Anti-Money Laundering (AML) Policy
Promax Trading Limited • December 2024 Compliance Framework
Promax Trading Limited
Registration No: 2024-00683 | IBC Act Cap 12.14
Registered Address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia.
Website: https://www.promaxtrading.com/
Introduction & Purpose of Policy
Promax Trading Limited (the "Company") is incorporated in Saint Lucia under the International Business Company's Act Cap 12.14 with registration number 2024-00683. The Company operates commercial financial, Forex brokerage, and CFD trading services.
The Company aims to prohibit, detect, and actively pursue the prevention of money laundering, terrorism financing, and predicate offences. The Company is dedicated to adhering to the highest international AML and CTF standards while fully complying with the laws of Saint Lucia.
Legal Framework
The applicable Legal Framework governing the Company includes:
- International Business Companies Act - Cap. 12.14
- Money Services Business Act - Cap 12.22
- Anti-Terrorism Act 2 - Cap. 3.16
- Money Laundering Prevention Act - Cap. 12.20
- Proceeds of Crime Act – Cap. 3.04
- UN Sanctions (Counter-Proliferation Financing) Act
- The Financial Services Regulatory Authority Act
- Regulations adopted by Financial Intelligence Authority (FIA), FATF, and CFATF
Stages of Money Laundering & Key Offences
Physical disposal of cash proceeds into legitimate financial systems.
Separating criminal proceeds via complex wire transfers, nominees, or shell companies.
Placing laundered funds back into economy as legitimate business assets.
Tipping Off Offence: Informing a suspect that a suspicious activity report or investigation has been initiated is a criminal offence.
Failure to Disclose: Failure to report a suspicious transaction within 7 days is a statutory offence.
Know Your Customer (KYC) Documentation
Records are retained for a minimum of 7 years from the transaction date or termination of business relationship.
Individual Clients
- Proof of Identity: Passport, National ID card, or Driver's License.
- Proof of Address: Utility bill (gas, water, electric) issued within last 3 months, or bank statement.
- EDD Requirements: Source of funds declaration, income proof.
Corporate Clients
- Certificate of Incorporation, Articles of Association, Business License.
- Proof of corporate address (utility bill / bank statement in company name).
- Identity proof for Directors, Shareholders (owning 25%+), and Authorized Signatories.
- Ultimate Beneficial Owner (UBO) verification.
Customer Due Diligence (CDD, SDD & EDD)
Customer Due Diligence (CDD): Mandatory identification verification performed upon business relationship establishment, when conducting occasional transactions above $25,000, or when suspicious activity is detected. Anonymous accounts or passbooks are strictly prohibited.
Enhanced Due Diligence (EDD): Applied to high-risk clients, non-face-to-face accounts, trust accounts, bearer share entities, cross-border correspondents, and Politically Exposed Persons (PEPs). EDD requires senior management approval and source of wealth verification.
Ongoing Monitoring & Transactions Exceeding $25,000
The Compliance/AML Officer maintains automated electronic management information systems to continuously monitor account turnover against economic profiles.
Any transaction or business activity exceeding $25,000.00 requires completion of a formal Source of Fund Declaration. Making a false declaration is a serious offence.
Suspicious Activity Reports (SAR) & Review
When reasonable suspicion of money laundering or terrorist financing exists, the AML Compliance Officer files an external Suspicious Activity Report (SAR) with Saint Lucia financial intelligence authorities.
This policy is audited annually by Internal Audit and reviewed by senior management at least every six months.
AML Compliance Inquiries
For further inquiries regarding our Anti-Money Laundering procedures, contact:
compliance@promaxtrading.com