Anti-Money Laundering and
Counter-Terrorism Financing Program
“AML/CTF Program”
prepared to deal.
The Anti-Money Laundering and Counter-
Terrorism Financing Act 2006 (the “AML/CTF Act”)
became effective on 12 December 2006. However,
some parts of the AML/CTF Act commenced in a
phased approach up to December 2008.
The purpose of our AML Risk Assessment is to
identify, mitigate and manage our potential ML/TF
1TradeMarket Limited trading as 1TradeMarket
risk. This Part A of the AML/CTF Program formally
(“1TradeMarket”) is a Reporting Entity on the basis
documents that in identifying our ML/TF risks, 1TradeMarket
that it provides a Designated Service (as defined in
has considered the risk posed by the following
section 6 of the AML/CTF Act).
Pursuant to the AML/CTF Act a Reporting Entity
(a)! our customer types, including beneficial owners
must have and comply with an AML/CTF Program.
of customers and any Politically Exposed
The AML/CTF Program is divided into Part A
(domestic, international
(general) and Part B (customer identification).
organisation and foreign);
This AML/CTF Program has been prepared so that
(b)! the source of funds and wealth of our
1TradeMarket can assess the potential money laundering
and terrorist financing (“ML/TF”) risks to which it
may be exposed and to manage those risks within
(c)! the nature and purpose of the business
the legislative framework.
relationship with our customers;
This AML/CTF Program was adopted by 1TradeMarket on
(d)! control structures of non-individual customers,
July 25th 2013. The AML/CTF program was last
and the beneficial owners of our customers;
updated on September 11th 2018.
(e)! the types of designated services we provide;
(f)! the methods by which we deliver our
The primary purpose of Part A of this AML/CTF
designated services;
Program is to identify, mitigate and manage the
risk that 1TradeMarket may reasonably face (inadvertently or
(g)! the foreign jurisdictions with which we deal.
otherwise) by facilitating money laundering or
terrorism financing through the provision of its
The identification of the ML/TF risks potentially
designated services.
faced by 1TradeMarket enables us to design and implement
the controls and measures required to mitigate
In this AML/CTF Program, “we”, “us” or “our” means
and manage these risks.
1TradeMarket has conducted a full risk assessment of the
business which has formed the basis of this
1TradeMarket is a company structured primarily to provide
program. The purpose of this risk assessment is to
general advice, dealing and market making
identify what ML/TF risks exist for 1TradeMarket when
services in derivatives and foreign exchange
providing designated services. The two risk types:
contracts to both retail and wholesale clients.
business risks and regulatory risks have both been
1TradeMarket’ primary mode of operandi is by way of an
electronic trading platform which operates over
The risks identified have then been
the Internet i.e. 1TradeMarket gives clients direct online
assessed/measured in terms of a combination of:
access to the rates/prices in the derivatives and
foreign exchange markets at which 1TradeMarket is
!Likelihood that these will occur
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!Impact of the consequence of loss or severity
of damage that may result if these do occur
Customers who are identified as being persons
or entities which support terrorist activity or are
Scales of likelihood and impact within a risk matrix
named in government lists or with credible
have been combined to generate a matrix of risk
scores. Risk appetite, tolerance and treatment has
sources in respect of corruption and/or criminal
also been defined.
1TradeMarket is committed to ensuring that its procedures
Nature, volume and frequency of trading
and policies prevent its services (and products)
having regard to the financial standing of the
from being used to facilitate money laundering or
terrorist financing.
Customers (not necessarily PEPs) based in, or
WHY IS 1TradeMarket AT RISK?
conducting business in or through, a high risk
geographic location, or a geographic location
Some of the risk themes currently faced by 1TradeMarket
with known higher levels of corruption or
have been set out below (this list is not
! Live chat facility;
Opportunities are presented for criminals to
engage in transnational activities have
! 1TradeMarket’s customer base is growing and from all
over the globe;
! Interactions are non-face to face; preferred by
communications technologies. Cyber-criminal
activities increasingly affect the financial
! Various electronic forms of payment credit
cards used to trade
security of online business. It is widely accepted
! E-payments is a known method to dispose of
that the financial and insurance industry is the
‘target of choice’ for financially motivated cyber
illegally obtained funds,
i.e. spending or receiving illegitimate money via
trading accounts.
Professional service providers such as lawyers,
accountants, investment brokers or other
professionals holding accounts for their
customers or acting on behalf of their customer
and where we would be required to place an
•! Risk Factors
unreasonable reliance on the professional
service provider;
For the purposes of the AML/CTF Act and Rules, in
identifying its ML/TF risks, 1TradeMarket has considered the
Requests for undue levels of secrecy with a
risks posed by the seven factors listed in paragraph
2 above and set out in detail below. Thus, certain
customer types, source of funds and wealth,
Whether the customer is a long-standing
business relationships and control structures,
designated services, delivery methods, foreign
transactions; and
jurisdiction considerations are all factors that can
result in a higher ML/TF risk.
the customer’s business activities place the
At a high-level, risk factors that we may reasonably
customer in a high-risk category;
face are identified as follows:
Customers who wish to use pre-paid credit
(i)! Customer Types, (including beneficial owners of
cards and the associated risks with the digital
payments arena.
