Countering money laundering

Fusion Trade Mark opposes money laundering and supports the fight against money launderers.

Fusion Trade Mark The company has policies in place to protect people from money laundering.

What is money laundering?

Money laundering is not simply an attempt to conceal money derived from the sale of drugs. Money laundering involves any transaction or series of transactions designed to conceal or disguise the source of proceeds derived from illegal activities, including drug trafficking, terrorism, organised crime, fraud and many other crimes. Money laundering occurs when any funds derived from illegal/criminal activity are moved through the financial system. The movement takes place in such a way as to give the impression that the funds have come from legitimate sources.
There is no specific method of money laundering; however, laundering is characterised by three stages in which money launderers may engage in numerous transactions that may be determined by a financial institution to be illegal: First, placement - the physical disposition of funds derived from illegal activity; in other words, the funds or cash equivalents are placed in the financial system.
Second, layering - separating illicit proceeds from their source by creating complex financial transaction structures designed to conceal transaction traces and provide anonymity; in other words, money is transferred or moved to other accounts (e.g. futures accounts) through a series of financial transactions designed to conceal the origin of the money (e.g. executing transactions with little or no financial risk or transferring account balances to other accounts).
Third, and finally, integration - providing apparent legitimacy to criminally obtained wealth; in other words, funds are reintroduced into the economy so that it appears that the funds came from legitimate sources (e.g., closing a futures account and transferring the funds to a bank account).
Trading accounts are one of the tools that can be used to launder illicit funds or to conceal the true owner of those funds. In particular, a trading account can be used to carry out financial transactions that help to disguise the origin of funds.
Fusion Trade Mark directs withdrawals back to the original remittance source as a preventative measure.
The international fight against money laundering requires financial services institutions to be aware of potential money laundering abuses that may occur in customer accounts and to implement a rigorous compliance programme to prevent, detect and report potential suspicious activity.

Determination of suspicious activity

At this time, there is no clear regulatory guidance on what is considered "suspicious activity".
The determination of whether a transaction or series of transactions is suspicious will necessarily depend on the customer and the specific transaction(s) in relation to the customer's normal business activities. Unusual or questionable transactions, sometimes referred to as "red flags", may include those that do not appear to have a reasonable economic basis or recognisable strategy based on what the firm knows about the client. Suspicious activities can occur either at the very beginning of a relationship with a client or long after the relationship has been established.

Know Your Customer ("KYC")

The Company has separate account opening procedures that are followed when opening new accounts. These procedures should be read in conjunction with the section "Screening of Potential Customers and Anti-Money Laundering Measures". However, in addition to these new account opening procedures, each Related Person must be familiar with the identity of its customer. The following are factors to consider in fulfilling the "Know Your Customer" obligation. The Compliance Officer will also be responsible for reviewing all new accounts and conducting an annual review of all accounts, taking into account the following factors: Whether the customer is an individual, intermediary, public, private or domestic corporation, financial or non-financial institution, regulated person or organisation;
Whether the customer has been an existing customer for a significant period of time; How the customer became a customer of the Company (e.g. the customer is personally known to a Related Person who was recommended by a long-established existing customer, etc.); Whether the customer's country of residence is a member of the Financial Action Task Force ("FATF").

"Red Flags" - indicators at the account opening stage:

The following is a list of potential indicators of suspicious activity that, while not exhaustive, may be indicative of money laundering:
The client shows unusual concern about the firm's compliance with government reporting requirements, particularly with respect to his or her identity, type of business and assets, refuses or is reluctant to disclose any information concerning business activities, or provides unusual or suspicious information or business records;
The client wishes to engage in transactions that lack business sense, an obvious investment strategy or that do not fit the client's stated business/strategy;
The client (or a person publicly associated with the client) has a questionable past or is the subject of news reports indicating possible criminal, civil or regulatory violations;
The client appears to be acting as an agent for another organisation but refuses, evades or is unwilling, without legitimate commercial reason, to provide any information in response to questions about that organisation;
The client has difficulty describing the nature of their business or lacks general knowledge of their industry;
Information provided by a customer that identifies a legitimate source of funds is false, misleading, or materially incorrect; and Upon request, the customer refuses to identify or fails to identify any legitimate source of his or her funds and other assets.

