ANTI-MONEY LAUNDERING (AML) & COUNTER-TERRORIST FINANCING (CTF) POLICY
Executive Commitment & Statutory Framework
Novixa Fund is committed to the highest standards of compliance against money laundering (AML) and counter-terrorist financing (CTF). The objective of the Company’s Policy against Money Laundering and Terrorism Financing is to actively prevent the risks of these matters across all foreign exchange (Forex) and contract for difference (CFD) brokerage activities.
To help international statutory bodies and governments combat the financing of terrorism and money laundering activities, financial compliance laws require all authorized financial institutions to obtain, verify, and record information that identifies each person or entity opening a trading account. Novixa Fund operates under a strict legal obligation to monitor client activities and report any suspicious client activity relevant to money laundering to appropriate authorities.
Definition & Sequential Stages of Money Laundering
Money Laundering is the process of converting funds or assets received from illegal activities (such as fraud, corruption, organized crime, or terrorism) 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:
Funds originating from criminal conduct are converted into financial instruments or deposited into bank accounts and trading accounts. To avoid detection and suspicion, money launderers frequently deposit small amounts over time across multiple channels (a practice commonly referred to as 'smurfing').
Layering:
Funds are transferred, converted, or routed through multiple accounts and financial instruments to obscure their original source and interrupt audit trails. In forex trading, this may involve complex trading across currency pairs or rapid inter-account transfers.
Integration:
Laundered funds are reintroduced into the economy as apparently legitimate capital through investments, asset acquisitions, or legitimate commercial withdrawals.
Critical Controls
Critical Operating Restrictions
Zero Physical Cash Acceptance
To prevent money laundering, Novixo Capital Ltd does NOT accept or pay out physical cash, cash equivalents, third-party cheques, or anonymous money transfers under any circumstances.
Strict Return-to-Source (RTS) Rule
Unilateral Right to Suspend
Implementation Framework & Procedures
Novixa Fund ensures that all registered clients are verified real and legal persons or corporate entities. The company performs mandatory due diligence in accordance with applicable statutory regulations. The AML policy is implemented through three core operational pillars:
Know Your Customer (KYC) Policy:
Rigorous identity verification and due diligence procedures prior to account activation.
Transaction & Trade Monitoring:
Real-time automated and manual surveillance of customer funding and trading activity.
Comprehensive Record Maintenance:
Secure archiving of client identity documentation and complete transactional audit trails.
Monitoring Client Activity & Suspicious Red Flags
Novixa Fund continuously monitors ongoing client financial activity to detect, investigate, and prevent suspicious transactions. Suspicious activity includes any transaction or trading behavior that is inconsistent with a client’s normal trading pattern, declared financial profile, or apparent commercial purpose.
Key Indicators of Suspicious Activity (Red Flags)
Novixa Fund ensures that all registered clients are verified real and legal persons or corporate entities. The company performs mandatory due diligence in accordance with applicable statutory regulations. The AML policy is implemented through three core operational pillars:
High Deposit Volume with Minimal Trading:
A client deposits significant capital and immediately requests a withdrawal without engaging in meaningful market trading.
Third-Party Funding Attempts
Attempts to fund a trading account from a bank account or credit card belonging to an unrelated third party.
Structured Payments (Smurfing):
Multiple incoming deposits submitted just below regulatory identification or reporting thresholds within a short timeframe.
High-Risk Jurisdictional Connections:
Transfers originating from or directed toward non-cooperative or high-risk jurisdictions as flagged by international authorities.
Record Maintenance & Audit Standards
To support law enforcement investigations and maintain complete audit capability, Novixa Fund securely stores:
- All individual and corporate client identification records and supporting documentation.
- Complete transactional ledgers, trade histories, deposit/withdrawal records, and banking receipts.
- Internal AML review notes, risk assessments, and communication logs.
Retention Standard: All records are maintained in encrypted archives for at least seven (7) years following the formal closure of the trading account or termination of the business relationship.
Mandatory Enforcement & Regulatory Reporting Actions
In any case of suspected money laundering or terrorist financing, Novixa Fund acts decisively in full accordance with applicable law and reports details to relevant statutory financial intelligence units (FIUs). The company may execute the following enforcement actions without prior client notification:
- Immediate suspension or cancellation of pending trading orders and withdrawal requests.
- Freezing or permanent closure of trading accounts involved in suspicious activity.
- Termination of the business relationship and blocking of associated access credentials.
- Filing of formal Suspicious Activity Reports (SARs) with regulatory authorities.
Get in Touch With Novixa Fund
Contact Information & Compliance Department
CONFIDENTIAL & PROPRIETARY — FINANCIAL COMPLIANCE DOCUMENT