1. Introduction

This policy notice on Anti-Money Laundering ("AML") and Know Your Customer ("KYC") outlines the guidelines and procedures established by https://nomotrade.com (hereinafter referred to as "we," "us," "nomo," the "platform"). The platform is operated by Nomo Trade Limited, an International Business Company number 2023-00509 in Saint Lucia. The registered office is situated at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, LC01 401, Saint Lucia. The physical office is located at 1344 Mariano Roque Alonso Street, Asunción, 001005, Paraguay.

2. Purpose of AML/KYC processes implemented by nomo

The purpose of incorporating AML and KYC processes at nomo is to ensure a reasonable level of compliance with applicable laws and international regulations. The primary objective is to prevent money laundering, terrorist financing, and other illicit activities. nomo is fully committed to achieving comprehensive compliance with relevant laws and international regulations related to anti-money laundering and countering the funding of terrorism. In pursuit of this commitment, nomo has adopted and enforces specific provisions outlined in anti-money laundering and countering the funding of terrorism rules and regulations, primarily focused on preventing and detecting instances of money laundering, terrorist financing, and other unlawful activities.

In addition to fulfilling legal requirements, nomo has established internal policies, guidelines, and additional resources to create a thorough framework for conducting due diligence on clients, monitoring transactions, and reporting any suspicious activities. The robust implementation of KYC and AML measures aims to protect the platform, clients, and maintain the overall integrity of the financial system.

Specifically, nomo is devoted to promptly recognizing and reporting actions related to the conversion or transfer of funds from criminal activity, attempts to conceal the illicit origin of funds, or aiding individuals involved in criminal activities to evade legal consequences. Any involvement in concealing the true nature, source, location, disposition, movement, rights, or ownership of funds derived from criminal activity, or knowingly receiving funds from criminal activity, raises concerns for nomo. In such instances, nomo diligently questions such behavior and promptly reports suspicions of money laundering to relevant authorities. The information and documentation gathered during these processes assist authorities in analyzing and investigating suspected instances of money laundering.

The regulatory framework governing anti-money laundering and countering the funding of terrorism, applicable to nomo, follows a risk-based approach. This mandates nomo to implement measures, policies, controls, and procedures proportionate to the risks it faces, with the aim of preventing and mitigating those risks.

Recognizing that each client poses varying levels of risk, nomo conducts a client-specific risk assessment when establishing a business relationship or carrying out occasional transactions. This assessment enables nomo to identify potential risks, particularly in cases where money laundering or terrorist financing is suspected, or when doubts arise about the accuracy or adequacy of previously obtained customer identification data. The assessment allows nomo to develop a risk profile for each client, categorizing the level of risk as low, medium, or high.

3. Putting "Know Your Client" steps into action

Ensuring we know our clients well and prevent any suspicious activities involves following a few important steps. We start by evaluating the level of risk a client might pose. This process, known as Customer Due Diligence (CDD), helps us confirm a client's identity and understand their behavior. If we notice anything unusual, we investigate and report it to the authorities, using the information we've gathered.

Here's what the CDD process involves:

Confirming identity:

When clients sign up, we collect and check the necessary info and documents to confirm their identity. We use strict procedures to ensure the authenticity of the documents. This process is based on the risk associated with the client, considering factors like their history and location.

Monitoring transactions:

We use smart systems to watch transactions and identify any unusual patterns. If we think extra checks are needed, we carry them out. We also regularly review client accounts and update our checks to ensure we are following the rules.

Reporting suspicious activities:

Our team is trained to quickly spot and report any unusual activities. We follow the rules and promptly report anything suspicious to the relevant authorities.

Self-check:

We regularly assess how well we're doing through internal and external reviews. This ensures our procedures are effective and compliant with the rules.

By following these steps, our goal is to truly understand our clients, monitor their activities, and contribute to preventing money laundering and terrorist financing.

LATAM-specific geographical risks include jurisdictions identified for weak AML/CFT systems, high corruption indices (e.g., Venezuela, Haiti), or those with significant informal economies. Conversely, countries like Chile and Uruguay with robust regulatory frameworks may present lower risks.

Therefore LATAM-specific considerations for CDD include verifying national ID systems such as Brazil's CPF (Cadastro de Pessoas Físicas), Mexico's CURP (Clave Única de Registro de Población), and validating tax compliance documentation (e.g., RFC in Mexico). Enhanced verification is required for clients operating in high-risk cash sectors or remittance-heavy industries.

To support LATAM clients, nomo ensures AML/KYC-related communications and documents are accessible in Spanish and Portuguese where applicable, alongside English.

Clients identified as PEPs, or those with ties to LATAM public officials, are subject to enhanced screening measures. This includes source-of-funds verification and continuous transaction monitoring.

Clients whose primary source of income originates from informal sectors (e.g., unregistered businesses) are subject to additional risk assessments, including verification of source of funds and economic activity.

Clients involved in cryptocurrency transactions are assessed for additional risk factors, such as the use of unregulated exchanges or peer-to-peer platforms common in LATAM.

4. Restricted locations and business operations:

Our platform's stance on specific regions and business activities it avoids is termed "Excluded jurisdictions and business activities." This reflects our decision to abstain from operations in particular areas and steer clear of certain business practices, as specified in the provided list.

To adhere to both legal requirements and internal guidelines, we abstain from providing services or engaging in business activities with individuals or entities from countries listed under various sanctions, including the FATF black and grey lists. Moreover, we retain the right to exclude jurisdictions at our discretion, with the possibility of occasional updates.

Specifically, our Platform does not extend services to clients in the following locations: 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.

