AML/KYC Policy

KW Investments Limited, operating under the trade name GXM Trading ("the Company"), is committed to the prevention of money laundering, terrorist financing, and proliferation financing in accordance with the Seychelles Anti-Money Laundering Act, the FATF Recommendations, and all applicable regulatory guidance issued by the Seychelles Financial Services Authority (FSA). Money laundering is the process by which the proceeds of criminal activity are concealed to disguise their illicit origin. Under internationally recognised standards, money laundering occurs in three distinct stages:

• (a) Placement – the introduction of illicit funds into the financial system, typically through deposits, wire transfers, or other instruments.
• (b) Layering – the separation of illicit proceeds from their source through a series of complex financial transactions designed to obscure the audit trail and conceal the beneficial owner.
• (c) Integration – the reintroduction of laundered funds into the legitimate economy, giving criminal proceeds the appearance of lawful income.

Where the layering stage succeeds, integration mechanisms re-inject the laundered proceeds into the financial system in a manner indistinguishable from legitimate business funds. The fundamental objective of money laundering is to convert the proceeds of criminal activity into ostensibly legitimate assets. Advances in financial technology and cross-border payment systems have enabled increasingly sophisticated laundering techniques, making detection and prevention more challenging. The misuse of financial institutions for the perpetration of financial crime is recognised globally as a systemic risk. The Company regards the prevention of such misuse as both a regulatory obligation and a core institutional responsibility.

The Company's AML/KYC/CFT programme comprises the following core components:

• Customer Identification Programme and Know Your Customer (KYC) procedures.
• Ongoing monitoring and detection of suspicious transactions.
• Appointment and oversight of the Compliance function.
• Mandatory AML/CFT training for all relevant personnel.
• Record-keeping in accordance with applicable retention requirements.
• Periodic independent testing and review of AML/KYC/CFT controls and compliance measures.

Customer Due Diligence (CDD) procedures encompass the following measures:

• (a) Establishing and verifying the identity of the Client.
• (b) Determining whether the Client is acting on behalf of a third party and, where applicable, identifying and verifying the identity of that third party.
• (c) Understanding the nature and purpose of the business relationship and the Client's expected transaction patterns.

Where the Client presents a higher risk profile, the Company shall apply Enhanced Due Diligence (EDD) measures, including but not limited to obtaining additional identification documentation, establishing the source of funds and source of wealth, and subjecting the relationship to senior management approval and heightened ongoing monitoring, in accordance with FATF Recommendation 10 and the Seychelles AML Act.

This policy applies to all branches, offices, employees, contractors, and affiliated entities of the Company and shall be read in conjunction with any related operational guidelines issued from time to time. These procedures define the responsibilities of management and personnel with respect to:

• Establishing and maintaining policies, procedures, and internal controls governing client acceptance, ongoing due diligence, and transaction monitoring.
• Customer due diligence and Enhanced Due Diligence (EDD) for high-risk clients.
• Declining, restricting, or terminating business relationships or transactions.
• AML/CFT training for all relevant personnel at onboarding and on a continuing basis.
• Ongoing monitoring of client accounts, transaction activity, and policy effectiveness.
• Internal awareness, escalation protocols, and communication.
• Management reporting and governance oversight.
• Filing of Suspicious Activity Reports (SARs) and Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit (FIU).

This policy is governed by the following key principles and objectives:

The Company shall implement and maintain robust policies, procedures, and internal controls to ensure that the risks of money laundering, proliferation financing, and terrorist financing associated with client relationships and transactions are effectively identified, assessed, managed, and mitigated.

Customer due diligence procedures governing the establishment, conduct, and termination of business relationships shall be developed and maintained in compliance with the Seychelles AML Act, FSA regulatory directives, and applicable FATF standards.

Prior to establishing a business relationship with any prospective Client, the Company shall obtain all requisite identification information and verify such information against independent and reliable sources as prescribed by applicable legislation.

The Company reserves the right to decline, suspend, or terminate any business relationship or transaction where there are reasonable grounds to believe that its services or infrastructure may be exploited for the purposes of money laundering, terrorist financing, or any other financial crime.

The Company shall ensure that all relevant employees receive appropriate and proportionate AML/CFT and KYC training at onboarding and at regular intervals thereafter.

The Compliance Department shall proactively monitor adherence to this policy and conduct periodic reviews to ensure ongoing compliance with all applicable legislative and regulatory obligations.

All relevant personnel of the Company shall be made aware of the contents of this policy, including their individual responsibilities, expected conduct, and reporting obligations.