Customer due diligence, anti-money laundering measures

The Company has procedures in place to prevent and detect money laundering. As part of these procedures, the Company has also developed detailed procedures for screening new customers. Such procedures are discussed in more detail in the context of anti-money laundering. The Compliance Officer is responsible for approving all new accounts to ensure that no account is subject to restriction or blocking prior to opening.
All new accounts must be checked and approved by the Compliance Officer before they are opened. It is essential that all necessary information is obtained and that all account holders and principal account holders are identified and matched against the lists of terrorists and suspected terrorists published by the Office of Foreign Assets Control ("OFAC") and other lists published by the Financial Services Authority. Action Task Force ("FATF") Anti-Money Laundering Task Force. The Complianceofficer is responsible for ensuring that the Company complies with the anti-money laundering procedures set out in a separate section entitled "Anti-Money Laundering Compliance Programme".

Verification of documents

Fusion Trade Mark should obtain the following information from all potential customers:
For residents:
A copy of an unexpired government-issued ID card with proof of citizenship or residence and a photograph (e.g. driver's licence, passport, alien registration card or similar ID card).
Bank card (on the front side of the card, the first 6 digits, the last 4 digits, the expiry date and the name of the holder must be visible. On the reverse side, the CVV code must be covered) A valid official utility bill with the name and address of the user (water, gas, electricity, telephone, bank statement, etc.) issued within the last three months.

For Non-Residents / Institutions or Institutions:

Memorandum and Articles of Association (certified original)
Certificate of registered address (certified original)
Directors' and shareholders' certificate (certified original)
Certificate of registration (certified original)
Account opening form completed, signed and initialled on each page Completed minutes, signed and initialled on each page
Financial position of the company - audited financial statements for the last 2 years
Complete documents: passport/ID, copy of credit card and proof of address (i.e. utility bill) of authorised person.
Passport/ID card, proof of address (e.g. utility bills) of all shareholders of the Company.

Fusion Trade Mark will be forced to close an account in cases where:

The identity of the potential client cannot be verified.
There is any doubt as to the legality of the source or use of the client's funds.
The client refuses to provide the mandatory information.
The information provided seems false or suspicious.
The information is contradictory and cannot be explained after further enquiries.

Deposits and withdrawals

Withdrawal Orders: The provision of documentation or any other type of Customer authentication that may be required from time to time under anti-money laundering (AML) regulations, credit card issuing companies and Fusion Trade Mark , is a prerequisite before executing a withdrawal order.
In accordance with the rules of the credit card companies, deposits may be returned to the same credit card upon withdrawal. Withdrawals to a bank account where initial deposits were made using credit cards will be made back to the credit card or bank account at the discretion of the company. Withdrawals to a bank account may take a longer period of time due to additional security procedures and documentation from the Client.
Credit Card Deposit Differences: If you select a base account currency other than U.S. dollars, your credit card may be charged amounts that, due to exchange rates and credit card company fees, may differ slightly from the original amount you deposited into your account. You hereby acknowledge that such changes may occur and hereby confirm that you will not attempt to object or request a refund. Please note that this phenomenon can be avoided when using the US dollar as the base currency of the account.
Bank Transfers: When making a deposit by bank transfer, as required by anti-money laundering regulations, you must use only one bank account that is opened in your country of residence in your name. An authentic SWIFT confirmation or transfer confirmation showing the origin of the funds must be sent to the worldwide legal name of Fusion Trade Mark brand Fusion Trade Mark . Failure to provide such SWIFT/confirmation may result in a refund of the deposited amount, resulting in the inability to deposit amounts into your Fusion Trade Mark account . Any withdrawal of funds from your Fusion Trade Mark account to a bank account can only be refunded to the same bank account from which the funds were originally received.
Alternative payment methods (e-wallets; money transfer services; Internet payment providers, etc.): when depositing funds using means other than credit cards and/or banks, you agree and acknowledge that you are bound by the terms and rules of such service, including but not limited to fees and other restrictions. Fusion Trade Mark, at its sole discretion, may make withdrawals to a means other than the means used for the initial deposit in accordance with the Company's rules and anti-money laundering regulations.

The company does not accept cash deposits.

These recommendations have been implemented to protect Fusion Trade Mark and its clients.

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