1.1. nomo is a digital trading platform managed by Nomo Trade Limited, registered as an International Business Company (IBC) in Saint Lucia under number 2023-00509, with its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, LC01 401, Saint Lucia (the “Company”, “we”, “us”, or “nomo”).

1.2. The Platform (nomotrade.com and mobile application) enables trading in CFDs, derivatives, copy trading, and diversified portfolios (the “Services”). This AML/KYC Policy (the “Policy”) establishes our framework for preventing money laundering, terrorist financing, and other illicit financial activities.

1.3. This Policy is periodically updated to reflect regulatory changes. Continued use of the Services constitutes acceptance of the current version. Users are responsible for reviewing it regularly.

2.1. nomo implements AML and KYC processes to comply with applicable laws and international regulations, with the primary objective of preventing money laundering (ML), terrorist financing (TF), and other unlawful financial activities.

2.2. nomo follows a risk-based approach, implementing controls proportionate to identified risks. Each client receives a risk profile categorised as low, medium, or high, based on a client-specific assessment conducted at onboarding and reviewed on an ongoing basis.

2.3. nomo maintains internal policies, procedures, and resources to support due diligence, transaction monitoring, and escalation processes. Suspicious conduct is assessed internally and addressed in accordance with applicable legal obligations.

3.1. The CDD process assesses risk at the point of onboarding and throughout the client relationship. It includes identity verification, evaluation of financial background and geographic location, and ongoing transaction monitoring.

3.2. For LATAM-region clients, nomo uses region-specific verification tools including national ID systems (e.g., Brazil CPF, Mexico CURP), tax compliance documents (e.g., RFC), and government databases (e.g., SAT in Mexico). Biometric verification is applied where applicable. AML/KYC communications are available in Spanish, Portuguese, and English.

3.3. Failure to provide required documentation or cooperate with CDD processes may result in account suspension, withdrawal restrictions, or closure.

4.1. All account registrations require identity verification. Standard verification (Level 1) requires: full name, date of birth, country of residence, email address, phone number, a government-issued ID (passport, national ID, or driver’s licence), and a liveness check. Level 2 additionally requires proof of address.

4.2. Enhanced Due Diligence (EDD) is applied to higher-risk users, including:

• Politically Exposed Persons (PEPs) and their associates
• Users involved in high-value or complex transactions
• Users from high-risk or sanctioned jurisdictions
• Users with income from informal or unregistered sectors
• Users conducting cryptocurrency transactions via unregulated platforms

4.3. EDD may include requests for source of funds documentation, enhanced transaction monitoring, and additional compliance reviews.

5.1. nomo does not provide Services to individuals from jurisdictions on the FATF black or grey lists, or subject to applicable international sanctions. The Platform retains the right to update this list at its discretion.

5.2. Currently restricted jurisdictions include: Afghanistan, Albania, Algeria, Angola, Bahrain, Bangladesh, Barbados, Belarus, Benin, Bhutan, Bosnia and Herzegovina, Botswana, Burkina Faso, Burundi, Cambodia, Cameroon, Cabo Verde, Central African Republic, Chad, China, Comoros, Congo DR, Crimea region, Cuba, Djibouti, Egypt, Eritrea, Ethiopia, Fiji, Gabon, Ghana, Guinea, Haiti, Iran, Iraq, Jamaica, Jordan, Kenya, Kosovo, Kuwait, Laos, Lebanon, Liberia, Libya, Macedonia FYR, Madagascar, Malawi, Maldives, Mali, Morocco, Myanmar, Namibia, Nepal, Niger, Nigeria, North Korea, Northern Cyprus, Oman, Pakistan, Palau, Qatar, Russia, Rwanda, Somalia, Senegal, South Sudan, Sudan and Darfur, Syria, Tanzania, Togo, Trinidad & Tobago, Tunisia, Tuvalu, USA, Vanuatu, Vatican City, Yemen, Zambia, Zimbabwe.

5.3. nomo does not currently provide Services to EEA-resident users. Legacy EEA accounts may be maintained solely for fund withdrawal purposes. New trading activity from EEA users is not permitted.

5.4. The restricted jurisdictions list is reviewed periodically in line with FATF updates and applicable regulatory changes.

6.1. The following activities are strictly prohibited on the Platform:

• Money laundering or any attempt to conceal the illicit origin of funds
• Financing of terrorism or support of terrorist organisations
• Fraud, identity theft, or misrepresentation
• Ponzi or pyramid schemes
• Trading in illegal goods or services

6.2. The following business types are subject to additional scrutiny and may be restricted:

• Unregulated cryptocurrency exchanges or peer-to-peer platforms
• Unlicensed lending, crowdfunding, or investment schemes
• Unlicensed gambling or lottery platforms
• Non-compliant money transfer or remittance businesses in high-risk jurisdictions

6.3. nomo may impose additional due diligence or restrict access for users operating in or with jurisdictions identified as high-risk for financial crime.

7.1. Risk is assessed across four dimensions: (i) user risk, (ii) product/service/transaction risk, (iii) interface risk, and (iv) geographical risk.

7.2. User risk is primarily driven by source of wealth and economic activity. Users with clear, stable income sources represent lower risk; users with opaque or complex financial profiles are subject to enhanced scrutiny.

7.3. Product/transaction risk is elevated for leveraged instruments, cryptocurrencies, and unregulated payment methods. All such transactions receive enhanced monitoring.

7.4. Geographical risk is assessed based on the regulatory environment, corruption index, and sanctions status of a user’s country of nationality, residence, and economic activity.

8.1. nomo retains customer identification records, transaction data, and relevant communications for a minimum of seven (7) years from the end of the business relationship, or longer where required by applicable law. Records are securely stored and accessible for regulatory audit purposes.

9.1. All relevant nomo personnel receive regular AML/KYC training covering policy obligations, identification of suspicious activity, escalation procedures, and LATAM-specific typologies including trade-based laundering, cash couriers, and shell company structures.

10.1. nomo has appointed a designated Compliance Officer responsible for overseeing implementation of this Policy, maintaining regulatory awareness, and ensuring timely escalation and reporting of compliance matters.

11.1. nomo’s AML/CFT programme is subject to periodic independent audits. Findings are reviewed by management and remediation is implemented as required.

11.2. Third-party providers used for identity verification and compliance checks are required to comply with applicable data protection laws and maintain confidentiality of user information.

12.1. nomo cooperates fully with competent authorities, including law enforcement agencies and financial intelligence units, in connection with investigations into ML, TF, or other illicit activity, within the bounds of applicable law.

13.1. Third parties engaged in business relationships with nomo are required to adhere to equivalent AML/KYC standards. Ongoing monitoring and periodic reviews assess their compliance with this Policy.

14.1. This Policy is reviewed regularly and updated as necessary. The version date at the top of this document reflects the most recent revision. Material changes are communicated to users via email or Platform notification. Continued use of the Services after any update constitutes acceptance of the revised Policy.

If you have any questions, concerns, or requests regarding this Policy, or if you would like to exercise your rights related to your personal data, please contact us using the following details:

• Email: support@nomotrade.com
• Operational address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, LC01 401, Saint Lucia.