Additionally, nomo does not currently provide services to users residing in EEA countries. While some legacy EEA clients may still hold accounts for fund withdrawals, new trading activity from users in EEA is not permitted. nomo reserves the right to restrict or terminate access for users who do not comply with these geographical limitations. Please note that this list is not exhaustive and may be subject to periodic reviews and regulatory changes, as well as modifications based on legal requirements and our discretion.

The Platform periodically reviews its excluded jurisdictions list based on changes to FATF recommendations and local LATAM regulatory updates. Specific focus is placed on maintaining compliance with sanctions and financial regulations in Brazil, Mexico, and Argentina.

5. User verification procedures:

User verification:

Our platform mandates a comprehensive user identification process for all account registrations.

Enhanced due diligence (EDD):

In specific scenarios, we may apply enhanced due diligence for customers posing higher risks, such as politically exposed persons (PEPs), high-value transactions, or those operating from high-risk third countries. This may involve additional verification steps, requests for documentation regarding the source of funds, and ongoing monitoring conducted by our compliance team.

For LATAM users, the Platform integrates region-specific verification tools such as accessing government databases (e.g., RENAP in Guatemala, SAT in Mexico) and utilizing biometric verification where applicable.

6. Business risk evaluation

Client risk

Assessing the risk in terms of money laundering/terrorist financing (ML/FT) depends on the client type. Evaluating an individual's risk typically involves considering their economic activity and/or source of wealth. A client with a single, steady income source poses a lower ML/FT risk compared to a client with multiple income sources or irregular earnings.

Product/service/transaction risk

Certain products, services, or transactions inherently carry higher risks, making them more appealing to criminals. These include those susceptible to criminal exploitation or involving specific funding methods, and they are treated as high-risk factors.

Interface risk

The channels used to establish a business relationship and conduct transactions can impact the risk profile of the relationship or transaction.

Geographical risk

Geographical risk is associated with the location of business/economic activity and the source of wealth/funds in a business relationship. Considerations include the client's nationality, residence, and place of birth, as they may indicate heightened geographical risk. Countries with weak anti-money laundering/counter-terrorist financing (AML/CFT) systems, high corruption levels, international sanctions related to terrorism or weapons proliferation, or a known presence of terrorist organizations are considered high risk. Conversely, countries with stronger AML/CFT systems and lower ML/FT risk are classified as presenting a medium or low risk.

7. Monitoring transactions

Real-time monitoring

Our platform employs advanced transaction monitoring tools to identify and analyze potentially suspicious activities. These tools continuously scrutinize transactions, account behavior, and patterns indicative of money laundering or terrorist financing.

Transaction reporting

Upon identifying suspicious activity, our platform promptly reports it to the relevant authorities, adhering to the laws of the Republic of Estonia and relevant international regulations.

Monitoring tools are calibrated to detect LATAM-specific patterns, such as high-volume remittances, informal sector cash flows, or transactions tied to politically exposed persons (PEPs) prominent in LATAM economies.

Cross-border transactions, particularly those involving high-risk jurisdictions or regions with weak AML frameworks, are subject to additional scrutiny. nomo ensures compliance with LATAM-specific foreign exchange and cross-border transaction reporting requirements.

nomo uses advanced tools to detect trade-based money laundering, including under-invoicing, over-invoicing, and misrepresentation of goods or services in LATAM trade transactions.

8. Record maintenance

Our platform maintains detailed records, including customer identification information, transaction data, and communications, for a minimum of 5 years, unless longer retention is required by applicable law, regulation, or directive. These records are securely stored and easily accessible for audits and regulatory requirements.

Training includes LATAM-specific AML/CFT considerations, such as local typologies for money laundering (e.g., trade-based laundering common in the region) and awareness of national compliance bodies like COAF in Brazil and UIF in Mexico.

9. Staff training

Regular and thorough training on AML and KYC policies and procedures is provided to all employees and relevant personnel within the organization. This training ensures they are fully aware of their responsibilities and equipped to effectively identify and report any suspicious activities.

Training includes LATAM-specific AML/CFT considerations, such as local typologies for money laundering (e.g., trade-based laundering common in the region) and awareness of national compliance bodies like COAF in Brazil and UIF in Mexico.

nomo ensures that employees are trained in identifying LATAM-specific money laundering patterns, such as trade-based laundering, cash couriers, and shell companies. Regular training covers regional regulations and typologies.

10. Compliance officer appointment

A designated compliance officer is appointed by the platform to oversee the implementation and adherence to AML and KYC policies. This compliance officer ensures that nomo stays updated with regulatory requirements and promptly reports any concerns or suspicions to the appropriate authorities.

11. External audits

nomo consistently undergoes independent audits of its AML/CFT program to assess its effectiveness, identify areas for improvement, and ensure adherence to regulations. Findings from these audits are thoroughly reviewed by management, and appropriate measures are taken to rectify any identified shortcomings.

12. Collaboration with Authorities

nomo maintains full cooperation with relevant authorities, such as law enforcement agencies and regulatory bodies, during investigations or inquiries related to money laundering, terrorist financing, or other illicit activities. The organization promptly provides requested information and assistance within the confines of applicable laws and regulations.

nomo strive to complies with country-specific reporting obligations, including the filing of Suspicious Activity Reports (SARs) with local financial intelligence units.

13. Third-party relationships

When establishing business relationships with third parties, nomo mandates adherence to the same AML and KYC processes outlined in this policy and guided by the compliance team. Ongoing monitoring and periodic reviews are conducted by nomo to assess the compliance of these third parties with AML and KYC regulations.

14. Periodic evaluation

This policy notice undergoes regular evaluations to ensure its effectiveness and compliance with evolving regulations and best practices. Updates and amendments are implemented as necessary. The effective date signifies the commencement of the latest version of this policy. Any changes to the effective date will be clearly indicated at the beginning of this document.