Anti-Money Laundering policy

1. INTRODUCTION

2. OXTRADES AML POLICY

3. ACCOUNT OPENING PROCEDURES - KNOW YOUR CUSTOMER POLICY (“KYC”)

4. BANK ACCOUNT REQUIREMENTS

5. FUNDS WITHDRAWAL PROCEDURE

6. COMPLIANCE FOOTNOTE

 

ANTI-MONEY LAUNDERING POLICY INTRODUCTION

Voya Group (IBC) LTD (hereinafter referred to as ‘Oxtrades” or the ‘Company’)

is registered in St. Lucia, with registration number 2024-00158. The

Company’s registered address is located ADCO INCORPORATED, #10 MANOEL STREET, CASTRIES, ST. LUCIA.

Additionally, Oxtrades carries out its activities in line with the Financial Intelligence

Centre Act, 2001 (Act No. 38 of 2001) as amended by the Protection of

Constitutional Democracy against Terrorist and Related Activities Act, 2004 (Act

No. 33 of 2004), the Financial Intelligence Centre Amendment Act, 2008 (Act No. 11

of 2008), the General Intelligence Laws Amendment Act, 2013 (Act No. 11 of 2013),

the Financial Intelligence Centre Amendment Act, 2017 (Act No. 1 of 2017) and the

Financial Sector Regulation Act, 2017 (Act No. 9 of 2017).

Oxtrades also follows the Financing Control Regulations, under Money Laundering

and Terrorist Financing Control Regulations, 2002, published in Government Notice

No. R. 1595 of 20 December 2002 as amended by GN R456 in Government Gazette

27580 of 20 May 2005 and GN R867 in Government Gazette 33596 of 1 October

2010 and GN 1107 in Government Gazette 33781 of 26 November 2010 and GN R.1062

in Government Gazette 41154 of 29 September 2017. The Minister of Finance has, in

terms of section 77 of the Financial Intelligence Centre Act, 2001 (Act No. 38 of 2001),

made the regulations set out in the Schedule.

Furthermore, Oxtrades is operating in line with the FATF Recommendations. The

“Financial Action Task Force” (“FATF ‘’) set standards and promote effective

implementation of legal, regulatory, and operational measures for combating

money laundering, terrorist financing and other related threats to the integrity of

 

the international financial system. Starting with its own members, the FATF monitors

countries’ progress in implementing the FATF Recommendations; reviews money

laundering and terrorist financing techniques and countermeasures; and promotes

the adoption and implementation of the FATF Recommendations globally.

OXTRADES AML POLICY

At Oxtrades we are devoted in preventing money laundering activities and identifying

suspicious transactions, therefore we have implemented the following measures to

comply with our regulatory requirements:

• Verifying our client’s identity and place of residence.

• The nature of the client’s business.

• The intended purpose of the business relationship concerned and the source of

the funds which the client expects to use.

• Identifying, monitoring and reporting any kind of suspicious transactions.

• Keeping documents and records for at least 5 years after the termination of the

business relationships with our clients.

• Continuous training of our staff to recognize suspicious transactions, fulfill all

reporting obligations and keep up to date with the AML regulatory requirement.

• Depending on client location, report any suspicious activities to authorities in

several countries.

In addition to the abovementioned OXTRADES:

• Collects, verifies and updates at least annually the personal identification

information of all account holders.

• Tracks any suspicious transactions made by clients and any transactions

executed under non-standard trading conditions.

• Does not accept deposits from 3rd parties nor cash deposits or disbursements

under any circumstances.

• Matches each deposit to the account name held on file for that customer.

• Monitors funding from bank accounts held outside the account holder’s home

country.

• Reserves the right to refuse to process a transaction where it believes the

 

transaction to be connected in any way to money laundering or criminal

activity. In accordance with international law, Oxtrades is under no obligation

to inform the client when suspicious activity is reported to any corresponding

regulatory or legal bodies.

! All OXTRADES client funds are held in separate, segregated accounts that are

designated solely for client deposits and withdrawals!

ACCOUNT OPENING PROCEDURES

KNOW YOUR CUSTOMER POLICY (“KYC”).

Account Opening Requirements

• In order to open a trading account with Oxtrades, the potential client must have a

permanent residence in a country not within the European Economic Area (EEA)

and be over 18 years old. In addition, the steps listed below must be followed:

• complete the account opening application, which includes providing personal

information (name, date of birth, etc), information relating to his/her economic

profile (annual income, estimated net worth, employment status, etc.)

• complete the appropriateness test

• provide identification documents which consist of a valid form of government issued identification and a proof of residence

! Please note that from the day of receipt of the account opening application

a timeframe of 1 month is given to provide the required information and

documentation. If the potential client fails to provide these within the

aforementioned timeframe, the Company will decline the application and in case

of any deposits, will refund the available balance back to the method used to

deposit the funds.