! Any politically exposed persons PEP’s
(domestic, international organisation and
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The list of Designated Services (located in Section 6
! Sources of wealth - the origin of the entire
of the AML/CTF Act) has been reviewed and the
body of wealth gives an indication of the
ones that 1TradeMarket provide have been identified and
volume of wealth of the customer. Whether it
ranked as low.
is at the expected level;
! Source of funds - the origin of funds or assets
which are the subject matter of the business
relationship between the customer and 1TradeMarket.
! Where the origin of wealth or source of funds
cannot be easily verified.
Item 33
Provision of a designated service in
the capacity of agent of a person,
acquiring or disposing of:
(ii)! The nature and purpose of the business
(a)! a security; or
relationship with its customers,
(b)! a derivative; or
(c)! a foreign exchange
! Risks arising from changes in the nature of the
contract; on behalf
business relationship, control structure or
of the person,
beneficial owner of 1TradeMarket’s customers;
(d)! the acquisition or disposal is in
! Intended type and level of transactions to be
the course of carrying on a
carried out and risks associated with those
business of acquiring or
transactions. Larger transactions present
derivatives or foreign exchange
higher AML/TF risk.
contracts in the capacity of
agent; and
(iii)! The control structure of non-individual
(e)! the service is not specified in the
Item 35
Provision of a designated service
! 1TradeMarket can only be satisfied that it knows who the
in issuing or selling a security or
beneficial owner is if they know who ultimately
derivative to a person, where:
owns or controls the customer - either directly,
or indirectly through interests in the
(a)! the issue or sale is in the course
of carrying on a business of
customer’s beneficial owner(s);
issuing or selling securities or
derivatives; and
! Where there is a failure to identify who
(b)! in the case of an issue of a
ultimately controls the business relationship
security or derivative—the issue
preventing developing a clear understanding of
does not consist of the issue by
the AML/TF risk associated with the business
a company of a security of the
company or of an option to
acquire a
! Where the structure of the customer/entity
renders it difficult to identify the true controlling
owner, or where there is no legitimate
commercial rationale for the structure.
(i)! The Types of Designated Services We Provide
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(i)! Methods by which we Deliver
d Service
Designated Services
security of the company; and
(c)! in the case of an issue of a
! Online
security or derivative—the
issue does not consist of the
! Telephone
issue by a government body
! Live chat facility
of a security of the
similar measures;
government body or of an
option to acquire a security
Countries identified by credible sources as
of the government body;
having significant levels of corruption and/or
criminal activity;
(d)! in the case of an issue of a
Countries identified by credible sources as
security or derivative—the
issue is not an exempt
lacking appropriate AML/CTF legislation/
financial market operator
systems/ measures or controls;
issue; and
Countries identified by the FATF as non-co-
(e)! such other conditions (if
operative countries and territories;
any) as are set out in the
AML/CTF Rules are satisfied
Countries identified by credible sources as
being tax havens;
Forex/ Bullion
Countries that are materially associated with
production and/or transnational-shipment of
Item 54
Provision of a designated service
illicit drugs.
in the capacity of holder financial
By way of an example a Risk Matrix which was
arrangements for a person to
formulated from the Financial Action Task Force on
receive a designated service
Money Laundering
(“FATF”) Guidance Note,
(other than a service covered by
entitled “Guidance on the risk based approach to
this item).
combating money laundering and terrorist
financing,” sets out general risk assessment criteria.
Item 1
Selling bullion, where the
selling is in the due course of
This AML/CTF Program is risk based.
carrying on a business*
The following diagram, formulated from the FATF
(i)! Foreign Jurisdictions
“Guidance on the risk based approach to combating
! Countries identified by credible sources as
money laundering and terrorist financing”, sets out
providing funding or support for terrorist
the suggested risk assessment and management
activities or who have terrorist groups
controls process that should be implemented.
working within the country;
! Countries subject to sanctions, embargoes or
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Identify, verify and then assess the customer
establishing or continuing the business
relationship with them.
The following steps are performed in identifying,
verifying and performing a risk assessment of the
3. Additional KYC information is
obtained to identify and verify the customer
STEP 1. Initial (or minimum) KYC information is
where the identity is unclear or non-verifiable
obtained to identify and verify the customer as
required by the AML/CTF Rules
If the minimum KYC information is considered
insufficient and 1TradeMarket is unable to identify and
1TradeMarket will initially seek to identify and then verify
verify the customer, then further
the customer is who they claim to be. As a result,
questions must be asked of the customer so that
initial questions / information must be obtained to
the identity of the customer can be verified with
identify (and verify) the person. This is referred to
“Know Your Client information” or
STEP 4. A risk assessment is performed with
respect to that customer
Beneficial owners and control structures are
determined and KYC information is collected and
1TradeMarket is then required to carry out a risk
verified. 1TradeMarket review the parties to the trust deed;
assessment as to its exposure to facilitating money
identify major shareholders; understand the
laundering and/or terrorism financing by its
management structure; and
customer in order to identify, mitigate and
understand the rights and responsibilities of
manage the risk identified. To mitigate risk, 1TradeMarket
senior managers to determine control structures.