Management reporting shall be produced at regular intervals to enable the Company to actively and effectively oversee client acceptance, ongoing due diligence, and transaction monitoring activities.

The Company's compliance function operates across two levels of authority, encompassing the responsibilities of the Money Laundering Reporting Officer (MLRO) and the Money Laundering Compliance Officer (MLCO).

1. CEO (serving as Money Laundering Reporting Officer) and the Board of Directors. The responsibilities of the CEO and the Board of Directors include:

• Establishing and sustaining a compliance culture throughout the Company, supported by rigorous recruitment, professional development, and performance monitoring of compliance personnel.
• Promoting a high degree of awareness at all levels of the organisation regarding the critical importance of adherence to AML/CFT and KYC obligations.
• Overseeing the development, periodic review, and effective implementation of all compliance-related policies and procedures.
• Maintaining close collaboration with the Compliance Department to ensure efficient governance and clear lines of communication between the Department and the Board.

2. The Compliance Department, headed by the Chief Operational Officer (serving as Money Laundering Compliance Officer). The Money Laundering Compliance Officer is responsible for:

• Appointing, supervising, and evaluating the performance of compliance officers within the Department.
• Coordinating and overseeing the day-to-day operational activities of the Compliance Department.
• Ensuring that all compliance officers receive adequate and ongoing training in AML/CFT procedures.
• Escalating to the CEO and the Board of Directors any matter where the Compliance Department has reasonable grounds to suspect that a transaction has resulted, or may result, in money laundering or terrorist financing.
• Conducting periodic assessments of the effectiveness of AML/KYC/CFT controls and compliance procedures.
• Performing periodic reviews and updates of this policy to reflect changes in legislation, regulation, and best practice.

The operational responsibilities of the Compliance Department include:

• Implementing and maintaining effective controls and systems for the detection of suspicious transactions and unusual activity.
• Exercising the authority to cancel, block, or prohibit any transaction deemed suspicious pending further review.
• Receiving, assessing, and recording internal disclosures related to suspicious transactions from staff or other sources.
• Developing and disseminating detailed guidelines, procedures, and training materials for the identification and reporting of suspicious activity.

The protection of client information and the integrity of the onboarding process are of paramount importance to KW Investments Limited, trading as GXM Trading. The Company is firmly committed to safeguarding the interests of its Clients at every stage of the business relationship.

The Company has implemented comprehensive Know Your Customer (KYC) procedures, aligned with applicable regulatory requirements and international best practices for financial services firms. These procedures are designed to prevent identity theft, money laundering, fraud, and the financing of terrorism.

The Company operates a strict zero-tolerance policy with respect to fraudulent activity. Any confirmed or suspected fraudulent conduct will be documented, reported to the relevant authorities where required, and will result in the immediate suspension and closure of all associated trading accounts. Funds held in any such accounts shall be subject to forfeiture in accordance with applicable law and the Company's terms of service.

Completion of the KYC verification process is mandatory. Until all required documentation has been submitted and verified, the Client's trading activity may be restricted and withdrawal requests will not be processed.

1. Proof of Identity (colour photograph or high-resolution scan). The Client must submit one of the following:

• Valid passport
• National identity card

The Proof of Identity document must clearly display the following information:

• Full legal name
• Date of birth
• Date of issue and date of expiry
• Clear, unobstructed photograph

The identity document must have a minimum remaining validity of six (6) months from the date of submission.

2. Secondary Identification Document (colour photograph or high-resolution scan). The Client may submit one of the following:

• Driver's licence
• Insurance identification card
• Certificate of birth, marriage, or divorce
• Educational diploma or certificate
• Military identification card

3. Proof of Residential Address (colour photograph or high-resolution scan), issued no more than ninety (90) days prior to the date of submission. The document must clearly display the Client's full residential address, first and last name, date of issue, and an official stamp, barcode, or institutional letterhead. Acceptable documents include:

• Utility bill (electricity, water, gas, or telecommunications)
• Bank statement or bank reference letter
• Official cheque or payment notice
• Certificate of residency issued by a government authority
• Tax notice or penalty notice from a government authority
• Signed lease agreement or property deed

4. Payment Card Verification (colour photographs of the front and back of each card used to deposit funds). For security purposes, the Client must obscure the CVV code and digits seven through twelve of the card number, leaving only the first six and last four digits visible. The cardholder's name and expiry date must be clearly legible on both sides.

All required documents must be submitted in PDF, JPEG, JPG, or PNG format to the Compliance Department at support@gxmtrading.com.

