ANTI-MONEY LAUNDERING POLICY STATEMENT

• Banyan Grow is committed to the highest standards of Anti-Money Laundering (AML) compliance and expects management and employees to uphold these standards in order to prevent the use of our goods and services for money laundering. Banyan Grow is dedicated to regularly assessing its anti-money laundering goals, plans, and tactics. Additionally, the business maintains a successful anti-money laundering policy that complies with industry standards for foreign financial brokerages. Respecting XCTrader's anti-money laundering procedure is the responsibility of every employee.The program includes record-keeping guidelines, client screening and monitoring procedures, "know your customer" guidelines (such as determining the identities of beneficial owners), reporting suspicious activity in accordance with applicable legal requirements, and anti-money laundering (AML) training.

• Objectives
• The Banyan Grow Global Anti-Money Laundering Programme (often referred to as the "AML Programme") contains minimum criteria that are applicable to Banyan Grow and are predicated on pertinent legal and regulatory requirements. These rules are designed to prevent Banyan Grow, our employees, and our clients from being unjustly utilized for financial crimes including money laundering or financing terrorist endeavors. The AML Program establishes the general framework for preventing the funding of terrorism and money laundering.

• Applicability


• It is the responsibility of Banyan Grow to guarantee that our affiliates and affiliated companies around the globe carry out their legal duties resulting from the regulations that have been established. When local regulations surpass the parameters specified in the AML Program, the strictest requirement needs to be adhered to. To resolve any legal disputes that may emerge in relation to the AML Program, Banyan Grow must meet with the local legal department. In a given country, Banyan Grow shall ensure that it will not follow the minimal criteria established in the AML Programme if doing so would violate local law or be impossible to enforce for non-legal reasons.


• Create a business relationship;


• 
  
• Carry out any required transactions. Regardless of any lingering legal or contractual obligations, Banyan Grow must make sure that any business connections that are presently in existence in that country are terminated.

• An explanation of what money laundering is
• Money laundering is the process of introducing assets derived from illegal and criminal activities (predicate offenses) into the legal financial and commercial cycle. A few instances of crimes are drug trafficking, extortionate robbery, fraud, corruption, organized crime, and money laundering. The basic charges for money laundering are outlined in local statutes. The money laundering process generally involves three "stages":
• Placement:
  The introduction of money or other illegally obtained assets into non-financial or financial institutions.
• Layering:
  The method of isolating illegal profits from their origin through a series of complex financial transactions. These tiers are designed to provide anonymity, conceal the funding source, and impede the audit trail.
• Integration:
  Putting money laundering proceeds back into the economy in a way that makes them legitimate money when they enter the banking system. These "stages" are fluid and frequently overlap one another. Financial institution abuse could occur at any point in the money laundering process.

• MANAGEMENT AND CONTROLS OF AML RISKS
• Banyan Grow' anti-money laundering (AML) program is based on the Financial Action Task Force (FATF) Recommendations, which provide a comprehensive and consistent framework of measures to be taken in order to combat money laundering, financing of terrorism, and financing of the proliferation of weapons of mass destruction. Included in the AML Program, but not limited to:


• 1. Customer Due Diligence Program: This comprises establishing a number of appropriate programs to handle incomplete customer due diligence on current clients as well as identifying and validating clients in accordance with Know Your Client rules.


• 2. Customer Due Diligence protocols to manage specific risks in virtual business transactions.


• 3. Clients who are deemed to be more vulnerable—for example, those who are politically exposed or have close ties to those who are—are subject to enhanced due diligence procedures.


• 4. Putting procedures and regulations in place to monitor client transactions and identify any odd behavior.


• 5. Ensuring that directors, employees of Banyan Grow, and members of the management committee receive regular and appropriate training on AML/CFT laws and regulations, customer due diligence practices, and how to recognize and report suspicious transactions.


• 6. Establishing strict hiring procedures to ensure high standards for directors, management committee members, and employees.

