AML & CTF Policy

This policy underscores the critical importance of compliance with relevant legal and regulatory frameworks, emphasizing a proactive approach towards preventing money laundering and financial crime activities.

A key objective of this policy is to encourage staff members to actively consider potential financial crime risks in the course of their duties. This includes fostering a comprehensive awareness of WePro's internal procedures designed to deter any illicit use of the platform for financial crime.

This Policy is not only approved but also endorsed by the Board of WePro. Furthermore, it undergoes a minimum annual review in conjunction with the Annual Risk Assessment and Group requirements. This iterative review process ensures that the policy remains dynamic and effective in mitigating financial crime risks.

This policy serves as a reinforcement of WePro's Code of Conduct, emphasizing the critical intersection between maintaining the firm's reputation and adhering to legal obligations.

The policy is subjected to an annual review, aligning with the broader risk assessment process. This regular review is imperative to ensure that the policy continues to provide robust guidelines for effective financial crime risk management.

This policy operates in conjunction with other essential policies, namely: • A. WePro KYC and Due Diligence Procedures • B. WePro On-boarding and Customer Risk Assessment Procedures (including PEPs and Sanctions) • C. WePro Compliance Monitoring Procedures

Globally, there exists a longstanding obligation to have effective procedures in place to detect and prevent money laundering. Specifically, WePro (License Number: 2025-00776), registered as WePro Limited in the St.Lucia is committed to adopting suitable AML policies and procedures.

WePro is committed to adhering to all global standards and applicable legislation. The policies and procedures outlined in this document are meticulously designed to ensure the firm's ability to detect and prevent money laundering activities.

Money laundering is precisely defined as the process through which criminals seek to conceal the true origins and/or ownership of the proceeds or benefits derived from criminal activity. This process aims to make the proceeds appear legitimate, thereby allowing perpetrators to evade prosecution, conviction, and the confiscation of criminal funds.

Given that financial institutions are often exploited for money laundering, it is imperative for employees within the sector to be cognizant of the regulatory requirements placed on both the firm they work for and themselves as individuals.

While money laundering is traditionally categorized into three stages, it's important to note that these stages may not occur in every case. Nonetheless, the three classic stages include: Placement: Physically introducing cash or other proceeds into the financial system. Layering: Moving proceeds through various financial transactions to complicate the audit trail. Integration: Sufficiently distancing funds from their origin to give the appearance of legitimacy and integrating them into the economy.

The layering stage poses the greatest risk for WePro. Employees should remain vigilant for any suspicious behavior by clients during this stage, such as attempting to make cash payments into their accounts or routing funds through third-party accounts.

Integration is the point at which funds have been sufficiently distanced from their origin to achieve the appearance of legitimacy, making it crucial for WePro to exercise due diligence to prevent such integration.

During the layering stage, WePro is particularly at risk. Employees should exercise vigilance for any suspicious behavior by clients, including but not limited to: • Trying to make cash payments into their account. • Depositing money only to withdraw it at a later date without engaging in any trading activity. • Deposits exceeding the amount stated as available for trading on application forms. • Routing funds through third-party accounts. • Engaging in trading without considering transaction costs. • Making extensive use of overseas accounts or complex corporate structures.

Having sufficient information about a client is an invaluable tool in the fight against financial crime and can protect WePro from reputational and financial risk.

Customer due diligence involves finding out the intended purpose and nature of the business relationship, identifying the customer, and verifying their identity based on reliable documents or data. Natural persons and legal entities undergo identification and verification as part of the on-boarding process.

WePro adopts a risk-based approach, considering factors such as business type, delivery channels, customer base, and geographic location of clients. Additionally, PEP and Sanction checks are conducted during on-boarding using relevant online systems.

The firm must ensure that systems and controls include appropriate training for its employees in relation to money laundering.

At WePro, all new employees are required to attend an introductory financial crime presentation provided by the Compliance department. Regular refresher training is provided for existing employees, usually in the form of computer-based testing. Ad-hoc training sessions are conducted as deemed necessary by the Compliance Department, with updates provided to staff.

Firms must keep records of client identity, transactions, and financial crime training to mitigate risks and demonstrate compliance.

WePro retains a copy of each client's identity evidence for five years after the client ceases to be a client or from the date of the last transaction if there is no formal termination of the relationship. Records of each transaction must also be retained for five years from the completion date.

Terrorism involves the use or threat of action to influence the government, intimidate the public, or advance a political, religious, or ideological cause.

The relevance to financial institutions is 'terrorist property' and the laundering of such property. It is defined as money or other property likely to be used for terrorism or proceeds of acts carried out for the purposes of terrorism.

While similarities exist, differences include the minimal amounts required for individual terrorist acts and the challenge of identifying when legitimate funds transform into terrorist property.

WePro's obligation in combating terrorist financing is to report any suspicious activity to the authorities, supporting law enforcement agencies in freezing property where there are reasonable grounds to suspect it could be used for terrorist activity.

Fraud encompasses any attempt, successful or not, to secure an unfair or unlawful gain through deliberate misrepresentation or omission of material facts.

Various safeguards are in place at WePro to prevent fraud, including a Code of Conduct, client take-on standards, client authentication, and payment process standards.

Procedures are in place to detect and report any fraudulent activity, and employees are obligated to report suspicions to the AML/CTF reporting officer. Internal reporting is crucial in initiating further investigation or external reporting when necessary.

Bribery is defined as offering money, services, or valuable items to induce someone to do something in return. Corruption is acting dishonestly for personal gain, abusing an official position to the disadvantage of others.

Procedures in place at WePro to combat bribery and corruption include a Whistleblowing Policy, Gifts and Inducement Policy, periodic policy reviews, training for all staff, and checks for Sanctions and Politically Exposed Persons (PEPs) for every new client.

Market abuse pertains to behavior by an individual or group in relation to qualifying investments traded on a prescribed market. There are seven types of abusive behavior, covering insider dealing, improper disclosure, misuse of information, manipulating transactions, manipulating devices, dissemination, and distortion.

Several indicators of suspicious transactions include significant orders made immediately after opening an account, transactions significantly deviating from a client's usual behavior, unusual trading patterns before price-sensitive information announcements, and an employee's own account transactions timed before client transactions.

Any suspicions of market abuse or suspicious transactions must be reported to the AML/CTF reporting officer without delay for further investigation and potential external reporting.

This Policy is approved and endorsed by the Board, with quarterly reports on AML issues submitted to the risk committee.

The AML/CTF reporting officer is designated to provide an annual report to the Board on systems and controls for preventing money laundering. The officer also conducts an annual AML Risk Assessment, investigates internal suspicions, and communicates well-founded details to external agencies and regulators as necessary.

WePro's Compliance department undertakes various monitoring programs to prevent the platform's use in financial crime. This includes weekly sampling of client accounts and daily checks of funds paid into client accounts for suspicious activity.

You must sign the declaration below, indicating that you have read and agreed to comply with the policies and procedures at WePro (Company Number: 2025-00776) to prevent money laundering, terrorist financing, and financial crime. Please return this to Compliance.