Policy Statement

ZQFX is firmly committed to the prevention of money laundering, terrorist financing, and financial crime. While incorporated as an International Business Company under Seychelles law, ZQFX voluntarily aligns its practices with international AML/CTF standards to protect its business, partners, and clients.

Objectives

• • Safeguard the Company from being misused for illicit purposes.
• • Establish and verify the true identity of all clients.
• • Apply a risk-based approach to onboarding and transactions.
• • Monitor client activity for unusual or suspicious behavior.
• • Report and escalate suspicious activity according to international standards.

AML Compliance Officer

• • ZQFX has appointed an AML Compliance Officer (AMLCO) responsible for AML/CTF compliance.
• • The AMLCO has authority to block, restrict, or terminate accounts where risks are identified.

Customer Identification (KYC)

• • Proof of Identity – Passport, national ID, or government-issued driver’s license.
• • Proof of Address – Utility bill, bank statement, or official correspondence (not older than 3 months).
• • Additional Verification – Source of funds, source of wealth, or enhanced due diligence documents for high-risk cases.
• • No account is activated until the KYC process is fully completed.

Ongoing Monitoring

• • Client accounts are continuously monitored for unusual or high-value activity.
• • Transactions inconsistent with client profiles may trigger Enhanced Due Diligence (EDD).
• • Suspicious activities are escalated internally and reported to authorities when required.

Risk-Based Approach

• • Clients are classified as Low, Medium, or High risk.
• • High-risk clients (e.g. PEPs or high-risk jurisdictions) are subject to enhanced controls.
• • Business relationships may be declined or terminated if risk is unacceptable.

Record Keeping

• • All AML and KYC records are securely stored for at least 5 years after relationship ends.
• • Records are only disclosed to competent legal or regulatory authorities when required.

Staff Training

• • All employees undergo AML/CTF training at onboarding and periodically.
• • Training includes due diligence, red flag detection, and reporting obligations.

Non-Compliance

• • Accounts may be suspended or closed for invalid or misleading information.
• • Pending transactions may be blocked in case of risk.
• • Cases may be reported to authorities if legally required.

Confidentiality

All information collected during AML/KYC processes is kept strictly confidential and protected under the ZQFX Privacy Policy. Disclosure is made only when legally required.

Policy Review

This AML Policy is reviewed regularly to ensure compliance with evolving international standards and industry best practices.