has taken the decision that Customers deemed to
be high risk at the outset are not offered an
1TradeMarket has strict KYC procedures to verify the
applicant’s identity. Manual verification is under
taken when a customer does not pass electronic
The assessment of ML/TF exposure must be risk
verification (EV). World Check (for international
based. The Act requires an assessment based
upon the following risk factors:
STEP 2. Identify whether a customer is a PEP
(1)! the types of customers we have (including
beneficial owners and PEPs);
1TradeMarket determines whether any customer or
(2)! the types of designated services we provide;
beneficial owner is a PEP (domestic, international
(3)! the methods by which we deliver our
organisation or foreign). Where a customer is
designated services; and
determined to be a PEP, 1TradeMarket collect and verify
(4)! the foreign jurisdictions with which we deal;
KYC information. 1TradeMarket then determine whether
(5)! Source of funds and wealth of customers
the PEP poses a high ML/TF risk. Additional due
(6)! The nature and purpose of the business
diligence measures and risk management
relationships with its customers
systems are implemented where the PEP is high
(7)! Control structures of non-individual customers
ML/TF risk or a foreign PEP. Foreign PEP’s are
and the beneficial owners of customers.
always classified as high risk.
Following this assessment, ML/TF risk of that
If a customer is a foreign PEP or a domestic or
customer is then measured or classified as low,
international organisation PEP who is assessed as
medium or high.
being a high ML/TF risk, 1TradeMarket take additional
measures such as taking reasonable measures to
establish the source of wealth and funds; and
require senior management approval before
providing the PEP with designated services or
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The process by which 1TradeMarket will assess risk and formulate and implement
management control processes is set out diagrammatically below:
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This Part A of the AML/CTF Program is designed
of Compliance must be notified prior to 1TradeMarket:
to identify, mitigate and manage the possible
ML/TF risks posed to 1TradeMarket and to document the
(i)! introducing a new designated service to the
controls and systems to address those risks. Any
weakness in this Part A of the AML/CTF Program
(ii)! introducing new methods of delivery of a
may impact adversely on the management of the
designated service; and/or
ML/TF risks.
any new or developing
technology used for the provision of
designated services.
This will enable the AML/CTF Compliance Officer/
Head of Compliance to identify any significant
1TradeMarket’s Part A program must be approved by its
governing board and senior management. Part A
changes in ML/TF risks and to formulate controls to
mitigate and manage those risks.
must also be subject to the ongoing oversight of
the reporting entity’s board and senior
management. 1TradeMarket’s board and senior
Where procedures are updated, staff are formally
trained to ensure they are aware of the
management are dedicated to overseeing the
procedures relevant to their specialized role at
AML/CTF program to ensure compliance with the
This AML/CTF Program has been adopted by the
Board. Any amendment to this AML/CTF Program
is subject to Board oversight and approval i.e. the
Board must formally adopt any amendment to the
AML/CTF Program.
The KYC procedures must be risk based having
The AML/CTF Compliance Officer/ Head of
regard to the ML/TF risks relevant to the provision
Compliance will provide a quarterly report to the
of the service/s offered. The procedures are
Compliance Committee and the Board, which will
designed to mitigate and manage the potential
include AML/CTF Program status reports and
ML/TF risks and ensure that 1TradeMarket is reasonably
incident reports. Quarterly compliance meetings
satisfied as to the true identity of its customers
have AML as an agenda item.
This AML/CTF Program has been designed to
The customer identification and verification
ensure and demonstrate compliance with the
procedures are detailed in Part B of this AML/CTF
AML/CTF obligations as follows:
Money laundering and terrorist financing
There is a requirement within the AML/CTF Act to
schemes can be difficult to identify and criminals
perform due diligence on certain representatives
can be ingenious in formulating different schemes
of 1TradeMarket i.e. staff, employees, contractors, those
to facilitate their money laundering or terrorist
seconded to the company for an interim period etc.
financing agendas.
The level of due diligence required depends upon
the function performed and level of seniority / work
Accordingly, for this AML/CTF Program to be
effective, it requires regular review, and if
necessary amendment, in order that it
The employee due diligence program includes
accomplishes its purpose of identifying,
appropriate risk-based systems and controls for
mitigating and managing ML/TF risk.
1TradeMarket to determine whether to, and in what manner
to, screen any prospective employee and also re-
Further, the AML/CTF Compliance Officer/ Head
screen an employee (where that employee is
9 | Anti-Money Laundering and Counter-Terrorism Financing Program | 1TradeMarket
transferred or promoted) that may be in a position
procedures has been completed.
to facilitate the commission of a money laundering
or financing of terrorism offence in connection with
Examples of representatives to be considered as
the provision of a designated service by 1TradeMarket.
