GEMFOREX’s Anti-Money Laundering Policy

Lindholm Capital Ltd (“hereinafter GEMFOREX”) as a provider of investment services related to financial products, issued this Anti Money Laundering Policy (hereinafter referred to as AML) regarding the provision of investment services related to financial products.

As a financial company is subject to laws and other forms of regulation of anti-money laundering (“AML”), which results in many measures, principles and rules that can be seen by applicants for business, clients or partners while dealing with GEMFOREX. itself, its subsidiaries, branches, subordinated enterprises or affiliates. To show the importance and willingness to comply with legal requirements and so to help achieve the goals of such, GEMFOREX has adopted within its structure the policies and measures required by the laws of European Union, which are widely known for being highly severe with subject persons performing within its jurisdiction and requiring them to follow very strict rules. Due to these rules and requirements, GEMFOREX focuses on the following.

  • Pay close attention to all information such as identity verification based on the information provided by the applicant such as each client or partner, its background, related activities, business, etc.;
  • Continuously monitor the activity of clients, partners and their transactions and make sure that they are in line with our AML and terms and conditions regarding our clients;
  • Create and safe keep records of accounts, transactions, communications with clients and partners, gathered information, concerned internal matters and particular procedures
  • Evaluate the possibility of money laundering while dealing with clients and transactions as well as the clients’ risk rate.
  • Apply enhanced due diligence when dealing with suspicious persons, trustees, politically exposed persons, clients from non-reputable jurisdictions and large deposits that exceed the threshold limit;
  • Organize quarterly and annual external trainings for employees, especially for those who deal directly with clients and partners;
  • Cooperate with a responsible Money Laundering Compliance Officer (MLCO) appointed upon employees of GEMFOREX and approved by the regulatory authorities;
  • Monitor changes to relevant legislation, sanction list, and International Financial Regulators and adopt new measures if necessary.
  • Prohibit offering any anonymous account or maintain business relationships with shell banks.
  • Report Suspicious Transactions to the competent Authority if deemed suspicious by the Money Laundering Compliance Officer.

In addition, if GEMFOREX operates in any way within a jurisdiction, where AML rules require some additional measures, GEMFOREX makes sure to meet all the additional requirements and ensures that relevant matters are handled accordingly.

The goal GEMFOREX would like to achieve by adopting a strict AML policy is to prevent itself, its clients, partners, employees, and the industry from being misused for money laundering, terrorist financing or other financial crimes.

GEMFOREX is fully aware of possible harmful effects and danger to the global society, which comes together with the possibility for wrongdoers and criminals to disguise criminal origin of property, transfer, acquire or in any way legalize the ownership of such property.

The most significant consequences of GEMFOREX.’s AML policy, that may affect either applicants for business, clients, or partners, are as following:

  • GEMFOREX develops a specific application through which any applicant has to enter data and upload documents if new account opening is requested. The application safe keeps all data, documents, records on transactions and trades executed by each client.
  • If you wish to open a new account, you will need to submit detailed personal information such as name, address, nationality, date of birth, ID number, nature of business in the case of a company, etc.
  • During this process (even before the account is opened) all this data is verified by requesting applicants to upload a copy of their Proof of Identity and Proof of Residence (proof of existence, list of directors and shareholders in case the applicant is a company, and other necessary due diligence documents). Applicant must further fill in an investment questionnaire, where employment and income details, history and experience with investment services are asked about.
  • All communication between GEMFOREX. and any client or partner concerning financial services provided by GEMFOREX. is recorded, regardless of the meaning of content.

Deposits in a particular account must be transferred from an account opened by an authorized credit institution or a credit card held in the name of the particular owner or applicant to open an account with GEMFOREX. Documents verifying ownership of a card or account are also requested during the account opening process or later if necessary.

Withdrawals are normally processed to the same deposit account.

New copies of verification documents are always requested from clients prior to the expiration of the current ones. Clients are obligated to provide new copies of verification documents once they expire.

If suspicious activity, transaction, or high risk is identified, the client’s account and activity will be investigated and reported to the relevant authorities if deemed necessary.

This content will be updated from time to time.

December 1, 2021