Anti-money laundering policy / KYC

In order to protect the funds of our clients and to ensure compliance with the world trade standards, Strato Finance Ltd (the "Company") works exclusively in accordance with the legislation on combating money laundering, obtained through criminal activity and countering the financing of terrorism and criminal activities.

To monitor compliance with the legislation, the Company has created the Compliance department, which develops Anti-Money Laundering and Know Your Client (AML/KYC) procedures, which are mandatory for compliance by all employees of the Company and policy-defining interactions with persons who enter into an Agreement with the Company and become clients of the Company (hereinafter referred to as the "Clients of the Company").

Compliance department shall to ensure that the Company's activities comply with international standards of Anti-Money Laundering Policy and all documents provided by the Clients are relevant and comply with the requirements of the law. In this connection, by concluding the Agreement with the Company, the Client shall fully and unconditionally accept the terms of this policy, agrees with the following rules and undertakes to observe them:

1. The company develops a list of documents that the Client must provide to verify the identity, namely:

a) For the individuals:

- Color copy of the passport (the first, second page with photos, as well as a page with registration data), or a color copy of the document that is proper for confirming the identity of the Client according to the legislation of the country of which the Client is a resident.

- At the request of the Company can request additional documents: may be provided a copy of the driver's license; receipts for payment of services or Utility Bill (for confirmation of the Client's residence). Also the verification process includes mandatory confirmation by the Client of its telephone number.

b) For legal entities:

- Certificate of Incorporation;

- Articles of Association/memorandum;

- Certificate of Incumbency/ Certificate of Good Standing;

- Proofs of identity for directors and shareholders (10%+). Usually passport or national identity cards;

- Proofs of address for directors and shareholders (10%+). Usually utility bill from last three months.

We realize that some of the above documents may not exist in some jurisdictions. In that cases, please send the best local equivalent.

2. Depositing and withdrawal of funds from the Client's account is allowed only after the Client passes the verification on the basis of the provided proper documents and completed questionnaire. The withdrawal of funds is carried out only to the account belonging to the person identified as the Client of the Company (the owner of the Traders Room). Withdrawal of funds to third parties is prohibited. Internal transfers between the Company's clients are also prohibited if otherwise is not agreed by the Company in writing.

3. The Company undertakes and has the right, without obtaining the prior consent of the Client, to exchange with any financial institution or law enforcement agency any information about the Client, in accordance with the requirements of the applicable law, and the Client gives the Company its consent to these actions. In order to comply with this clause, the Company keeps any information about the Client's payment transactions for at least five (5) years.

4. The Client assumes the obligation to comply with legal acts, including international ones, aiming the combating illegal trade, financial fraud, money laundering and legalization of criminal money;

5. The Client undertakes to exert maximum efforts to exclude direct or indirect complicity of illegal financial activities and any other illegal transactions using the site of the Company Strato Finance Ltd.

6. The Client guarantees the legal origin, legal possession and the right of use of the funds transferred to the account.

7. In case of detection of suspicious transactions on the Client's Trading account, cash replenishments from unreliable sources (for example, the data of the sender of funds and the owner of the trading account do not coincide) and / or any actions showing signs of fraud (including any refunds or cancellations of payments), the Company reserves the right to conduct an internal investigation, block or close the Client's Trading account, cancel any payments made and suspend operations on the account before the end of the official investigation. In making a decision the Company is guided by the provisions of applicable law or established practice.

8. The company has the right to request additional information about the Client in the event that the money withdrawal method differs from the depositing method. Also the Company reserves the right to block the Client's Trading account for the duration of the investigation, in case the client refused to provide additional information requested by the Company.

9. During the investigation, the Company has the right to request from the Client copies of additional documents confirming the identity of the Client, as well as copies of bank cards used to replenish the account, payment, as well as other documents confirming the legal possession and legal origin of funds. In case the client provides copies of documents, the Company has the right to demand the provision of originals of documents for review.

10. The Company will carefully check Clients identified by applicable law as being in high risk countries.

11. The Company's refusal to conduct transactions that are suspicious from the Company's point of view (including the blocking or closing of the Client's Trading account) shall not result for the Company's civil liability arising for failure to fulfill its obligations to the Client.

12. The Company is not obliged to inform the Clients and other persons about the measures taken to counteract the legalization (laundering) of proceeds from crime and the financing of terrorism, with the exception of informing Clients about the suspension of the operation, refusal to comply with the Client's order to perform operations, the need for the Client to provide documents.

13. This Anti-Money Laundering Policy is an integral part of the Agreement. By concluding the Agreement the Client confirms that it has acknowledged the provisions of this policy and will follow the listed requirements.