“high risk” include the following:
The employee due diligence program also
(i)! Representatives who are in a position of
establishes and maintains a system for 1TradeMarket to
dealing with customers or circumstances which
manage any employee who fails, without
are identified as high risk.
reasonable excuse, to comply with any system,
(ii)! Representatives in “key” positions.
control or procedure established in accordance
(iii)!Representatives that provide unusual or
with Part A or Part B of this AML/CTF Program
extraordinary activities.
(refer policy document entitled,
(iv)!Representatives who fail to conform to the
Action Procedures”).
company’s or Group’s compliance systems
and/or controls.
1TradeMarket has prepared a Recruitment Policy which
(v)! Staff promoted to more senior levels with
covers the vetting of candidates for employment,
greater AML/CTF responsibilities that are yet to
taking and checking of references and the
complete further AML/CTF training in policies
procedures to be followed in the recruitment
and procedures.
(vi)!Representatives with lavish lifestyles, which
cannot be supported by the representative’s
The Recruitment Policy requires senior
salary or other practical reason.
management to conduct a formal interview of the
candidate. 1TradeMarket may also perform skills
The level of staff turnover will also be considered
assessment, reference checks or any combination
and monitored on a regular basis.
of these prior to offering a candidate a position.
Representatives will be selected on the basis of
Employees are not allowed to open a trading
their experience, skills, qualifications and industry
account with 1TradeMarket. This is to minimize the risks
associated with ML/TF. Customer accounts are
subjected to the AML/CTF procedures under the
The status of all new members of staff must be
supervision of the AML/CTF Compliance Officer/
on their commencement of
Head of Compliance.
employment (authority to represent the company
and provide a designated service) and the
The performance of supervisors with respect to
identification must be verified and recorded i.e.
compliance with the AML/CTF obligations will be
1TradeMarket will ensure that the identity and past history
monitored as part of their annual performance
of a prospective employee (representative) has
review. Should any customer account be managed
been verified prior to employment or authority
by the AML/CTF Compliance Officer/ Head of
granted to represent the company.
Compliance then these will be reviewed by senior
Representatives who fail to comply with the
compliance systems and/or controls will be subject
to disciplinary procedures, which may include
Once employed (or appointed to represent the
termination of employment
(cancellation to
company), employees (representatives) that are
represent the company). Representatives that are
identified as “high risk” will be subject to closer and
suspected of facilitating money laundering or
more frequent monitoring. This includes
terrorism financing will be reported to the
monitoring of the representative’s customer
appropriate authorities.
accounts and relationships (i.e. monitoring will be
undertaken more frequently than that prescribed
by the regular intervals pursuant to internal audit
procedures). In addition, these representatives
may be subject to transactional limits until such
time that comprehensive training in policies and
Appropriate training with regard to money
10 | Anti-Money Laundering and Counter-Terrorism Financing Program | 1TradeMarket
laundering and terrorist financing is vital in
pamphlets, videos, intranet systems, in-person
managing the ML/TF risk. Accordingly, all
lectures, and explanatory memos.
representatives are required to undergo training in
AML/CTF laws and internal policies. In order that
Records of training are maintained to demonstrate
our ML/TF controls are successful, training
that the person/s attended the training session/s,
programs are formulated having regard to the
the dates of training, a brief description of the
representative’s level of responsibility and
subject matter of the training provided and the
number of hours (or level of accreditation) for
Updated or refresher training will depend upon
attending the course/session/seminar.
staff promotions and/or depending upon the level
of assessed ML/TF risk of the designated service.
Certain key employees exposed to a greater ML/TF
Training will be carried out under the supervision
risk or those identified as “high risk” will undergo
of the AML/CTF Compliance Officer/ Head of
specialized additional training.
Compliance and senior management. Ongoing
general refresher training for all staff will occur on
a periodic basis (at least annually) and monthly
AML updates will be provided to all staff.
The AML/CTF Compliance Officer/ Head of
At a minimum the AML/CTF training program will
Compliance reports to the compliance committee
be designed to enable representatives to
and the Board.
