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.

Concretamente, nomo se compromete a reconocer y reportar las acciones relacionadas con la conversión o transferencia de fondos procedentes de actividades delictivas, los intentos para ocultar el origen ilícito de los fondos o para ayudar a aquellos individuos relacionados con actividades delictivas a evadir las consecuencias legales derivadas de ellas. Toda implicación en la ocultación de la verdadera naturaleza, origen, ubicación, disposición, movimientos, derechos o propiedad de fondos derivados de actividades delictivas, o en el conocimiento sobre la recepción de fondos procedentes de ellas, suscita la preocupación de nomo. En estos casos, nomo cuestiona diligentemente dicho comportamiento e informa de inmediato a las autoridades relevantes de sus sospechas acerca del blanqueo de capitales. La información y la documentación recogida en estos procedimientos ayuda a las autoridades en su análisis e investigación de las actividades sospechosas de blanqueo de capitales.

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.

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, Australia, Bahrain, Bangladesh, Barbados, Belarus, Benin, Bhutan, Bosnia and Herzegovina, Botswana, Brazil, 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, Puerto Rico, Qatar, Russia, Rwanda, Somalia, Senegal, South Sudan, Sudan and Darfur, Syria, Tanzania, Togo, Trinidad & Tobago, Tunisia, Tuvalu, the United Kingdom, the USA, Vanuatu, Vatican City, Yemen, Zambia, and Zimbabwe.

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. User verification procedures:

User verification:

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

Enhanced due diligence (EDD):

En determinados escenarios aplicamos procedimientos reforzados de diligencia debida para aquellos clientes que comportan mayores niveles de riesgo, como personas expuestas políticamente (PEP), con transacciones de alto valor o traders situados en países de alto riesgo. Ello puede requerir etapas de verificación adicionales, solicitudes de documentación sobre el origen de los fondos y monitoreo continuo por parte de nuestro equipo de cumplimiento.

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.

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.

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.

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.

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.