1. Policy statement
DuaFx Ltd. is committed to preventing its products, platform and payment channels from being used for money laundering, terrorist financing, sanctions evasion or any other financial crime. This policy summarises the framework we operate to meet that commitment under applicable anti-money laundering and counter-terrorist financing (AML/CTF) regulations.
The framework is owned by our Chief Compliance Officer, approved by the board, reviewed at least annually, and applies to every employee, officer and business partner of the Company without exception.
2. Customer due diligence
No trading account is activated until customer due diligence (CDD) is complete. CDD includes verification of the client's identity and residential address against reliable, independent documentation as described in our KYC Policy, screening against international sanctions lists, and identification of politically exposed persons (PEPs).
For corporate applicants, we identify and verify the entity, its directors and every ultimate beneficial owner holding 25% or more, and we obtain an understanding of the ownership and control structure before onboarding.
Enhanced due diligence (EDD) — including senior management approval, source of wealth corroboration and closer ongoing monitoring — is applied to higher-risk relationships such as PEPs, clients from higher-risk jurisdictions, and accounts with activity inconsistent with their stated profile.
3. Risk-based approach
We assess the money laundering risk of each business relationship at onboarding and on an ongoing basis, considering client type, geography, product usage, funding patterns and behaviour. Each client is assigned a risk rating that determines the depth of due diligence and the frequency of periodic review.
Our enterprise-wide risk assessment is refreshed at least annually and whenever we launch new products, payment methods or enter new markets, so that controls remain proportionate to the risks we actually face.
4. Funding rules and same-method withdrawals
Deposits are accepted only from payment sources held in the client's own name. Third-party deposits — funds arriving from any person or entity other than the verified account holder — are rejected and returned to the originating source.
Withdrawals are returned via the same method and to the same source used to deposit, up to the total amount deposited through that method, before any alternative payout method is considered. Profits above the deposited amount are paid to a verified account in the client's own name. This same-method rule is a core anti-laundering control and is applied without exception.
Accounts used primarily to pass funds through without genuine trading activity may be restricted, investigated and reported. We reserve the right to request supporting documentation for any deposit or withdrawal at any time.
5. Transaction monitoring
We operate automated and manual monitoring designed to detect unusual patterns, including deposits inconsistent with a client's declared profile, rapid deposit-withdrawal cycles with minimal trading, structuring of transactions below reporting thresholds, and use of multiple funding instruments without an evident rationale.
Alerts are investigated by the compliance team, which may request additional information or documentation from the client. Failure to provide satisfactory explanations may result in account restriction or termination in accordance with our Terms & Conditions.
6. Sanctions and prohibited jurisdictions
Clients and transactions are screened at onboarding and continuously thereafter against applicable sanctions lists, including those maintained by the United Nations, and other lists relevant under applicable regulations. Confirmed matches result in immediate account freezing and reporting to the relevant authorities.
We do not open accounts for residents of jurisdictions subject to comprehensive sanctions or where the provision of our services would breach applicable regulations. The list of restricted jurisdictions is maintained by the compliance team and applied automatically during onboarding.
7. Reporting and record keeping
Suspicious activity identified through monitoring or by staff is escalated internally to the money laundering reporting officer, who determines whether a report to the relevant financial intelligence unit is required. Tipping off a client that a report has been made or is contemplated is strictly prohibited.
We retain identification documents, transaction records and investigation files for the minimum period required by applicable regulations after the end of the business relationship — typically at least five years — in a form that permits timely reconstruction of individual transactions.
8. Training and oversight
All staff receive AML/CTF training at induction and refresher training at least annually, with role-specific modules for client-facing, payments and compliance personnel. Training records are maintained and completion is mandatory.
The effectiveness of this framework is tested through periodic independent compliance reviews and audits, with findings reported to senior management and remediated on a tracked basis.