understand the following:
The AML/CTF Compliance Officer’s/ Head of
Compliance duties specifically in relation to
(i)! the company (or Group’s) AML/CTF Policy;
ensuring compliance with the AML/CTF Act and
(ii)! the company (or Group’s) AML/CTF Program;
Rules include the following:
(iii)!the obligations of 1TradeMarket under the AML/CTF Act
and Rules;
(i)! monitoring compliance and adherence to the
(iv)!the types of ML/TF risk 1TradeMarket might face and the
obligations of the AML/CTF Act and Rules;
potential consequences of such risks;
(ii)! receiving
an investigating reports of
(v)! how to identify signs of ML/TF that arise during
suspicious matters activities;
the course of carrying out their duties;
(iii)! adopting a risk based approach to monitor
(vi)!escalation procedures i.e. what to do once a
customer activity to identify suspicious activity;
ML/TF risk is identified;
(iv)! overseeing communication and training for
(vii)what employees' roles are in the firm's
compliance efforts and how to perform them
(v)! ensuring that proper AML/CTF records are
i.e. the processes and procedures relevant to
each person’s role;
(vi)! reporting suspicious activity to senior
(viii)! the company’s (or Group’s) record keeping
management, the Compliance Committee and
and record retention policy; and
the Board;
(ix)!the consequences (including civil and criminal
(vii)! submitting regular reports to the Compliance
penalties) for non- compliance with the
Committee (at least quarterly);
AML/CTF Act and supporting Rules
(viii)! submitting regular reports to the Board (at
penalties of a maximum of $3.4 million for an
least annually);
individual and $17 million for a company apply
(ix)! providing advice to senior management, the
for non-compliance under the Act);
Compliance Committee and the Board;
(x)! Monthly closed jurisdiction updates;
(x)! lodging annual compliance report;
(xi)!AML Regulatory updates to update and inform
(xi)! receiving and carrying out directions or orders
staff, to ensure ongoing understanding of
issued by authorities; and
(xii)! Liaison with regulatory bodies and law
enforcement in respect of suspicious activity
Training may be developed and provided either in
house or by contracted training organizations,
external AML Consultants. Delivery of the training
The AML/CTF Compliance Officer/ Head of
may include written updates, educational
Compliance is authorized to act independently in
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order to fulfil the commitments of his role.
smoothly and that they are happy with the
platform performance. Ongoing monitoring is
The AML/CTF Compliance Officer/ Head of
undertaken during this process and KYC
Compliance, under the direction of the Board, will
information verified to ensure it is up to date.
ensure that any government or FATF findings
Further, if any suspicion is aroused, further KYC
concerning the approach to money laundering
is collected and the SMR procedure is followed;
and/or terrorism financing prevention, in particular
countries or jurisdictions, is assessed and
Initial courtesy calls are made to clients at the
appropriate changes made to the AML/CTF
beginning of the relationship when a demo
Program. Amendments will be communicated to
account is downloaded. At this stage the sales
those representatives affected by the changes.
team ascertain the trading experience of the
applicant and will canvass trading strategies
and intended length of the relationship and
spend. This enables 1TradeMarket to monitor and
Ongoing customer due diligence is an important
identify any unusual trading activity, patterns of
component in mitigating and managing the ML/TF
spend with reference to the disclosed strategies
risks (potential and identified). 1TradeMarket maintains an
and relationship length.
ongoing relationship with its customers through
updating KYC information, implementation of a
Sales staff accept withdrawal requests and will
transaction monitoring program
(TMP) and by
flag to the accounts team if there any
conducting enhanced customer due diligence.
discrepancies or attempted third party
1TradeMarket has systems in place to determine when
withdrawal requests;
further KYC or beneficial owner information should
be collected or verified to review and update
New accounts staff re-verify customers if any
information. All customer records are reviewed
errors are identified on an account, or any
and updated where the ML/TF risk warrants this.
suspicion is formed;
This applies to both new and pre-existing
The accounts and trading teams review
All new accounts are screened for errors by the
transactions, including trading and electronic
new accounts team with supervision and
fund transfers, in the context of other account
guidance from the AML/CTF Compliance
activity to determine if a transaction is
Officer/ Head of Compliance.
suspicious. A formal TMP is in place;
Sales and support staff maintaining an ongoing
the AML/CTF Compliance Officer/Head of
relationship/ contact with clients. This contact is
Compliance is responsible for monitoring
both for commercial purposes, to provide
adherence to the AML/CTF Act, will document
ongoing technical support and also for the
when and how it is carried out, and will report
purposes of updating and maintaining KYC
suspicious activities to the appropriate
information by verifying name, date of birth and
address. All notes are recorded in Salesforce in
the company’s account information. Customers
exception reports are utilized to identify
are requested to provide evidence in the form
possible ML/TF risks and include monitoring
of proof of address documentation (such as a
transaction size, location, type, number and
utility or bank statement) to action a change of
nature of the activity;
address on the system;
the AML/CTF Compliance Officer/ Head of
Each member of the 1TradeMarket sales team maintains
Compliance conducts an appropriate
a list of their own customers. This list is
investigation before reporting a suspicious
monitored on a daily basis. Contact is therefore
maintained with all customers. Those customers
not actively trading are contacted to incentivize
Instances where 1TradeMarket re-verify for the purposes of
a return to trading. Those actively trading will
updating and maintain KYC information on all
be contacted to ensure everything is running
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are in an amount just below reporting or
1TradeMarket ensures that the information it retains about its
recording thresholds
customers is up to date. The trading team monitor
(ii)! The customer attempts to make frequent or
customer account activity, including trading and
large deposits of currency, insists on or asks for
electronic fund transfers on an ongoing basis. Staff
exemptions from the firm’s policies relating to
are trained to identify “triggers” for the requirement
the deposit of cash and cash equivalents.
to update KYC information. For example,
(iii)!For no apparent reason, the customer has
disconnected telephone numbers, returned mail.
multiple accounts under a single name or
multiple names, with a large number of inter-
Staff are trained to identify and verify beneficial
account or third-party transfers.
ownership information for all non-individual
(iv)!The customer has accounts in, a country
customer types on an ongoing basis. Where
identified as a non- cooperative country or
beneficial owner or true controllers are
territory by the Financial Action Task Force.
determined, additional KYC information is
(v)! The customer’s account has unexplained or
collected and verified.
sudden extensive wire activity, especially in
accounts that had little or no previous activity.
