AML / KYC Policy

This is the client-facing summary of our anti-money-laundering programme. The full programme – risk assessment, internal procedures, reporting lines and training records – is maintained internally and is available to our regulators on request.

5.1 Commitment. AvexFx does not tolerate the use of its services for money laundering or terrorist financing. We comply with the anti-money-laundering law applying to the entity that holds your account: in Cyprus the Prevention and Suppression of Money Laundering Activities Law and the EU anti-money-laundering directives, in Seychelles the Anti-Money Laundering and Countering the Financing of Terrorism Act, and in Mauritius the Financial Intelligence and Anti-Money Laundering Act and with applicable sanctions regimes.

5.2 Risk-based approach. We assess money-laundering risk by client, product, delivery channel, payment method and geography, and apply due diligence proportionate to that risk. The assessment is documented and reviewed at least annually.

5.3 Customer due diligence. We verify every client before the account is funded or traded. We do not operate anonymous or numbered accounts.

Individuals – we collect and verify:

• Full legal name, date of birth, nationality, residential address
• Government-issued photo identity document (passport, national ID or driving licence), valid and unexpired
• Proof of address dated within the last 3 months (utility bill, bank statement, government correspondence)
• Contact telephone and email, both verified
• Occupation, expected trading activity, source of funds, and where risk warrants it, source of wealth

Legal persons – we additionally collect: certificate of incorporation, constitutional documents, registered and trading address, proof of the directors’ and authorised signatories’ identity, ownership structure, and identification of every beneficial owner holding more than 25%.

5.4 Enhanced due diligence. We apply EDD, including senior management approval before onboarding and closer ongoing scrutiny, where: the client is a politically exposed person, a family member or known close associate of one; the client or their funds are connected to a high-risk third country; the ownership structure is unusually complex or opaque; the relationship is conducted entirely non-face-to-face in circumstances of elevated risk; or activity is inconsistent with what we know of the client.

A politically exposed person is someone who holds or has held a prominent public function – a head of state or government, senior politician, senior government, judicial or military official, senior executive of a state-owned enterprise, or an important political party official – together with their immediate family and known close associates. PEP status is not an accusation and does not by itself bar an account. It requires additional scrutiny, senior approval, and establishing the source of both funds and wealth.

5.5 Sanctions screening. All clients and beneficial owners are screened against UN, EU, OFAC, UK and any other applicable sanctions and watch lists at onboarding and on an ongoing basis, including on list updates. A confirmed match results in refusal or freezing, and reporting as required.

5.6 Restricted jurisdictions. We do not accept clients resident in the United States, Belgium, Iran, Canada or North Korea, or in any other jurisdiction where we are not permitted to offer our services. Residence is established from the proof of address collected under 5.3, before your account is approved for trading and before we accept a deposit. It is checked again whenever your details change, on sanctions and watch-list updates, and on periodic review. Where verification shows that you are resident in a restricted jurisdiction we will decline the account and return your funds to the source they came from.

5.7 Accounts and payments. Accounts are opened and operated in the client’s own name only. We do not accept accounts operated for an undisclosed third party, and account sharing is not permitted.

Third-party payments are not accepted in either direction. Deposits must come from an account or instrument held in the client’s own name, and withdrawals are returned to the same source, in the same currency, up to the amount deposited, before any profit is paid to an alternative verified method. Cash is not accepted.

Where a deposit is made by cryptocurrency or e-wallet, we establish source of funds before the funds are credited: the wallet or account must be in your own name, you must be able to demonstrate control of it, and the exchange or provider must itself perform customer due diligence. We may decline any payment method we consider to carry unacceptable risk.

5.8 Ongoing monitoring. We monitor the relationship and the transactions through it for consistency with what we know of the client, their business and their risk profile. We keep client information current and may request updated documents at any time. Trading patterns with no apparent economic purpose – including funding an account, trading minimally and withdrawing – are investigated.

5.9 Reporting. Where we know or suspect that funds derive from criminal conduct or relate to terrorist financing, our Money Laundering Reporting Officer reports to the financial intelligence unit for the entity that holds your account – MOKAS in Cyprus, the Financial Intelligence Unit of Seychelles, or the Financial Intelligence Unit of Mauritius. We are prohibited by law from informing you that a report has been made, or from disclosing the content of any investigation. This is why we may be unable to explain a refusal, a freeze or a delay.

5.10 Refusal and termination. We may refuse to open an account, decline a transaction, freeze an account, or terminate the relationship where due diligence cannot be completed, documents are not provided, information appears false, or we have concerns we cannot resolve. Where we do so lawfully we are not liable for any resulting loss.

5.11 Governance. We appoint an MLRO with sufficient seniority and independence, at senior management level, whose identity is notified to the regulator of the entity that holds your account. All relevant staff receive AML training at induction and at least annually, and training is recorded. The programme is subject to independent review.

5.12 Records. We retain client identification records and transaction records for at least five years after the relationship ends or the transaction completes, or longer where required. Retention for AML purposes is a legal obligation and overrides erasure requests under data protection law; see the Privacy Policy.

5.13 Your cooperation. Providing complete and accurate information promptly is a condition of holding an account. Delays in verification are the most common cause of delayed withdrawals. Last reviewed 21 September 2026.