1. Introduction

This Anti-Money Laundering (AML) Policy outlines the measures and procedures implemented by FundsCap (hereinafter referred to as “the Company,” “we,” “our,” or “us”) to prevent and detect money laundering and the financing of terrorism. In accordance with regulatory requirements and industry best practices, this policy addresses customer identification and verification, as well as the use of SumSub, a third-party software for identity verification. 

2. Purpose

The purpose of this AML Policy is to: 

• • Ensure compliance with anti-money laundering and counter-terrorism financing regulations. 

• • Identify and mitigate risks associated with money laundering and illicit financial activities. 

• • Establish procedures for customer identification and verification, including the use of SumSub. 

3. Customer Identification and Verification

3.1. Customer Due Diligence (CDD) 

We will perform customer due diligence (CDD) to understand our customers, their financial activities, and the potential risks they may pose. This includes assessing the purpose and intended nature of the business relationship, transaction, or activity. 

3.2. Customer Identification 

We require customers to provide the following information and documentation during the onboarding process: 

a. Name

b. Date of Birth

c. Contact Details (address, phone number, email)

d. Identity Documentation (passport, national ID, or other government-issued ID)

e. Proof of Address (utility bill, bank statement, or similar)

3.3. SumSub – Third-Party Identity Verification 

The Company employs SumSub, a third-party software solution, for customer identity verification. SumSub uses a combination of document checks, facial recognition, and biometric data analysis to verify the authenticity of customer-provided identification documents. By using SumSub, we aim to: 

• • Verify the identity of customers. 

• • Detect and prevent identity theft. 

• • Ensure that customers are not on international watchlists or sanctions lists. 

4. Ongoing Monitoring

We will continuously monitor customer transactions and activities for any unusual or suspicious behaviour. This includes reviewing the nature of transactions, the source of funds, and any deviations from established patterns of behaviour. 

5. Reporting Suspicious Activities

If we identify any suspicious activities or transactions, we will promptly report them to the relevant authorities in accordance with regulatory requirements. We will also cooperate with law enforcement and regulatory agencies in any related investigations. 

6. Record Keeping

The Company will maintain records of customer identification and verification data, as well as transaction records, for a minimum of 5 years. These records will be made available to regulatory authorities upon request. 

7. Staff Training and Awareness

Our employees will receive training to raise awareness of AML and CTF (Counter-Terrorism Financing) risks and to ensure compliance with this policy. Training will be ongoing to keep staff informed about the latest developments in AML regulations. 

8. Policy Review

This AML Policy will be reviewed and, if necessary, updated at least once a year to ensure it remains compliant with regulatory requirements and reflects best practices. 

9. Contact Us

If you have any questions, concerns, or requests related to this AML Policy, please contact us at: 

FundsCap Limited 

Registered Address: Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Saint Lucia LC01 401 

Email: [email protected]  

By using our services, you agree to comply with and adhere to this AML Policy. We appreciate your cooperation in helping us combat money laundering and the financing of terrorism.