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

1.2. nomo operates through both a website, available at https://nomotrade.com, and a mobile application (hereinafter - “Platform“ or “nomo”). This Platform allows users to engage in trading activities, including Contracts for Difference (CFDs) on various securities, derivative instruments, copy trading, and investment in diversified portfolios, and provide users with other services (hereinafter - “Services”) that are completely described our Terms and Conditions. As part of our commitment to providing a robust and secure environment, nomo offers tools and features that enable users to make informed decisions in their trading journey.

1.3. At nomo, we are committed to maintaining the highest standards of regulatory compliance, integrity, and security for our users and the Platform. To support these commitments, we have implemented this AML/KYC Policy (hereinafter - “Policy“). This Policy is designed to prevent illegal activities such as money laundering, terrorist financing, and other illicit financial activities on our Platform. The Policy is an integral part of our operations and provides clear guidelines on how we verify users, monitor transactions, and comply with local and international regulations. This document is intended to inform users of their responsibilities and our procedures, ensuring that we can all contribute to a safe and transparent trading environment.

1.4. This Policy may be periodically updated to reflect changes in applicable laws, regulatory requirements, or internal compliance measures. When significant changes or updates are made to the Policy, we will notify users through appropriate channels, including email or Platform notifications. We encourage you to review this Policy regularly to stay informed of any changes. By continuing to use nomo’s Services, you acknowledge and agree to comply with the updated Policy. It is your responsibility to understand the terms outlined in this Policy, as well as the additional policies that govern the use of the Platform.

1.5. This AML/KYC Policy should be understood in conjunction with other documents and policies available on the Platform.

1.6. As part of our efforts to prevent misuse of our Platform, it is essential for users to understand and follow the guidelines outlined in this Policy. Failure to comply with the KYC requirements or to provide accurate information during the verification process may result in delays, restrictions, or even suspension of account access. We encourage all users to read this Policy thoroughly and ensure they meet the required standards for identity verification, financial transparency, and compliance.

2.1. 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.

2.2. 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 users, monitoring transactions, and reporting any suspicious activities. The robust implementation of KYC and AML measures aims to protect the Platform, users, and maintain the overall integrity of the financial system.

2.3. 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.

2.4. The regulatory framework governing anti-money laundering and countering the funding of terrorism, applicable to nomo, follows a risk-based approach. This mandates us 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 us 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 user identification data. The assessment allows us to develop a risk profile for each user, categorizing the level of risk as low, medium, or high.

3.1. To ensure that nomo operates in a secure and compliant manner, we follow a set of essential procedures for understanding our users and preventing suspicious activities. Our Customer Due Diligence (hereinafter - “CDD”) process helps us evaluate and verify users, ensuring we remain in compliance with AML and KYC regulations.

3.2. The CDD process is implemented to assess the risk associated with each user. It includes the following steps:

• We collect necessary personal information and documents to verify a user’s identity.
• We evaluate the user’s financial background, trading history, and geographic location to determine the risk level. Clients in higher-risk jurisdictions or with complex financial backgrounds may be subject to enhanced checks.
• After nomo account creation, we continuously monitor transactions and activities for any unusual patterns that could indicate suspicious behavior, such as money laundering or terrorist financing. If necessary, we conduct additional checks and report any suspicious activity to relevant authorities.

3.3. As nomo provides its Services in the LATAM region, we implement region-specific tools and procedures to ensure compliance with local regulations:

• In the LATAM region, we use national ID systems like Brazil's CPF and Mexico's CURP, and tax compliance documents (e.g., RFC in Mexico) to verify users.
• Clients operating in high-risk cash sectors (e.g., remittance businesses) or those involved in informal sectors may undergo additional verification steps.
• Where applicable, we may also utilize biometric verification to enhance security.

3.4. To support users from the LATAM region effectively, we ensure that AML/KYC communications and documentation are available in Spanish, Portuguese, and English, as applicable to the region. This ensures that users are fully informed and able to meet all regulatory requirements.

3.5. Users are expected to fully cooperate with the AML/KYC processes by providing accurate and complete information. Failure to provide the required documents or to update information as necessary may result in account suspension, withdrawal restrictions, or account closure.

4.1. As part of nomo’s commitment to AML /KYC regulations, our Platform requires a comprehensive user identification process for all account registrations. This is essential for ensuring the integrity of the Platform, maintaining a secure trading environment, and protecting our users from illegal activities such as fraud, money laundering, and terrorist financing.

