To operate effectively within the framework of international and domestic law, an anti-money laundering compliance program must include effective “know your customer” procedures and rules. The true identity of each customer must be ascertained by the provision of documents proving the true identity of the customer, the nature of the customer’s business, and the intended purpose of the customer’s transactions.

As a broker with robust AML and KYC requirements, BellsTrade Global Markets Limited shall be responsible for:

(a) Providing the account application
(b) Conducting AML and KYC procedures
(c) Clearing and monitoring of all trades
(d) Being the custodian of the accounts, funds and paperwork.

Each trading account applicant must first be approved and accepted by the broker before trading.

Identity

For each new customer we will collect:

(a) The customer’s name
(b) Date of birth
(c) Residential address
(d) A proof of address such as bank statements, utility bill, driver’s license etc.
(e) Unexpired government identification card number showing nationality or residence, and photo ID.

For each new customer which is an entity, we will collect:

(a) The customer’s business name
(b) Principal place of business
(c) Proof of business such as bank statements, utility bill etc.
(d) Government issued identification or tax number
(e) Other government issued documentation certifying the existence of the business or enterprise such as certified articles of incorporation, a government issued business license, a partnership agreement or a trust instrument.

We will not accept an account without the required identification information. If the entity is a trust or similar, personal identification information as outlined in the previous paragraph will be needed for the account controller.

In the event a customer does not present a valid government ID; or the firm is not familiar with the documents the customer provides; or the customer opens the account without appearing in person; and any other circumstances that increase the risk that we will not be able to verify the true identity of the customer through documents an account will not be opened.

UN Sanction List

All individuals and entities will be checked against applicable lists of sanctioned countries published by the United Nations and periodically rechecked against updated lists. If a customer is from a country on the list, his or her account will not be opened.
All new customers’ names will be compared to the list provided by a third-party customer screening service. If a customer’s name appears on the list, we will contact law enforcement authority immediately

Purpose

We will verify all information given pertaining to the purpose of the trading account.
Although not all inclusive, some examples of behavior that will flag as of concern on account opening are:

(a) A customer exhibits an unusual level of concern for secrecy, particularly with regarding to the customer’s identity, type of business or sources of assets
(b) A corporate customer lacks general knowledge of its own industry
(c) A customer is unconcerned with risks, commissions or other costs associated with trading
(d) A customer appears to be acting as an agent for another entity or individual but is evasive about the identity of the other entity.
(e) A customer is from a country identified as a haven for bank secrecy, money laundering, or narcotics production.

Suspicious Transactions

Suspicious transactions are those that have no business or apparent lawful purpose, are unusual for the customer, or lack any reasonable explanation.

A few examples of “red flags” are:

(a) A customer engages in extensive, sudden or unexplained wire activity (especially wire transfers involving countries with bank secrecy laws);
(b) A customer makes a funds deposit followed by a request that the money be wired out, (in and out).
(c) For no apparent reason, a customer has multiple accounts under single name or multiple names, with a large number of inter-account transfers.
(d) Multiple sources of deposit are made in a short period of time only to request withdrawal via crypto currency to one or several addresses.

For all accounts, a determination of whether any transaction or series of transactions is suspicious will depend on the customer and the particular transaction(s) compared with the customer’s normal business activity. All accounts will be monitored for suspicious activity every 30 days.

BellsTrade Global Markets Limited follows guidelines set by the UK’s Joint Money Laundering Steering Group. As such, BellsTrade Global Markets Limited does not accept cash, money orders, third party funds, exchange houses transfer or Western Union transfers. Also, incoming and outgoing bank wires must be to the same banking institution having the customer’s name on the account, directing withdrawals back to the original source of remittance is a preventive measure to aid against Anti-Money Laundering efforts.

Customer Identification Program

Financial Services Companies must ascertain the identity of their customers, learn the nature of the customer’s business and learn the intended purpose of customers’ transactions.

BellsTrade Global Markets Limited anti-money laundering procedures mandate that individuals and entities that refuse to provide information verifying their identities, will not be permitted to trade with BellsTrade Global Markets Limited.

All new accounts will be subject to the stringent approval process by “COMPLIANCE”. “COMPLIANCE” will ensure that the new account form is complete. “COMPLIANCE” will review all new accounts for financial credit worthiness and trading suitability, as well as for the presence of anti-money laundering intentions. “COMPLIANCE” will check to ensure that identifying information is listed for all individuals named on the new account form and that none of the individuals named on third party customer screening service lists or any other sanctions lists are opened at the Company.

Any conduct or account activity that is inconsistent with trading foreign currencies, CFD’s, Crypto currencies or any subsequent offering by
BellsTrade Global Markets Limited with a goal of profiting thereby, must be considered suspicious activity and reported immediately to “COMPLIANCE” who will evaluate the situation and determine whether to take further action consistent with these procedures.

We may consider the following factors, among others, in assessing the risks of violating Anti-Money Laundering Policies posed by particular customers or transactions:

(a) Whether the customer is an individual, an intermediary, public, private, domestic or foreign corporation, a financial or non-financial institution, or regulated person or entity;
(b) Whether the customer has been an existing customer for a significant period of time;
(c) How the customer became a customer of the Company;
(d) Whether the business of the customer or the particular type of account, is the type more likely to be involved in illicit activity (e.g., cash intensive businesses);
(e) Whether the customer’s home country is listed on UN’s list of non-cooperative countries or sanctioned countries or is otherwise subject to adequate anti-money laundering controls in its home jurisdiction; and
(f) Whether the customer resides in, is incorporated in or operates from a jurisdiction with bank secrecy laws, or one that has otherwise been identified as an area worthy of enhanced scrutiny.

All BellsTrade Global Markets Limited personnel are instructed to be on alert for any situations that may be “indicators” for potential money laundering activities, For example:

(a) Customer exhibits an unusual concern regarding the Company’s compliance with government reporting requirements, particularly with respect to his or her identity, type of business and assets, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspect identification or business documents.
(b) Customer wishes to engage in transactions that lack business sense, apparent investment strategy, or are inconsistent with the customer stated business or strategy.
(c) Customer has a questionable background or is the subject of news reports indicating possible criminal, civil or regulatory violations.
(d) Customer has difficulty describing the nature of his business or lacks general knowledge of his or her industry.

Personnel who become aware of any such situations when accounts are being opened, will promptly notify “COMPLIANCE” of the potential suspicious activity. “COMPLIANCE” will make the decision if the account should be opened as is, request additional information, reject the account and/or report the activity to the law enforcement agencies.

BellsTrade Global Markets Limited holds a zero-tolerance fraud policy and is taking all measures possible to prevent it. Any fraudulent activity will be documented and all related accounts to it will be immediately closed. All funds in these accounts will be forfeited.