(vi)!The customer’s account indicates large or
frequent wire transfers, immediately withdrawn
without any apparent business purpose.
(vii)The customer makes a funds deposit followed
by an immediate request that the money be
1TradeMarket has a risk based transaction monitoring
wired out or transferred to a third party, or to
(TMP) to monitor transactions of
another firm, without any apparent business
customers, including regard to complex, unusual
large transactions and unusual patterns of
(viii)! The customer makes a funds deposit for the
transactions which have no apparent economic or
purpose of pursuing a long-term trading
visible lawful purpose
strategy, followed shortly thereafter by a
request to transfer the proceeds out of the
Staff in the new accounts team manually monitor
accounts to ensure that there isn’t fraudulent
activity on the accounts, staff review ID, and look for
layering of funds using the trading accounts.
Transactions are monitored by staff on an ongoing
basis. Customers are monitored on an ongoing
Although it is 1TradeMarket’s policy not to accept customers
basis in order to identify any suspicious activity;
identified as high risk at the outset, it has
Staff are required to review deposit alerts, and
implemented an enhanced due diligence program
trading activity. Suspicious patterns are reported to
to include systems and controls to ensure, where
Manager of team in the first instance. This
appropriate, measures such as clarifying,
information is communicated to the AML/CTF
analyzing, verifying or updating beneficial owner
Compliance Officer/ Head of Compliance who will
information collected from the customer; or
apply enhanced customer due diligence
collecting further beneficial owner information
(such as the source of the beneficial owner’s funds
Accounts and sales staff are trained to look for
and wealth) are taken.
specific activity which is deemed a Red flag trigger,
as follows:-
1TradeMarket has implemented systems so that ongoing
due diligence is conducted on the business
(i)! The customer engaging in transactions
relationship and scrutinizing transactions to
involving cash or cash equivalents or other
ensure that the transactions are consistent with
monetary instruments that appear to be
the knowledge of the customer, and their
structured to avoid the $10,000 government
business and risk profile.
reporting requirements.
Enhanced due diligence will be undertaken for all
i.! especially if the cash or monetary instruments
high risk customers and transactions and where:
13 | Anti-Money Laundering and Counter-Terrorism Financing Program | 1TradeMarket
(a)! there is a requirement to access further
information in order to clarify & update KYC
1TradeMarket may also seek to utilise automated (exception)
(b)! obtain further KYC info;
reporting that will include a comprehensive sample
(c)! consider and investigate the suspicious
of activity and monitor things such as transaction
size, location, type, number and nature of the
(d)! verify or re-verify information;
(e)! undertake more detailed analysis and
monitoring regarding transactions; and
The AML/CTF Compliance Officer/ Head of
(f)! lodge a suspicious matter report.
Compliance, will be responsible for performing
these ongoing monitoring activities.
Where it is determined that enhanced due
diligence should be applied, the process will be
They will document when and how it is carried out
as follows;
and will report suspicious activities to senior
management and/or the appropriate authorities
1.! AML/CTF Compliance Officer/ Head of
(where required). The AML/CTF Compliance
compliance will conduct a thorough
Officer/ Head of Compliance will conduct an
investigation to determine the source of the
appropriate investigation before reporting a
customer’s and each beneficial owner’s
suspicious matter.
2.! Check the validity of the account registration
Employee guidelines with examples of suspicious
money laundering activity and lists of high-risk
3.! Review any linked accounts;
customers that may warrant further scrutiny will
4.! Re-verify KYC information;
also be prepared and distributed to those
5.! Analyze the customer’s past transactions and
possibly monitor future transactions if deemed
In addition to regular reviews, circumstances may
6.! The purpose or nature of specific transactions
arise in which an otherwise low risk customer will
7.! Check IP address where possible to detect any
be elevated to high risk.
suspicious connection sources
8.! Determine if a suspicious matter report should
For example, a customer on commencement of the
be lodged in accordance with process set out
relationship may be classified as low risk. However,
after a change in client circumstances or activities,
the risk profile of the customer may be elevated to
Monitoring will be conducted either:
medium or high. An example of this is a client’s
change of country of residence.
In circumstances where the customer’s risk profile
The AML/CTF Compliance Officer/ Head of
is elevated, further measures and controls will be
Compliance and senior management will ensure
implemented to mitigate and manage against
that a sufficient sample of activity will be selected
potential ML/TF risks, including the following:
to enable the identification of matters of concern,
such as patterns of unusual size, volume, type of
(i)! Immediate notification to all appropriate
transactions, foreign jurisdiction factors, or any of
representatives / business units;
the “triggers” identified.