Identification Documents:

1. Proof of Identity

Following documents are accepted as a Proof of Identity:

• A valid Passport

• A valid National Identity Card

• A valid government ID, such as a Driver’s License

 

• A valid Residence Permit

The document must be issued on your name and all information on the

document including your photo must be visible.

! Please keep in mind that your Proof of Identity must be updated once the

document expires.

! All photo IDs are verified through a third-party compliance software.

The Company reserves the right to ask for certified true copies of the above

mentioned documents.

2. Proof of Residence

Following documents are accepted as a Proof of Residence:

• A utility or phone bill

• A bank statements

• Governmental documents such as tax bill or residence certificate

(stamped)

• Please note that your proof of residence document must be recent (not

older than 6 months), show your name, permanent address and date of

issue.

Please keep in mind that your Proof of Residence must be updated at least once per year! (After the documents are provided it will be checked and accepted or rejected within 3 business days.)

The Company reserves the right to ask for certified true copies of the above

mentioned documents.

Additionally, the company reserves the right to request additional documents

from its clients whenever it deems necessary.

BANK ACCOUNT REQUIREMENTS.

Oxtrades account holders must have a valid bank or credit card account in their

name. The bank/credit card statement must show their name and the same

registered address as that shown on their application.

FUNDS WITHDRAWAL PROCEDURE.

The withdrawal procedure at Oxtrades detailed below follows strict principles to

ensure that the funds are sent back to their originating source.

a. Oxtrades customers must complete a signed paper or digital withdrawal request

 

containing inter alia, their correct account information.

b. The withdrawal form must be submitted to the Oxtrades Finance department for

processing. The Finance department will do the following:

• confirm the account balance

• confirm that the account is approved and the provided documents are up-to date.

• verify that there are no holds or withdrawal restrictions on the account

• verify that the original funds are being withdrawn through the same method of

deposit and to the name of the account holder on file

• examine the withdrawal request against the customer’s deposit history to

ensure there is no suspicious activity

• verify the bank account details held on file

• If there is no mismatch or suspicious activity the Finance Department will

approve and the money will be sent to the customer within 7 business days by the method of customer's choice.

• In the event that the Finance Department believes there was suspicious activity

on the account, the Oxtrades Anti-Money Laundering Compliance Officer

(AMLCO) will be informed, in order to perform further investigation.

• If the withdrawal is flagged for suspicious activity by the Oxtrades AMLCO, the

withdrawal is placed on hold, and sent to the Oxtrades Management.

• Oxtrades Management along with the Oxtrades AMLCO will decide if further

action is needed and which, if any, relevant regulatory bodies need to be

contacted.

! Please note that your trading account must be verified in order for the withdrawal

to be processed!

COMPLIANCE FOOTNOTE.

The compliance procedure related to AML listed above is only a brief summary of

the compliance function guidelines followed by the Oxtrades Compliance Team.

A detailed copy of our Compliance Policy is available for qualified institutions,

regulatory bodies and related counterparties.

No substitutions or modifications will be accepted to the requirements above. The

Oxtrades Compliance Department reserves the final determination regarding the

validity of these documents.

 

1. Clients should assume that all information provided to the Company is available

to the competent regulatory authorities in the country of incorporation of the

Company, i.e. the of St. Lucia Island;

2. the country of origin of any funds transmitted to Oxtrades; and

3. the destination country of any funds refunded by or withdrawn from the

Company.

Oxtrades does not wish to enter into a business relationship if the funds are sourced

from criminal activities or if the nature of your account transactions is illegal in any

manner whatsoever.

The Company reserves the right to review and/or amend its Anti Money Laundering

Policy, at its sole discretion, whenever it deems fit or appropriate.

Our AML Policy is a policy only but is not part of our Terms and Conditions of

Business and is not intended to be contractually binding.

For additional questions concerning Oxtrades policies, please contact our Compliance

Department:

Email: [email protected]

Attn. Compliance Department, Voya Solutions (PTY) LTD, registration 2024-00158.

Address: The Company’s registered address is located at ADCO INCORPORATED, #10 MANOEL STREET, CASTRIES, ST. LUCIA.

Voya Group (IBC) LTD

Oxtrades is operated by Voya Group (IBC) LTD, a St. Lucia investment firm,

Voya Group (IBC) LTD, registration number 2024-00158.

Registered Address: The Company’s registered address is located at ADCO INCORPORATED, #10 MANOEL STREET, CASTRIES, ST. LUCIA.

Website: www.Oxtrades.com

Email: [email protected]