ANTI-MONEY LAUNDERING POLICY

Marketricks Investment Management Company is dedicated to upholding the highest standards in anti-money laundering (AML) practices. Our Board of Directors and all employees are required to adhere to these standards to protect the integrity and reputation of our firm against misuse for money laundering, terrorist financing, or any other illegal activities. We continuously review our AML policies, procedures, and objectives to ensure a secure environment.

We have established comprehensive policies and procedures outlining our commitment to combating money laundering. Detailed documentation confirms the implementation of these standards in our daily operations. All policies are accessible to employees on our internal platform and are subject to an annual review to ensure compliance with AML regulations.

Marketricks Investment Company will refuse to open or maintain accounts if we cannot verify the true identity of a customer or the nature of their business. We will not accept assets suspected to be the proceeds of criminal activity or engage in relationships with individuals or entities known or suspected to be involved in terrorism or listed on sanctions lists. Activities such as maintaining anonymous accounts, entering into relationships with prohibited industries, or failing to report suspicious activities will be escalated to our Financial Intelligence Unit. Employees are regularly reminded of their duty to report suspicious activities promptly to the AML Officer.

We maintain a robust framework to identify, manage, and monitor AML risks, including:

• A comprehensive Know Your Customer (KYC) program.
• An employee training and awareness program.
• Processes to ensure the reliability of employees.

Regular reviews of compliance with our AML program at the group level will be conducted to ensure effective implementation. The Compliance Manager/AML Officer will oversee appropriate control measures.

Our rigorous KYC program mandates appropriate identification, risk classification, and monitoring for all clients (both individuals and entities). This program is implemented globally across all business divisions and includes the identification of beneficial owners and authorized signatories. We enforce strict identification requirements, name screening procedures, and ongoing transaction monitoring, with special safeguards for politically exposed persons and clients from high-risk countries or industries.

Marketricks Investment Company implements a comprehensive AML training program for all employees involved in processing transactions or establishing business relationships. This training raises awareness of potential money laundering patterns and covers external legal and regulatory requirements, ensuring that employees understand their responsibilities in preventing financial crime.

All data obtained must be documented in accordance with customer identification and AML security procedures. Records will be retained for a minimum of ten years, or longer if required by local laws. 

If you have any questions about this Policy, please contact us.

Marketricks Investment Management Company