been written or is intended to be written.
Investigation
After notification to the AML Compliance Committee, an investigation will be initiated to determine whether a report should be made to the appropriate law enforcement or regulatory authority. The investigation will include a review of all available information, such as payment history, date of birth and address. If the findings of the investigation are justified, a recommendation will be made to the AML Compliance Committee to file a special investigation report with the appropriate law enforcement or regulatory authority. The AML Compliance Committee is responsible for any notifications or filings with law enforcement or regulatory agencies
The results of investigations will not be disclosed or discussed with anyone other than those with a legitimate need to know. Under no circumstances may any officer, employee or designated agent disclose or discuss any AML issue, investigation, notification or SAR filing with a relevant person or any other person, including family members of the officer, employee or designated agent.
Freezing Accounts
If we know that the funds in an account are derived from criminal activity, or from fraudulent instructions, the account must be frozen. If it is believed that the account holder may have been involved in fraudulent activity that is being reported, it may be necessary to freeze the account.
IQGlobal Limited is registered in Comoros, with Registration Number 15984, holding an International Brokerage Clearing House License with License ID L15984/IQGL.
The registered office is at Hamchako, Mustamudu, The Autonomous Island of Anjouan, 1212, Union of Comoros.
The operational office is located in Hong Kong, with address at Unit 12E, 14th Floor, Yue Fung Industrial Building, 35-45 Chai Wan Kok Street, Tsuen Wan Nt, Hong Kong
Email: support@iqglobal-trade.com
Landline: (+852) 35007293
Disclaimer:
IQGlobal is committed to providing the highest level of service to its customers. In some instances, and due to regulatory or legal requirements, IQGlobal is unable to provide services or accept customers from certain countries. Currently IQGlobal does not accept customer from the US, Canada, Yemen, Iran, Cuba, Sudan, Syria, and North Korea. Customers should familiarise themselves with the FX rules applicable in their country's before deciding to use IQGlobal services.
Risk Disclosure:
Trading foreign exchange on margin carries a high level of risk, and may not be suitable for all investors. The high degree of leverage can work against you as well as for you. Before deciding to trade foreign exchange you should carefully consider your investment objectives, level of experience and risk appetite. The possibility exists that you could sustain a loss of some or all of your initial investment and therefore you should not invest money that you cannot afford to lose. You should be aware of all the risks associated with CFD and foreign exchange trading, and seek advice from an independent financial advisor.
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