4.2. For regular users (those not subject to Enhanced Due Diligence (hereinafter - “EDD”), the verification process is an essential step to access full features of the Platform. This process ensures compliance with KYC and AML regulations.
Users must provide basic personal details during the registration process. This includes: full name, date of birth, country of residence, email address, and phone number These details help verify your identity and establish your user profile on the platform.
To complete the identity verification process, users must upload the following documents: government-issued identification document (common documents include a passport, national ID card, or driver’s license), proof of address (documents such as a utility bill, bank statement, or tax document will be used to confirm your residency). Also the liveness check is required.
All information and documents provided during the verification process are encrypted and securely stored to maintain the confidentiality of your personal data. We take the protection of your sensitive information seriously and comply with industry standards to safeguard your privacy.
Once your identity is successfully verified, you will gain full access to the platform’s features, including the ability to withdraw funds (provided you meet the necessary account level for withdrawals).
It is important to note that withdrawals are only available to users who have completed the full verification process at Level 1 or Level 2 (see our Terms and Conditions).

4.3. In specific cases, nomo may apply EDD for users who present higher risks. This typically applies to:

• Politically Exposed Persons (hereinafter - “PEPs”): individuals who hold or have held prominent public positions, or their relatives.
• High-value transactions: large transactions that could potentially raise concerns about the source of funds.
• High-risk jurisdictions: users located in or dealing with countries that are subject to higher regulatory scrutiny.
• Users whose primary income comes from informal sectors (e.g., unregistered businesses).
• Users involved in cryptocurrency transactions: users using unregulated exchanges or peer-to-peer platforms. Cryptocurrency transactions are closely monitored due to their potential for higher anonymity and volatility.

In such cases, the verification process will be more thorough and may include additional steps, such as requests for documentation about the source of funds, economic activity review, ongoing monitoring of the user's account activity by our compliance team.

4.4. For users from the LATAM region, nomo integrates region-specific verification tools to enhance compliance with local regulations. These tools include:

• Accessing government databases such as SAT in Mexico for identity verification.
• Biometric verification, where applicable, to ensure the security and authenticity of the user’s identity.

These measures are part of our commitment to maintaining a safe and compliant trading platform, tailored to the regulatory requirements of the LATAM region.

5.1. To adhere to both legal requirements and internal guidelines, we abstain from providing Services or engaging in business activities with individuals 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.

5.2. 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.

5.3. 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. We reserve 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.

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

6.1. nomo prohibits users from engaging in any business activities that involve illegal or illicit activities. The following are strictly forbidden on the Platform:

• any activity designed to obscure or disguise the origin of illegally obtained funds, including transferring funds through the Platform with the intent to clean or launder money;
• engaging in financial activities intended to fund terrorism or support terrorist organizations;
• using nomo’s Services to conduct fraudulent activities, including but not limited to identity theft, misrepresentation, or financial scams.;
• promoting or engaging in Ponzi schemes, pyramid schemes, or any other form of fraudulent investment schemes that mislead investors or violate financial regulations;
• using the Platform to trade in illegal goods or services, including but not limited to, counterfeit products, drugs, weapons, or any other prohibited goods under applicable laws.

6.2. Certain high-risk activities or business types are subject to additional scrutiny, and may be restricted or prohibited based on considerations. These activities include:

• users involved in operating unregulated cryptocurrency exchanges or peer-to-peer platforms that lack transparency or compliance with financial regulations;
• businesses involved in financial activities such as lending, crowdfunding, or investment schemes without the proper licenses or regulatory approval;
• platforms offering gambling, betting, or lotteries that are not licensed or regulated in the jurisdiction in which they operate;
• businesses facilitating money transfers or remittances that are not compliant with AML or KYC regulations or are located in high-risk jurisdictions.

6.3. nomo may restrict users or businesses operating in or engaging with countries identified as high-risk for financial crimes or AML/CFT violations. Such high-risk jurisdictions may include, but are not limited to:

• countries under economic sanctions by international bodies such as the United Nations, European Union, or United States;
• jurisdictions with weak regulatory frameworks for financial services, or those that lack AML/CFT regulations.

For users or businesses involved in these regions, nomo reserves the right to impose additional due diligence checks or restrict access to the Platform.

6.4. Users are solely responsible for ensuring that their activities comply with nomo’s policies and applicable local and international regulations. By using the Platform, you agree not to engage in any of the prohibited or restricted business activities listed above. Failure to comply with these restrictions will result in account suspension, transaction reversals, and potential legal action depending on the severity of the violation. nomo reserves the right to report any illegal or suspicious activity to relevant authorities.

7.1. At nomo, we take a comprehensive approach to evaluating the risks associated with our users, products, services, and transactions. This process helps us identify and mitigate potential risks related to money laundering and terrorist financing. The risk evaluation is based on several key factors, which include the user risk, product/service/transaction risk, interface risk, and geographical risk.

