1. Purpose and Scope

Verity Markets Ltd (“the Company”) is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance in all business activities.

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy establishes the framework, controls, and procedures implemented to prevent the Company from being used for money laundering, terrorist financing, fraud, or any other financial crime.

This Policy applies to all prospective clients, existing clients, employees, contractors, and associated parties of Verity Markets Ltd.

2. Regulatory Framework

Verity Markets Ltd operates in accordance with applicable international AML/CFT standards and best practices, including but not limited to the principles set forth by the Financial Action Task Force (FATF), applicable Anti-Money Laundering and Counter-Terrorist Financing laws in relevant jurisdictions, and global proceeds-of-crime and anti-terrorism frameworks.

The Company adopts a risk-based approach in line with global regulatory expectations and applies enhanced controls where higher risks are identified.

Additionally, Verity Markets Ltd ensures that all personal data is processed in accordance with applicable data protection laws and international best practices, including lawful processing, data minimization, purpose limitation, security safeguards, and confidentiality.

3. Roles and Responsibilities

The Board of Directors is responsible for approving and overseeing this Policy and ensuring that adequate resources are allocated for AML/KYC compliance.

The Compliance Officer is responsible for implementing and maintaining AML/KYC procedures, monitoring client activity and risk exposure, filing Suspicious Transaction Reports (STRs), and acting as the primary liaison with regulatory and enforcement authorities.

All employees are required to complete AML/KYC training, adhere strictly to internal compliance procedures, and report any suspicious activity immediately to the Compliance Officer.

4. Risk-Based Approach

Verity Markets Ltd applies a risk-based methodology to assess and manage client risk.

Clients are categorized as low risk, medium risk, or high risk based on factors including geographic location, nature of business activity, transaction behavior and volume, source of funds, and ownership structure.

Enhanced controls and monitoring are applied proportionately to higher-risk clients.

5. Customer Identification and Verification

Prior to establishing a business relationship, the Company performs full identity verification procedures.

For individuals, this includes a valid government-issued identification document such as a passport, national ID, or driver’s license, along with proof of residential address such as a utility bill or bank statement.

For legal entities, this includes a certificate of incorporation, registered address, director and shareholder information, and identification of Ultimate Beneficial Owners (UBOs).

All documentation is verified through reliable and independent sources, including electronic verification systems where applicable.

6. Customer Due Diligence (CDD)

The Company conducts Customer Due Diligence to establish and verify client identity, understand the purpose and nature of the business relationship, and assess associated risk.

CDD measures include collection of personal and corporate information, sanctions screening, Politically Exposed Person (PEP) identification, and adverse media checks.

7. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to higher-risk clients, including Politically Exposed Persons (PEPs), clients from high-risk jurisdictions, clients with complex ownership structures, and those exhibiting unusual transaction patterns.

EDD measures include verification of source of funds and source of wealth, senior management approval prior to onboarding, additional documentation requirements, and increased monitoring frequency.

8. Ongoing Monitoring

Verity Markets Ltd conducts continuous monitoring of client relationships and transactions.

This includes automated and manual review systems to detect unusual or suspicious activity, periodic updates of client information, and trigger-based reviews upon material changes.

High-risk clients are reviewed at least annually, while standard-risk clients are reviewed every two to three years.

9. Reporting Obligations

The Company maintains strict reporting procedures in accordance with AML/CFT obligations.

Suspicious Transaction Reports (STRs) are filed promptly upon detection of any activity that may indicate money laundering or terrorist financing.

All reporting is conducted confidentially and in accordance with applicable laws and regulatory requirements.

10. Sanctions and PEP Screening

Verity Markets Ltd screens all clients against international sanctions lists, politically exposed person databases, and adverse media sources.

Screening is conducted at onboarding, on an ongoing basis, and upon any material change in a client’s profile.

11. Record Keeping

The Company maintains comprehensive records of client identification, transactions, risk assessments, and compliance activities.

All records are retained for a minimum of seven (7) years and are stored securely with restricted access and audit controls.

12. Training and Awareness

All employees undergo mandatory AML/KYC training upon onboarding and complete annual refresher training.

Training programs are regularly updated to reflect regulatory developments, emerging financial crime risks, and industry best practices.

13. Data Protection and Confidentiality

Verity Markets Ltd ensures that all personal and financial data is securely stored, access-controlled, and used strictly for compliance and operational purposes.

All compliance-related reports, including STRs, are treated as strictly confidential.

14. Policy Review

This Policy is reviewed at least annually and updated as necessary to reflect changes in regulatory requirements, business operations, or risk exposure.

All updates must be approved by senior management.

15. Contact Information

Verity Markets Ltd
Email: compliance@veritymarkets.com
Website: https://www.veritymarkets.com