The Client is required to submit all compliance documentation promptly following the activation of the trading account. Incomplete or outstanding documentation may result in restrictions being applied to the Client's account, including but not limited to trading limitations and the suspension of withdrawal processing.

No withdrawal request shall be processed until all required KYC documentation has been received, reviewed, and verified by the Compliance Department.

The Company's withdrawal policy is governed by the following provisions:

• The Client has the right to request a withdrawal of available funds at any time, subject to the completion of all applicable KYC and compliance requirements.
• Bonus funds, where applicable, may only be withdrawn upon fulfilment of the specific conditions set out in the relevant promotional campaign under which the bonus was granted.
• The Client must submit a duly signed withdrawal request form to the Company prior to the processing of any withdrawal.
• All withdrawals shall be processed to the same payment method and account from which the original deposit was made. For example: funds deposited via bank wire transfer shall be returned by wire transfer to the originating bank account; funds deposited via credit or debit card shall be refunded to the same card.

The compliance procedure governing the processing of withdrawal requests is set out in the table below.

All transactions identified as potentially suspicious must, wherever practicable, be reported to the Compliance Department prior to execution. Full details of all suspicious transactions, whether executed or not, shall be documented and reported to the Compliance Department without delay. A transaction flagged as suspicious prior to execution shall proceed only with the express prior approval of the Compliance Department. The Compliance Department shall be afforded unrestricted and timely access to all information, documentation, and systems necessary to discharge its responsibilities effectively and with due diligence.

The Compliance Department is responsible for promptly notifying the CEO of any significant suspicious activity identified. The CEO shall escalate any extraordinary suspicious activity to the Board of Directors for determination. The Board of Directors shall decide whether to file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the Financial Intelligence Unit (FIU) in accordance with the Seychelles AML Act and applicable FATF guidance. SARs and STRs contain detailed information regarding transactions that are known or suspected to be connected with money laundering, terrorist financing, fraud, or other criminal activity. The purpose of such filings is to assist government authorities in identifying individuals, groups, and organisations engaged in financial crime, and to enable the Company to fulfil its statutory obligation to report known or suspected violations of law and to take all reasonable measures to ascertain the purpose of the transaction, the origin and ultimate destination of the funds involved, and the identity of all beneficial owners.

The Company maintains a structured onboarding and continuing professional development programme to ensure that all relevant personnel are adequately trained in AML/CFT and KYC procedures. Training content and frequency are calibrated to the role and responsibilities of the recipient. New employees receive foundational training in AML/CFT principles, KYC requirements, and the importance of strict adherence to all applicable compliance policies during a mandatory onboarding programme. Personnel engaged in direct client interaction are trained to verify client identities in accordance with CDD and EDD requirements, exercise ongoing due diligence in the management of existing client accounts, and recognise patterns and indicators of suspicious activity. Regular refresher training is provided to ensure that employees remain current with evolving regulatory requirements, emerging typologies of financial crime, and updates to internal policies and procedures. The Company recognises that the consistent and effective implementation of KYC and AML/CFT policies depends upon fostering a strong compliance culture at all levels of the organisation, underpinned by clear communication, accountability, and management commitment.

All employees are required to comply fully with the policies, procedures, and controls set out in this policy and any related operational guidelines. Failure to comply with AML/CFT and KYC obligations constitutes a serious matter and may result in disciplinary action up to and including termination of employment. In addition, non-compliance may expose the individual to personal civil or criminal liability under the Seychelles AML Act and related legislation, including fines, sanctions, and imprisonment. The Company may also face regulatory action, including enforcement proceedings, financial penalties, licence suspension, or revocation by the FSA. Employees who become aware of any breach or potential breach of this policy are required to report the matter immediately to the Compliance Department. Failure to report a known or suspected breach may itself constitute a disciplinary and, in certain circumstances, a criminal offence.

The Company maintains open and effective channels of communication between the Compliance Department and all employees. Periodic updates on AML/CFT regulatory developments, emerging financial crime typologies, and changes to internal KYC procedures are disseminated to relevant staff through internal bulletins, briefings, and training sessions. The Company's training programme is designed with differentiated objectives for frontline client-facing staff, compliance personnel, and account management teams, ensuring that each group fully understands the rationale, requirements, and practical application of the Company's compliance policies. All employees are encouraged to raise compliance-related questions or concerns with the Compliance Department at any time. Enquiries regarding this policy may also be directed to the Company at support@gxmtrading.com or via the gxmtrading.com website.