AML Policy

1. INTRODUCTION

This Legal Opinion has been prepared at the request of TradeFX Pte. Ltd. for the purpose of assessing whether its Anti-Money Laundering and Counter-Terrorist Financing (“AML/CFT”) Policy is appropriately designed in accordance with internationally accepted AML/CFT standards and applicable compliance expectations for foreign exchange brokerage activities.

TradeFX Pte. Ltd. is a company incorporated under the laws of Saint Lucia.

The Company is registered with the Accounting and Corporate Regulatory Authority (ACRA) in Singapore for corporate registration purposes.

This opinion is strictly limited to the assessment of the AML/CFT Policy and does not constitute confirmation of any financial services licensing status in any jurisdiction

The purpose of this Legal Opinion is to determine whether the AML/CFT Policy of the Company is structured in accordance with:

• International AML/CFT standards;
• Risk-based compliance principles; and
• Generally accepted financial services compliance frameworks applicable to forex brokerage operations.

This opinion is prepared with reference to globally recognized AML/CFT standards, including:

• Financial Action Task Force (FATF) Recommendations
• Basel Committee on Banking Supervision AML Principles
• Wolfsberg Group Guidance
• United Nations Security Council Sanctions Framework

Where relevant and applicable to global best practices, the AML/CFT Policy has also been assessed against regulatory expectations commonly applied by competent authorities, including:

• Australian Securities and Investments Commission (ASIC)
• Australian Transaction Reports and Analysis Centre (AUSTRAC)
• Federal Financial Supervisory Authority (BaFin), Germany
• Emirates Securities and Commodities Authority (ESCA)
• Cyprus Securities and Exchange Commission (CySEC)
• Financial Services Commission (FSC), Mauritius / other FSC jurisdictions
• Financial Markets Authority (FMA)
• Monetary Authority of Singapore (MAS)
• Virtual Assets Regulatory Authority (VARA), Dubai
• Financial Services Commission Mauritius (FSCM)
• Financial Services Authority Seychelles (FSAS)
• Vanuatu Financial Services Commission (VFSC)
• Relevant Financial Intelligence Units (FIUs) in applicable jurisdictions
• Other competent regulatory authorities where the Company may operate

The AML/CFT Policy of TradeFX was reviewed with respect to the following key components:

• Corporate governance and AML oversight structure
• Appointment and role of AML Compliance Officer
• Risk-based customer classification framework
• Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures
• Enhanced Due Diligence (EDD) for high-risk customers
• Beneficial ownership identification and verification
• Politically Exposed Persons (PEP) screening
• Sanctions screening and adverse media checks
• Ongoing transaction monitoring systems
• Suspicious Transaction Reporting (STR) procedures
• Record-keeping and data retention requirements
• Employee AML/CFT training programs
• Independent audit and compliance review mechanisms

6. FINDINGS

Based on our review, the AML/CFT Policy of TradeFX Pte. Ltd. contains the fundamental structural components of an effective AML/CFT compliance framework for a foreign exchange brokerage business.

The Policy provides for customer identity verification prior to onboarding using reliable and independent documentation sources.

It incorporates a risk-based approach, categorizing customers based on their potential exposure to money laundering and terrorist financing risks.

Enhanced Due Diligence measures are applied to higher-risk categories, including politically exposed persons, customers from high-risk jurisdictions, and those exhibiting unusual or complex transaction behavior.

The Policy provides for sanctions screening against relevant international sanctions lists and ongoing monitoring throughout the customer lifecycle.

The Company maintains procedures for the identification, escalation, and reporting of suspicious transactions to the appropriate Financial Intelligence Unit (FIU), where required under applicable law.

The Policy also establishes internal governance mechanisms, including designation of an AML Compliance Officer, employee training obligations, and periodic independent review of the AML/CFT framework.

In our opinion, the AML/CFT Policy of TradeFX Pte. Ltd. is consistent with internationally recognized AML/CFT principles, including the FATF Recommendations and general regulatory expectations applicable to financial services provider.

The Policy demonstrates adequate coverage of key AML/CFT controls, including:

• Customer identification and verification
• Risk-based customer classification
• Enhanced due diligence procedures
• Sanctions and PEP screening
• Ongoing transaction monitoring
• Suspicious activity reporting mechanisms
• AML governance and compliance oversight
• Record retention and auditability
• Employee training and awareness

The Policy is structured to mitigate risks associated with money laundering, terrorist financing, sanctions evasion, fraud, and other financial crimes.