AML & KYC Policy

1. Introduction and Commitment

Vakto is fully committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy sets out the measures we implement to detect, prevent, and report suspicious activity in accordance with applicable laws and regulatory requirements.

2. Legal and Regulatory Framework

• —The Money Laundering (Prevention) Act of Saint Lucia and its associated regulations.
• —The Proceeds of Crime Act of Saint Lucia.
• —The Anti-Terrorism Act of Saint Lucia and related legislation.
• —Financial Action Task Force (FATF) recommendations.
• —Applicable directives and regulations in jurisdictions where we operate.

3. Customer Due Diligence (CDD)

Before establishing a business relationship, we conduct Customer Due Diligence to verify the identity of all clients. Standard CDD requires: (i) full legal name as it appears on official documents; (ii) date of birth; (iii) residential address; (iv) government-issued photo identification (passport, national ID, or driver's licence); and (v) proof of address dated within 90 days (utility bill, bank statement, or official government correspondence).

4. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied to higher-risk clients, including: Politically Exposed Persons (PEPs) and their associates; clients from high-risk jurisdictions as designated by FATF; clients whose source of funds requires additional verification; corporate entities with complex ownership structures; and clients whose transactions or patterns raise unusual concerns. EDD may require additional documentation, interviews, or third-party verification.

5. Source of Funds and Wealth

Vakto reserves the right to request evidence of source of funds and source of wealth from any client. This is particularly applicable when deposit amounts are significant, when funds originate from unusual sources, or when a client's trading activity is inconsistent with their declared financial profile. Acceptable documentation includes bank statements, employment contracts, business accounts, or inheritance documentation.

6. Ongoing Monitoring

We continuously monitor client accounts and transactions for unusual patterns or activity that may indicate money laundering, fraud, or other financial crime. Our monitoring systems assess: transaction frequency and volume relative to client profile; geographic patterns of deposits and withdrawals; unusual trading strategies with no apparent economic rationale; rapid fund movements without associated trading activity.

7. Suspicious Activity Reporting

All employees are required to report any suspicion of money laundering or financial crime to our designated Money Laundering Reporting Officer (MLRO). We will file Suspicious Activity Reports (SARs) with the appropriate financial intelligence unit as required by law. We are prohibited by law from 'tipping off' any client or third party that a SAR has been submitted.

8. Record Keeping

We maintain records of all KYC documentation and transaction data for a minimum of 5 years following the end of a business relationship, or longer where required by applicable regulations. All records are stored securely and made available to regulatory authorities upon lawful request.

9. Staff Training

All Vakto employees receive regular training on AML/CFT obligations, red flag indicators, and internal reporting procedures. Our compliance team conducts periodic assessments to ensure awareness of current regulatory requirements and emerging typologies of financial crime.

10. Sanctions Screening

We screen all clients and transactions against applicable sanctions lists, including those maintained by the UN Security Council, OFAC, HM Treasury, and the EU. Clients and transactions involving sanctioned individuals, entities, or jurisdictions will be refused or frozen. We conduct periodic re-screening of existing clients as sanction lists are updated.