Introduction

QuiqTech LLC (hereafter “Abbado” or the “Company”) is a Company incorporated and registered under the laws of Saint Vincent and the Grenadines.

The objective of the Anti-Money Laundering Policy (hereinafter referred to as the “Policy”) is to establish the internal practices, measures, procedures, and controls essential for preventing money laundering and terrorist financing within the Company. This Policy is applicable to all services provided to the Company’s Clients, encompassing the Company’s interactions with its Clients. This includes foreign exchange trading transactions, specifically those that do not involve the physical delivery of the agreed foreign currency or are not materially settled in cash (foreign exchange spot trading). The Policy applies uniformly, regardless of the size of the Client’s account or the frequency of trading activities.

Money laundering is the procedure through which illicitly obtained funds are processed within legitimate systems and enterprises, allowing them to be purified and ultimately returned to the criminal in the guise of lawful money.

The money laundering cycle comprises three main stages, commonly known as:

– Placement: This denotes the introduction of illicit funds into legitimate institutions.

– Layering: This is the intricate phase of the money laundering cycle, typically involving numerous transactions aimed at concealing the identity of the individual and/or erasing any trace of the fund’s source. This may encompass multiple electronic transfers or the utilization of traded products and/or services. The objective is to swiftly transform assets into a different form while concealing or altering the original source of the funds. Consequently, transactions may occur through various licensees, potentially involving different products—anything facilitating rapid ownership transfer and mechanisms that complicate or obscure an audit trail.

– Integration: In this stage, money is reintegrated into the possession of the money launderer as legitimate funds and can be employed for any purpose. The Company adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing of illegally gained funds. AML policy means preventing the use of the company’s services by criminals, with the aim of money laundering, terrorist financing or other criminal activity. To prevent money laundering, QuiqTech LLC neither accepts nor pays cash under any circumstances. The company reserves the right to suspend any client’s operation, which can be regarded as illegal or may be related to money laundering in the opinion of the staff.

Company Risk Based Approach

The Company employs suitable measures and procedures, utilizing a risk-based approach, to concentrate its efforts on areas where the risk of Money Laundering and Terrorist Financing is perceived to be comparatively higher.

The risk-based approach implemented by the Company encompasses specific measures and procedures to determine the most cost-effective and suitable methods for identifying and managing Money Laundering and Terrorist Financing risks. These measures include:

– Evaluating and appraising the Money Laundering and Terrorist Financing risks associated with specific Clients or types of Clients, financial instruments, services, and geographical areas of its Clients’ operations.

– Effectively managing and mitigating the identified risks through the application of suitable measures, procedures, and controls.

– Ongoing monitoring and enhancements to ensure the efficient operation of the policies, procedures, and controls.

Company Procedures

The Client Acceptance Policy (referred to hereinafter as the “CAP”) outlines the criteria for the admission of new Clients and establishes the criteria for Client categorization to be adhered to by the Company, particularly by employees involved in the Client Account Opening process. The Company ensures verification of the authenticity of individuals or legal entities and conducts all necessary measures in accordance with applicable laws and regulations issued by regulatory authorities. The Company’s procedures for Anti-Money Laundering (AML) purposes encompass, among other things:
– Know Your Customer (KYC) and Due Diligence;

– Monitoring client activity; and

– Record-keeping.

Know Your Customer (KYC) and Due Diligence

The Company has implemented Anti-Money Laundering (AML) and Know Your Customer (KYC) policies, which may require each prospective client to undergo a thorough verification process. When establishing a business relationship with any client, the Company may request the Client to submit satisfactory evidence or take other measures to obtain sufficient proof of the customer’s or counterparty’s identity. Additionally, enhanced due diligence is applied to clients residing in countries identified by credible sources as having insufficient AML standards or posing a high risk of crime and corruption. The same heightened scrutiny applies to beneficial owners residing in and sourcing funds from jurisdictions considered high risk.

Individual Clients

The Company will collect the following details to verify the authentic identity of individuals:

– Legal name and any aliases as per the official identity card or passport;

– Complete permanent address, including postal code;

– Contact numbers (home and mobile), as well as fax numbers;

– Email address, if available;

– Date and place of birth;

– Nationality; and

– Professional and occupational details of the Client, including the name of the employer or business organization.

