AML & KYC Policy — Leofins Anti-Money-Laundering Programme

SECTION 01

Our commitment

Leofins does not hold client funds and does not offer regulated investment services, but we pay performance-based compensation and therefore run a risk-based AML and counter-terrorist-financing programme aligned with Cyprus law and the EU AML directives.

A named compliance officer owns the programme, reports to the board quarterly and reviews the policy at least annually.

SECTION 02

Identity verification (KYC)

—Verification is required before your first payout, and again if your identity, name or payout method changes.—We ask for a valid government photo ID, a proof of address dated within 90 days and a liveness check.—Corporate participants must provide incorporation documents, ownership structure and ID for each beneficial owner holding 25% or more.—Enhanced due diligence applies to politically exposed persons, high-risk jurisdictions and unusually large or rapid payout patterns.

SECTION 03

Sanctions and PEP screening

Every participant is screened against EU, UN, UK and US (OFAC) sanctions lists at registration, before each payout and on an ongoing basis. A confirmed match results in immediate suspension, a freeze on any pending payout and a report to the competent authority where required.

SECTION 04

Payment and payout controls

—Fees must be paid from a method held in the participant's own name; third-party payments are rejected and refunded.—Payouts are only made to a verified method belonging to the account holder — never to a third party.—Cash and anonymity-enhanced payment instruments are not accepted.—Crypto payouts use supported networks only, and destination addresses are screened for exposure to illicit activity.

SECTION 05

Monitoring and prohibited use

We monitor for behaviour that suggests the programme is being used to move value rather than to demonstrate trading skill: coordinated opposite positions across accounts, deliberate loss transfer, repeated fee payments from unrelated sources or payout requests inconsistent with trading activity.

Suspicious activity is escalated to the compliance officer, may result in withheld payouts and account closure, and is reported to MOKAS where legally required. We do not tell a participant that a suspicious activity report has been filed, because the law forbids it.

SECTION 06

Record keeping and restricted jurisdictions

Verification documents, screening results and transaction records are retained for five years after the end of the relationship, then deleted.

We do not offer the programme to residents of jurisdictions subject to comprehensive sanctions or on the FATF call-for-action list. The current restricted list is available from legal@leofins.com and is enforced at registration and at payout.

QUESTIONS ABOUT THIS DOCUMENT

Write to legal@leofins.com, or ask a plain-language question through 24/7 support. Practical summaries of the rules referenced here live on trading objectives, fees and the FAQ. This document is provided for information and does not constitute legal or financial advice.

Anti-money-laundering policy