AML & KYC Policy – Recommended Amendments for Trading TP
Your AML & KYC Policy is already comprehensive. Only the following additions are recommended to cover the Copy Trading and Internal Transfer features.
Add to Section 3 – Risk Assessment & Classification
The Company may also consider Copy Trading activity, Internal Transfer activity, relationships between Master Traders and Copy Traders, unusual profit-sharing patterns, and abnormal internal transfer behavior when assessing account risk.
Add New Section After Section 7
7A. Copy Trading Compliance
The Company may monitor Copy Trading relationships to detect fraud, market manipulation, coordinated trading activity, artificial performance inflation, abuse of profit-sharing mechanisms, or any attempt to circumvent Platform policies.
Trading TP reserves the right to suspend, investigate, or permanently remove any Master Trader or Copy Trader where suspicious activity is identified.
Add New Section
7B. Internal Transfer Monitoring
Internal Transfers are subject to continuous AML and fraud monitoring.
Trading TP may delay, reject, suspend, reverse (where appropriate), or investigate Internal Transfers where there are reasonable grounds to suspect:
- Money laundering.
- Fraud.
- Unauthorized account access.
- Sanctions violations.
- Terrorist financing.
- Circumvention of Platform limits.
- Abuse of promotional programs.
- Multiple-account schemes.
- Any activity inconsistent with the legitimate use of the Platform.
Add to Section 10 – Source of Funds & Withdrawal Controls
The Company may require additional verification before approving withdrawals where funds have been received through Internal Transfers or where significant Copy Trading profits generate enhanced compliance concerns.
Additional documentation may be requested before withdrawals are approved.
Add to Section 11 – Internal Compliance Oversight
Compliance reviews may include analysis of Copy Trading activity, Internal Transfer history, linked accounts, blockchain transaction patterns, device identifiers, and other internal fraud prevention indicators.
Add to Section 13 – Cooperation with Authorities
Where legally required, information relating to Internal Transfers, Copy Trading activity, transaction history, identity verification, blockchain analysis, and compliance investigations may be disclosed to competent authorities or authorized regulatory bodies.