To authenticate the Client’s details, the Company will ask the Client to provide the following documents:

– Present a valid passport with a clear view of the first page, displaying the photo and signature;

– Submit a driver’s license with a photograph;

– Provide a national identity card, including both the front and back pages;

– Provide documentation validating the current permanent address, such as utility bills or bank statements.

These documents must display the client’s full name and place of residence and should not be more than 3 months old from the filing date.

Corporate Clients

For legal entity clients, the Company will verify that the natural person representing them is duly authorized and their identity is duly established and verified. The Company will take all necessary steps to comprehensively understand the control and ownership structure of the legal entity and verify the identity of the natural persons acting as Beneficial Owners and exercising control over the entity. Corporate clients will be required to submit the following documents:

– Certificate of Incorporation or its national equivalent;

– Memorandum and Articles of Association, along with statutory statements or their national equivalents;

– Certificate of good standing or alternative proof of the registered address of the company;

– Board resolution authorizing the opening of an account and granting authority to those who will operate it;

– Copies of powers of attorney or other authorities granted by directors concerning the company;

– Proof of identity of directors if they are dealing with the Company on behalf of the

Customer (in accordance with the individual identity verification rules outlined above).

Note: If the legal entity applicant is listed on a recognized or approved stock exchange, or if there is independent evidence indicating that the applicant is a wholly owned subsidiary or under the control of such a legal entity, additional identity verification measures are generally not necessary.

Monitoring of client activity

In addition to obtaining information from clients, the Company consistently monitors the activities of each client to detect and prevent any potentially suspicious transactions. A transaction is deemed suspicious if it deviates from a client’s known, legitimate business or personal activities, or from the typical operations of the specific account, and more broadly, from the economic profile established by the Company for the client. The Company ensures it possesses sufficient information and insight into its clients’ activities to promptly identify any unusual or suspicious transactions. To achieve this, the Company:
– Conducts continuous monitoring of changes in the client’s financial status, business activities, and transaction types; and
– Engages in ongoing monitoring to identify whether any client is involved in practices outlined in the list containing examples of what may constitute suspicious transactions/activities related to Money Laundering and Terrorist Financing.

Record keeping

The Company is required to retain records of:

– Client identification documents and information acquired during the Client identification and due diligence procedures, as applicable; and

– All pertinent details related to the provision of investment services to Clients.

These documents and data, as specified above, must be preserved for a duration of seven (7) years, calculated from the execution of transactions or the termination of the business relationship.

Deposit and withdrawal requirements

The following guidelines pertain to all deposits and withdrawals:

– The Company does not accept any form of cash.

– The Company does not facilitate the receipt or deposit of funds to any third parties.

– Funds transferred to the Company must originate from a cryptocurrency account, bank account, Credit/Debit card, or Alternative Payment Method registered under the same name as the trading account with the Company.

– Client withdrawals should be executed using the same method employed by the Client for funding their Client Account and must be directed to the same remitter. The Company reserves the right to reject a withdrawal with a specific payment method, suggesting an alternative where the Client needs to initiate a new withdrawal request or provide additional documentation. In cases where applicable, the Company reserves the right to return Client funds only in the currency of the initial deposit. If the Company finds any provided documentation unsatisfactory, the withdrawal transaction may be reversed, and the amount will be deposited back into the Client’s Account net of any charges/fees imposed by the Client’s Bank Account providers.

– All withdrawal requests are processed based on the funding source of origin. For instance, if a deposit is made via a Debit/Credit Card, a subsequent withdrawal request may not exceed the original deposited amount. Profits exceeding the deposited amount may be transferred to a nominated bank account, held under the same name as the trading account.

– Initial withdrawal requests may undergo verification for safety and security, requiring the provision of a bank statement or account statement containing account holder information and bank details. The Company does not accept deposits or withdrawals under a different name than the registered name with the Company.

– If a trading account was credited in a manner unsuitable for funds withdrawal, the funds may be withdrawn to a bank account under the same name as the trading account with the Company, provided the client submits satisfactory evidence of ownership for both the source and destination bank accounts.

Conclusion

The Company retains the authority to temporarily halt any client’s activities deemed unlawful or potentially linked to money laundering based on the Company’s judgment. The Company possesses absolute discretion to temporarily suspend a suspicious client account, initiate the necessary reporting, and/or terminate an ongoing client relationship at its discretion and without prior notice.