(ii)! further KYC information and verification
procedures performed;
It is proposed that representatives will review
(iii)!an increase in the level on monitoring (i.e. in
transactions (including trading and electronic fund
accordance with the new classification or rating
transfers) in the context of other customer activity
of the customer risk, being medium or high and
to determine if a transaction lacks financial
monitoring intervals commensurate with the
rationale or is suspicious because it is an unusual
identified risk);
transaction or strategy for that customer, or
(iv)!Increased monitoring of transactions in
14 | Anti-Money Laundering and Counter-Terrorism Financing Program | 1TradeMarket
accordance with senior managements
requirements in respect of the customer or
Suspicion is formed when a representative
considers that an existing or prospective customer
is attempting to use the services offered by 1TradeMarket for
ML/TF purposes and/or any one of the following
conditions is met:
the representative suspects on reasonable
1TradeMarket has implemented monitoring and reporting
systems in respect of designated services offered
grounds that the customer is not the person
they claim to be;
across all relevant business units.
the representative suspects on reasonable
grounds that the customers agent is not the
Relevant employees are trained to identify and
report suspicious matters to the Head of
person they claim to be;
the representative suspects on reasonable
Compliance AML/CTF Compliance Officer/ Head
grounds that the provision, or prospective
of Compliance.
provision, of the service is preparatory to the
commission of an offence of financing of
The AML/CTF Compliance Officer/ Head of
Compliance is adequately trained to investigate
suspicious matters, prepare, lodge and retain
the representative suspects on reasonable
grounds that information collected by 1TradeMarket
records of suspicious matter reporting.
concerning the provision, or prospective
provision of the service may be relevant to the
Staff are trained to be aware of potential indicators
that will trigger a suspicion. The aim is to identify
investigation of, or prosecution of, a person or
entity for an offence of financing of terrorism;
those prospective (or existing) customers that are
the representative suspects on reasonable
seeking to use the services offered by 1TradeMarket for
money laundering or terrorist financing purposes,
grounds that the provision, or prospective
provision, of the service is preparatory to the
thereby triggering reporting obligations to the
commission of an offence of money laundering;
relevant authorities.
the representative suspects on reasonable
grounds that information collected by 1TradeMarket
The AML/CTF Compliance Officer/ Head of
concerning the provision, or prospective
Compliance is responsible for submitting SMR’s,
provision, of the service may be relevant to the
however staff are aware that it is a shared
responsibility to be vigilant in respect of any
investigation of, or prosecution of, a person or
entity for an offence of money laundering.
suspicious matters.
(vii)! the representative suspects on reasonable
An SMR must be submitted by the AML/CTF
grounds that information collected by 1TradeMarket
Compliance Officer/ Head of Compliance within
concerning the provision or prospective
provision of services:
three business days of forming the suspicion. If the
suspicion relates to the financing of terrorism, the
(viii)! may be relevant to investigation of, or
SMR must be submitted within 24 hours of forming
prosecution of a person or entity for an evasion,
or an attempted evasion of taxation law;
the suspicion.
(ix)! may be relevant to investigation of, or
prosecution of a person or entity for an evasion,
Staff are trained to avoid “tipping off” in respect of
or an attempted evasion, of a law of a State or
suspicious matters to avoid wrongfully disclosing
Territory that deals with taxation; or
to others, information about a suspicious matter.
(x)! may be relevant to investigation of, or
Staff are aware that this is an offence.
prosecution of a person or entity for, an offence
against a law of the Commonwealth or of a State
If staff form a suspicion whilst dealing with a
or Territory; or
prospective (or existing) customers, this suspicion
must be referred to the AML/CTF Compliance
(xi)! may be of assistance in the enforcement of the
Proceeds of Crime Act 2002 or regulations
officer/ Head of Compliance who will make a
under that Act; or
decision as to whether a suspicious matter report
should be submitted
(xii)! may be of assistance in the enforcement of a
15 | Anti-Money Laundering and Counter-Terrorism Financing Program | 1TradeMarket
law of a State or Territory that corresponds to
! assess whether Part A of the AML/CTF Program
the Proceeds of Crime Act 2002 or regulations
has been effectively implemented; and
under that Act;
! assess whether 1TradeMarket have complied with Part A
of the AML/CTF Program.
The result of the review, including any report
1TradeMarket will design and implement robust systems to
prepared, will be provided to the Board, the
detect threshold transactions covering all
Compliance Committee and senior management.
prescribed requirements. Currently, the
A draft checklist entitled “Independent Review of
prescribed threshold amount is $10,000 i.e. cash
the AML/CTF Program”.
transactions in excess of this amount must be
reported to AUSTRAC. 1TradeMarket has confirmation
Record Keeping:
stating they are not required to report these
transactions as these are reported directly from
In accordance with meeting legislative obligations,
the bank receiving funds.