7.2. The level of risk associated with a user is evaluated by considering multiple factors, primarily focusing on the user’s economic activity and source of wealth. The primary goal is to determine whether the user presents any higher risk for engaging in money laundering or terrorist financing.
A user with a single, steady income source (e.g., salaried employment or stable business activity) generally poses a lower AML/CFT risk. In contrast, users with multiple income sources or irregular earnings may present a higher risk due to the complexity and potential opacity of their financial activities.
Understanding how a user generates wealth is crucial. Users with clear, transparent sources of wealth (such as regular employment or a legitimate business) pose a lower risk. However, users with vague or unexplained sources of wealth, or those who engage in high-risk business sectors, may be flagged for further scrutiny.

7.3. Certain products, services, or transactions inherently carry higher risks due to their susceptibility to criminal exploitation. These risks may arise from the nature of the transaction, the methods of payment, or the product or service being traded.
Financial products like leveraged trading tools, cryptocurrencies, and highly liquid assets are often favored by criminals due to their volatility, ease of movement, and potential for large transactions.
Transactions involving unregulated payment methods (e.g., peer-to-peer platforms or cryptocurrencies without clear regulatory oversight) are more vulnerable to exploitation. These transactions may be subject to closer monitoring and increased due diligence to prevent misuse.
All transactions, particularly those involving high-risk products or services, will undergo enhanced scrutiny to ensure they comply with AML and CTF regulations.

7.4. The channels used to establish a business relationship and conduct transactions play an important role in evaluating the risk profile of the relationship or transaction. nomo ensures that all user registrations and transactions are processed through secure channels to mitigate risks related to the interface through which the services are accessed.

7.5. Geographical risk refers to the potential risks associated with a user’s nationality, residence, or the location of their economic activities. The risk evaluation takes into account the regulatory environment of the country in which the user operates, as well as the source of funds.
Countries with weak AML/CFT systems, high corruption levels, or those subject to international sanctions (such as sanctions related to terrorism or weapons proliferation) are considered high-risk. Additionally, countries known to harbor terrorist organizations or engage in illicit financial activities present higher geographical risks.
Countries with robust AML/CFT frameworks and low levels of money laundering and terrorist financing risks are considered medium or low risk. Countries with well-established regulations and international cooperation on financial crimes present lower risks.
nomo applies additional due diligence checks for users from high-risk jurisdictions, which may include verifying the source of funds, monitoring transaction patterns, and conducting ongoing assessments of the user’s activities.

8.1. 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.

8.2. Upon identifying suspicious activity, our Platform promptly reports it to the relevant authorities in LATAM region countries.

8.3. Monitoring tools are calibrated to detect LATAM region specific patterns, such as high-volume remittances, informal sector cash flows, or transactions tied to PEPs prominent in LATAM region 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.

8.4. 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.

9.1. 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.

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

10.2. 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.

10.3. 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.

11.1. 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.

12.1. 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.

12.2. To ensure the security, accuracy, and compliance of our Platform, nomo utilizes third-party service providers to assist in the verification of our users. These providers help us perform critical identity verification and AML/KYC compliance checks to mitigate risks and prevent financial crimes such as money laundering and terrorist financing. We rely on trusted third-party verification tools to verify the identity of users, confirm the legitimacy of financial transactions, and ensure that all users meet the necessary regulatory requirements. These tools may include access to government databases, credit rating agencies, and biometric verification services where applicable. nomo ensures that all third-party providers used in the verification process are compliant with data protection laws and handle your personal information with the utmost confidentiality and security.

13.1. We maintain 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 strives to comply with country-specific reporting obligations, including the filing of Suspicious Activity Reports with local financial intelligence units.

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

15.1. 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 Policy.

15.2. We encourage all users to regularly review this policy to stay informed about any updates. nomo will notify users of significant changes via email or Platform notifications. By continuing to use nomo’s Services after any modifications to this Policy, you acknowledge and agree to the updated terms and conditions.

If you have any questions, need assistance, or require clarification regarding our AML/KYC Policy, we are here to help. Whether you need support with the identity verification process, have concerns about your compliance status, or need further explanation about our procedures, feel free to reach out to us:

• Phone: +371 254 93 909
• Email: support@nomotrade.com
• Operational address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, LC01 401, Saint Lucia.

We are committed to offering efficient and reliable support to ensure you fully understand your responsibilities under our AML/KYC Policy. Our team is available to guide you through any verification process, address any concerns regarding your account’s compliance status, or provide information about our AML/KYC procedures.