• MINIMUM REQUIREMENTS
• Prospective clients wishing to transact with Banyan Grow will be subject to the following anti-money laundering controls and procedures in order to ensure that client cash or assets are not being used as proceeds from drug sales, criminal activity, or financing of terrorism.
• Identification and Verification of Customer Identity: Before beginning a commercial connection, Banyan Grow will verify a client's identity by gathering the required information about them and by using reliable, independent sources of data, papers, or information to validate their identity.
• Identification and Verification of Beneficial Owner: If Banyan Grow finds relevant information or data from credible, independent sources, it will use it to assess whether the customer has any beneficial owners. Additionally, it will verify and identify the beneficial owners.
• Continuing Monitoring: Every client will be the subject of ongoing supervision, which entails attentively monitoring all transactions made during business dealings and keeping an eye on how their account is being managed. Customers' transactions have to match their funding source and financial profile.
• Prohibited Activities: Banyan Grow will not maintain accounts that are anonymous, have fictitious names, have been tampered with, or have phony documentation.
• Reporting of Suspicious Transactions: It is mandatory for Banyan Grow to report any suspicious transaction, including attempts at transactions, to the relevant local authorities. The Group Anti-Money Laundering Department will be notified of any transaction that gives rise to concerns.

• RETENTION OF RECORD
• All client-related information and documentation, transactions, account files, business correspondence, and analytical results have to be retained on file for a minimum of ten years.

• PROHIBITED BUSINESS RELATIONSHIPS
• Banyan Grow will not establish a business relationship with a client or will end an existing one if Banyan Grow cannot reasonably ascertain the true identity of the client and/or beneficial owners, or if the client is unwilling or reluctant to provide any information or document requested by Banyan Grow. In particular, the business will not:


• Accept funds that are believed or proven to be the proceeds of illicit activity.


• Create or maintain business relationships with individuals or groups that are listed as sanctioned, suspected of being terrorists, members of criminal organizations, or both.


• Establish alliances with clients from countries that are prohibited or restricted.


• Make relationships with customers who operate in sensitive, hazardous, or illegal industries.

• Controls
• To make sure the firm's efforts are successful, adherence to the global AML program needs to be reviewed on a regular basis. As a result, the Banyan Grow AML Officer must carry out the relevant processes. The responsible AML Officer can ensure that security measures are working as intended and that all applicable AML standards are met by implementing adequate controls over consumers and business operations.

• Risk Analysis
• Banyan Grow has created an ongoing AML Risk Analysis to identify the appropriate security measures based on the firm's clients, goods, services, companies, and geographic locations. The purpose of this study is to evaluate the firm's exposure to risk. AML protections are determined by looking at the results of the AML Risk Analysis.

• KYC Programme
• Banyan Grow has implemented a strict KYC process to ensure that all types of customers—whether they be natural persons, legal entities, or both—are subject to the proper identification, risk assessment, and monitoring processes. This initiative has been implemented globally. KYC involves knowing the clients and companies that the firm works with or services, as well as the Ultimate Beneficial Owners (UBOs), Authorized Signatories, and Legal Representatives as needed. The program consists of rigorous identification criteria, name screening procedures, regular evaluations, and oversight of all active business relationships. When doing business with clients from high-risk countries or industries, as well as politically exposed people (PEPs), certain measures are put in place.

• Training Programme
• To ensure that all staff members, particularly those in charge of handling transactions and/or establishing and preserving business relationships, have received AML awareness training, Banyan Grow has implemented an extensive AML training program. Banyan Grow has created specialized training for the organization to ensure that staff members are aware of the different money laundering strategies and patterns that may come up over the course of their daily duties. Training covers financial criminal activity and money laundering typologies as well as general obligations arising from pertinent external (legal and regulatory), internal, and individual requirements that must be followed in day-to-day operations.

• Reliability of Staff


• Banyan Grow has established protocols to ensure that they are only partnered with reliable individuals.

• INDEPENDENT TESTING
• The AML program criteria will be independently verified by Banyan Grow's Internal Audit department and the Semi-Annual External Auditor.