1TradeMarket will retain all records relevant to its AML/CTF
Program and policies, including the following:
1.! the AML/CTF Program and all reviews and
An AML/CTF Compliance Report is an annual
addendums to the same;
2.! its AML/CTF Policy and all reviews and
report which 1TradeMarket prepares that helps provide
addendums to the same;
authorities with information on our compliance
3.! transactional records;
with the Anti-Money Laundering and Counter-
Terrorism Financing Act 2006 (AML/CTF Act), the
4.! Customer identification and verification
regulations and the Anti-Money Laundering and
5.! Audits and compliance reviews;
Counter-Terrorism Financing Rules Instrument
6.! Suspicious matter reporting (from 13
December 2008);
Compliance Report contributes to monitoring of
7.! Threshold reporting (from 13 December 2008);
ongoing industry compliance with the AML/CTF
8.! Senior management approvals;
Act, the regulations and the AML/CTF Rules. 1TradeMarket
9.! Customer account/relationship records;
follows the AML/CTF Act obligations and
10.!Annual compliance reports and other
completes an AML/CTF Compliance Report
management reports;
before 31 March of each year.
11.!Training and compliance monitoring reports;
12.!Information relating to the effectiveness of
A review of Part A of the AML/CTF Program will be
Records in respect of customer identification and
undertaken annually. The review will be undertaken
verification are retained for 7 years after account
Where 1TradeMarket (or its agent or intermediary) carries
! internally i.e. by a person separate from the
out a customer identification and verification
AML/CTF Compliance Office
(or his/her
procedure with respect to a prospective customer
department or direct control); or
to whom 1TradeMarket proposes to provide a designated
! by an external service provider that will be
service, it must make (and retain) a record of:
retained to conduct the review.
(i)! the procedure (i.e. the Checklist); and
The purposes of the review will be to:
(ii)! information obtained in the course of carrying
out the procedure
! assess the effectiveness of Part A of the AML/CTF
documentation to verify the identification of
Program, having specific regard to the ML/TF
the customer); and
risks faced by 1TradeMarket;
(iii)!such other information
(if any) about the
! assess whether Part A of the AML/CTF Program
procedure as is specified in the AML/CTF
complies with the AML/CTF Rules;
16 | Anti-Money Laundering and Counter-Terrorism Financing Program | 1TradeMarket
(currently no further information is
training programs in respect of the change to
ML/TF risks and will oversee the delivery of
training programs.
Records in respect of financial transactions are to
9.! The AML/CTF Compliance Officer/ Head of
be retained for 7 years after the date of the
Compliance will retain all records relevant to
the risk assessment, addendums to the
AML/CTF Program and the training programs.
AML/CTF Program and addendums together with
10.!The AML/CTF Compliance Officer/ Head of
any documentation relevant to the reason for
Compliance, under the direction of the Board,
amendment are also to be retained for 7 years
will ensure that any government or FATF
after the adoption of the AML/CTF Program and/
findings concerning the approach to money
or amendments cease to be in force.
laundering and terrorism financing prevention
in particular countries or jurisdictions, is
assessed and appropriate amendments made
to the AML/CTF Program. Furthermore, all
1TradeMarket will review all areas of its business to identify
compliance procedures will be made and
potential ML/TF risks that may not be covered in
communicated to all representatives.
the procedures described above. The additional
areas of ML/TF risks are in respect of new
products, services, distribution channels and
developing technologies.
1TradeMarket will co-operate with all external authorities.
Additional procedures to address these ML/TF risks
1TradeMarket will comply with any directions or notices
are as follows:
received from such bodies and will actively search
and retain records of any guidance issued or
The AML/CTF Compliance Officer/ Head of
released in respect of perceived ML/TF risks.
Compliance will be consulted by any person
having responsibility for a new service or
method of delivery or new technology (“the
project manager”) at design stage or prior to
Customer identification
and verification
the introduction of the new service, delivery
procedures will be carried out having regard to the
method or technology. He will be required to
Privacy Act
1988. 1TradeMarket’s Privacy Policy and
advise on the ML/TF risk factors which are to be
Disclosure Document/s (e.g. the Financial Services
considered having regard to:
Guide and Product Disclosure Statements) will be
the target market (customer type);
amended to include the following disclosure:
the service features;
foreign jurisdictional features / offerings;
(i)! that personal information may be collected
any electronic access to / the delivery method
because 1TradeMarket is obliged by Law to collect
of the service.
certain information
(for example, the Anti
The AML/CTF Compliance Officer/ Head of
Money Laundering Counter Terrorism
Compliance will, in consultation with the project
Financing Act 2006 requires 1TradeMarket to collect
manager undertake the risk assessment and
information and verify the identity of its clients /
formulate the controls and systems to manage
customers. This is often referred to as “know
any ML/TF risks.
your customer” information);
The AML/CTF Compliance Officer/ Head of
(ii)! that information may be collected from other
Compliance will review the AML/CTF Program,
persons or organizations and a listing of those
policies and procedures to ensure that any new
sources including agents, brokers, publicly
ML/TF risks are identified in the AML/CTF
available information and documents; and
Program and amendments to the AML/CTF
(iii)! that where required by Law, the client or
Program are made. All amendments will be
customer’s personal information may be
overseen by senior management and will
disclosed to other parties.
require Board approval.
The AML/CTF Compliance Officer/ Head of
Compliance will formulate staff awareness and
17 | Anti-Money Laundering and Counter-Terrorism Financing Program | 1TradeMarket