Measures to Prevent Financial Crime

JMS Trading Limited (Company No. C 108433), a Virtual Financial Assets Service Provider licensed by the Malta Financial Services Authority (MFSA) under the Virtual Financial Assets Act (Authorization ID – JTL – 24283) (hereinafter referred to as Company) prioritizes the prevention of financial crime as a core component of its ethical business practices. We are firmly committed to identifying and mitigating the risk of being involved—directly or indirectly—in illicit financial activities across all facets of our operations. Our framework for financial crime prevention outlines the necessary risk management and internal controls to ensure the organization and its employees can effectively identify, assess, investigate, report, and manage risks associated with financial misconduct. Central to our compliance approach is the implementation of robust customer due diligence, in line with the Know Your Customer (KYC) principle. We place significant value on fostering long-term customer relationships, which enhances our ability to detect irregularities. As part of our diligence process, the Company is committed to identifying beneficial owners—individuals who derive substantial benefit from business dealings even if they are not directly engaged or in communication with us.

Company’s risk-based strategy for preventing financial crime includes the following key components:

• Conducting comprehensive risk evaluations twice a year to assess exposure to financial crime threats across customer segments, geographical presence, transaction flows, products, services, and delivery methods.
• Applying a tiered risk approach during client onboarding, encompassing identity verification and due diligence. This initial analysis sets benchmarks for expected behaviour, aiding in ongoing risk monitoring.
• Continuously reviewing and analysing customer activity to detect suspicious patterns or transactions and fulfilling obligations to report such activity to competent authorities.
• Implementing systems and controls to ensure compliance with sanctions imposed by the United Nations, European Union, United States, United Kingdom, and other relevant jurisdictions.
• Discontinuing relationships that pose an unmanageable financial crime risk.
• Maintaining thorough and accurate records related to clients and transactions, in line with regulatory retention requirements.
• Ensuring the effectiveness of our financial crime framework through regular independent audits and reviews.
• Delivering mandatory training to all new employees upon joining and requiring semi-annual refresher courses for all staff, including executive management.

In line with our regulatory and ethical standards, the Company reserves the right to block or decline transactions, freeze assets, restrict access to services, or terminate relationships when financial crime risks are identified. We may also impose enhanced requirements beyond those mandated by law and refrain from supporting certain business activities, even when they are legally permissible.

Combating Money Laundering, Terrorist Financing, and Proliferation Financing

The Company does not engage with client types deemed to present an unacceptably high risk of money laundering, terrorism financing, or proliferation-related activities. Where customers exhibit elevated risk—such as politically exposed persons (PEPs), or entities based in jurisdictions with known AML/CFT weaknesses—heightened scrutiny and enhanced controls are applied.

Sanctions Adherence

The Company is fully aligned with the sanctions regulations enforced by global authorities including the United Nations, European Union, United States, United Kingdom, and other jurisdictions where the Company operates. As a result, Company may be legally or internally restricted from offering services to certain individuals or entities. In some instances, transactions may be held for compliance review. If a transaction appears to contravene applicable sanctions or fall outside Company’s risk tolerance, we may suspend access to funds or reject the transaction outright. Additional steps may be taken to prevent any breach of applicable economic sanctions.

Anti-Bribery and Anti-Corruption Measures

We uphold the highest standards of integrity and strictly prohibit all forms of bribery and corruption. No employee or affiliate of the Company may directly or indirectly offer, solicit, or accept bribes or use influence inappropriately to gain a business advantage. The receipt or processing of assets obtained through corrupt practices is similarly forbidden. As part of our risk management programme, all customers and third parties are evaluated for bribery and corruption risk, which influences the extent of due diligence and the monitoring protocols applied to them.

Fraud Risk Management

The Company employs controls to deter, detect, and respond to fraudulent activity associated with its services or customers. We are committed to preventing both internal and external fraudulent conduct, and we will not process transactions suspected of being fraudulent. We also avoid entering into or maintaining relationships with individuals or entities known or reasonably suspected to be involved in fraudulent schemes.