KYC / AML Policy

ZeonFX is committed to the highest standards of compliance against money laundering (AML) and anti-terrorist financing (ATF). The objective of the Company's Policy against Money Laundering and Terrorism Financing is to actively prevent the risks of these matters. To help the government combat the financing of terrorism and money laundering activities, the law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. We have an obligation to report suspicious client activity relevant to money laundering.

INTRODUCTION

ZeonFX Limited ("ZeonFX", "we", "us", "our") has adopted this KYC/AML Policy in accordance with applicable anti-money laundering and counter-terrorist financing laws and regulations. This policy applies to all clients, products, and services and is designed to prevent the use of our services for money laundering or the financing of terrorism.

MONEY LAUNDERING DEFINITION

Money laundering is the process of converting funds received from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that appear legitimate to hide or distort the actual source of funds.

The money laundering process can be divided into three sequential stages:

PLACEMENT

The stage at which criminally derived funds are introduced into the financial system or used to purchase assets. ZeonFX does not accept cash deposits or cash payments under any circumstances.

LAYERING

The funds are transferred or moved to other accounts and other financial instruments. It is done to disguise the origin and interrupt the indication of the entity that carried out the multiple financial transactions. Moving funds and changing their form makes it difficult to track the money that is being laundered.

INTEGRATION

The funds are re-circulated as legitimate to purchase goods and services. ZeonFX adheres to the principles of Anti-Money Laundering and actively prevents any action that targets or facilitates the legalization process of illegally obtained funds. The AML policy means preventing the use of the company's services by criminals, with the objective of money laundering, terrorist financing, or other criminal activity.

OUR COMMITMENT

ZeonFX does not accept or pay in cash under any circumstances. The company reserves the right to suspend the operation of any client which may be considered illegal or, in the opinion of the staff, related to money laundering.

ZeonFX will ensure that each client is a real or legal person. ZeonFX performs all necessary measures in accordance with applicable laws and regulations issued by the relevant monetary and regulatory authorities.

The AML policy is implemented within ZeonFX through the following means:

Know Your Customer (KYC) policy and customer due diligence

Ongoing monitoring of customer activity

Registry and record maintenance

Reporting of suspicious activity

Sanctions and PEP screening

KNOW YOUR CUSTOMER (KYC) AND DUE DILIGENCE

Due to the company's commitment to AML and KYC policies, each customer must complete a verification procedure before ZeonFX initiates any cooperation. The company ensures that satisfactory evidence is presented or other measures are taken that produce satisfactory proof of the identity of any client or counterparty.

The company applies increased scrutiny to clients who are residents of countries identified by credible sources as having inadequate AML standards or who may pose a high risk of crime and corruption, and to beneficial owners who reside in or whose funds are sourced from such countries.

INDIVIDUAL CLIENTS

During the registration process, each client provides personal information, specifically:

Full name

Date of birth

Country of origin

Full residential address

Contact details (email, telephone)

Profession and source of funds

The following documents are required to verify personal information (if documents are written in non-Latin characters, a notarized English translation may be required to avoid delays):

Identity verification (one of the following):

Valid passport (first page with photo and signature clearly visible); or

Driving licence with photograph; or

National identity card (front and back)

Proof of address (one of the following, not older than 3 months from the date of submission):

Utility bill

Bank statement

Tax authority letter

Official government correspondence

Documents must contain the customer's full name and place of residence and must be current.

CORPORATE CLIENTS

Where the applicant company is listed on a recognized or approved stock exchange, or where there is independent evidence that the applicant is a wholly owned subsidiary or under the control of such a company, simplified due diligence may apply.

Where the company is not listed and none of the main directors or shareholders already has an account with ZeonFX, the following documentation must be provided:

Certificate of incorporation or national equivalent

Memorandum and Articles of Association and statutory declaration or national equivalent

Certificate of good standing or other proof of the company's registered address

Board resolution to open an account and grant authority to those who will operate it

Copies of powers of attorney or other authorities granted by the directors

Proof of identity of the directors (in accordance with individual identity verification rules above)

Proof of identity of the ultimate beneficial owner(s) and/or the person(s) under whose instructions the account signatories are empowered to act (in accordance with individual identity verification rules above)

ONGOING MONITORING AND TRACKING CUSTOMER ACTIVITY

In addition to collecting customer information at onboarding, ZeonFX continues to monitor the activity of each customer to identify and prevent any suspicious transactions. A suspicious transaction is one that is not consistent with the legitimate business of the customer or with the known transaction history of the customer.

ZeonFX has implemented a transaction monitoring system (both automated and, where necessary, manual) to prevent the use of the company's services for money laundering or other financial crime. We monitor for unusual patterns, high-risk jurisdictions, and other red flags in accordance with our internal procedures.

REGISTRY AND RECORD MAINTENANCE

Records must be kept of all transaction data and data obtained for identification purposes, as well as all documents related to money laundering issues (e.g. suspicious activity reporting files, AML account monitoring documentation). Those records are kept for a minimum of 7 years after the account is closed, in line with applicable regulatory requirements.

REPORTING AND MEASURES TAKEN

Where ZeonFX suspects that a transaction or activity is related to money laundering or other criminal activity, it will proceed in accordance with applicable law and report the suspicious activity to the relevant regulatory authority. We are prohibited from informing the client that a report has been made.

ZeonFX reserves the right to suspend the operation of any client which may be considered illegal or related to money laundering in the opinion of the staff. ZeonFX has full discretion to temporarily block a suspicious customer's account or terminate the relationship with an existing customer. We may also refuse to open an account or execute a transaction where we are not satisfied as to the client's identity or the legitimacy of the activity.

WITHDRAWALS AND SAME-NAME / SAME-SOURCE RULE

Any withdrawal of funds from your ZeonFX account to a bank account can only be refunded to the same bank account that the funds were originally received from, or to another bank account in the client's individual name, in accordance with our Deposit & Withdrawal Policy. Processing times depend on the currency, location, and policies of the recipient's financial institution; please expect amounts to be credited within 2 to 7 business days where applicable.

SANCTIONS AND PROHIBITED JURISDICTIONS

ZeonFX does not provide services to individuals or entities in jurisdictions subject to comprehensive sanctions or where doing so would violate applicable sanctions laws. We screen clients and transactions against relevant sanctions, PEP (Politically Exposed Persons), and adverse media lists as required by our compliance procedures. For a list of restricted countries, please see our Restricted Countries page.

UPDATES TO THIS POLICY

ZeonFX may update this KYC/AML Policy from time to time to reflect changes in law, regulation, or our procedures. The current version will always be available on our website. Continued use of our services after any update constitutes acceptance of the revised policy.

CONTACT

For any questions regarding this KYC/AML Policy or to submit documentation, please contact us at support@zeonfx.com.