AML & KYC Policy

Last Updated: March 28, 2026

1. Introduction and Commitment

Aramas GmbH, operating as MyAllies Trading, is committed to the highest standards of anti-money laundering (AML) compliance and counter-terrorist financing (CTF) prevention. We have implemented a comprehensive AML/CTF program designed to detect, prevent, and report money laundering, terrorist financing, and other financial crimes.

This policy summary describes the key elements of our AML/KYC program as they apply to our clients. The full internal AML/CTF policy, risk assessment methodology, and procedures are maintained by our Compliance Department and are not published for security reasons.

We take a zero-tolerance approach to money laundering and terrorist financing. Any client found to be engaging in or attempting to engage in these activities will have their account immediately frozen, and the matter will be reported to the relevant authorities.

2. Legal and Regulatory Framework

Our AML/KYC program is designed to comply with the following regulatory frameworks:

• Swiss Anti-Money Laundering Act (AMLA/GwG): The primary Swiss legislation governing the prevention of money laundering and terrorist financing
• Swiss Anti-Money Laundering Ordinance (AMLO/GwV): Implementing provisions for the AMLA
• FINMA Anti-Money Laundering Ordinance (AMLO-FINMA): Specific requirements for financial institutions supervised by FINMA
• Swiss Criminal Code (StGB): Provisions related to money laundering (Art. 305bis) and terrorist financing (Art. 260quinquies)
• FATF Recommendations: International standards on combating money laundering and terrorist financing issued by the Financial Action Task Force
• EU Anti-Money Laundering Directives: Where applicable to our operations and client base
• US Bank Secrecy Act (BSA) and PATRIOT Act: As applicable through our US-based execution and clearing partners

3. Customer Due Diligence (KYC)

We conduct Customer Due Diligence (CDD) on all prospective and existing clients. The KYC process is a mandatory step before account activation and access to live trading services.

3.1 Individual Accounts

For individual account applicants, we collect and verify:

• Full legal name, date of birth, and nationality
• Current residential address (verified through utility bill, bank statement, or official correspondence dated within the last three months)
• Valid government-issued photo identification (passport, national ID card, or driver's license)
• Tax identification number(s) and tax residency declaration
• Source of funds and source of wealth information
• Employment status, occupation, and employer details
• Expected account activity, including anticipated trading volume and investment objectives

3.2 Corporate Accounts

For corporate or institutional account applicants, we additionally collect and verify:

• Certificate of incorporation or equivalent formation documents
• Articles of association or equivalent governing documents
• Register of directors and officers
• Beneficial ownership information for all individuals owning or controlling 25% or more of the entity
• Authorized signatory documentation and board resolution authorizing account opening
• Proof of the entity's registered and operating addresses
• Financial statements or proof of the entity's economic activity
• Source of funds declaration for the entity

3.3 Verification Methods

Identity verification is conducted using a combination of document-based verification and, where appropriate, electronic verification methods. We use automated and manual verification procedures, including:

• Document authentication technology to detect fraudulent or tampered identification documents
• Biometric verification (facial matching) comparing a live selfie to the photo on the identification document
• Address verification through independent data sources
• Cross-referencing against government databases and public records where available

4. Enhanced Due Diligence

We apply Enhanced Due Diligence (EDD) measures in situations that present a higher risk of money laundering or terrorist financing. EDD triggers include:

• Politically Exposed Persons (PEPs): Individuals who hold or have held prominent public positions, their family members, and known close associates. PEP screening is conducted at onboarding and on an ongoing basis
• High-Risk Jurisdictions: Clients residing in or conducting business in countries identified as having elevated AML/CTF risks, including those on FATF grey or black lists
• Complex Ownership Structures: Corporate clients with complex, opaque, or multi-layered ownership structures that make it difficult to identify beneficial owners
• Unusual Transaction Patterns: Accounts exhibiting transaction patterns inconsistent with the client's stated profile, business activity, or expected trading behavior
• Large or Unusual Deposits: Significant deposits or fund transfers that are unusual for the client's profile, particularly when the source of funds is unclear
• Adverse Media: Clients or their associates who are the subject of adverse media reports related to financial crime, corruption, or sanctions violations

EDD measures may include requesting additional documentation, conducting enhanced source of wealth and source of funds reviews, obtaining senior management approval for the business relationship, and increasing the frequency of ongoing monitoring.

5. Ongoing Monitoring

We conduct ongoing monitoring of all client relationships and transactions throughout the duration of the business relationship. Our monitoring program includes:

• Transaction Monitoring: Automated systems that analyze transaction patterns, amounts, frequency, and other parameters to detect potentially suspicious activity
• Profile Updates: Periodic reviews of client information to ensure it remains accurate and current. We may request updated documentation or information at any time
• Risk Reassessment: Regular reassessment of client risk ratings based on account activity, changes in client circumstances, and updates to risk factors
• Sanctions Screening: Continuous screening against updated sanctions lists (see Section 6)
• Behavioral Analysis: Monitoring for account activity that deviates from the client's established pattern or stated purpose

6. Sanctions Screening

We screen all clients, counterparties, and transactions against applicable sanctions lists, including:

• Swiss State Secretariat for Economic Affairs (SECO) sanctions lists
• European Union Consolidated Sanctions List
• United Nations Security Council Sanctions Lists
• US Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) List and other OFAC lists
• UK Office of Financial Sanctions Implementation (OFSI) Consolidated List

Sanctions screening is performed at account opening, on an ongoing basis as lists are updated, and before processing transactions. We will not open accounts for, maintain accounts of, or process transactions for individuals or entities subject to applicable sanctions.

7. Suspicious Activity Reporting

We file Suspicious Activity Reports (SARs) with the Money Laundering Reporting Office Switzerland (MROS) and other relevant Financial Intelligence Units (FIUs) as required by law. We are legally prohibited from disclosing to the client or any third party that a SAR has been filed or that an account is under investigation ("tipping off" prohibition).

If we identify suspicious activity or have reasonable grounds to suspect money laundering or terrorist financing, we may take the following actions without prior notice:

• Freeze the account and any pending transactions
• Restrict account functionality, including deposits, withdrawals, and trading
• File a SAR with the relevant authorities
• Retain relevant funds pending the outcome of any investigation
• Close the account and terminate the business relationship

8. Record Keeping

We maintain comprehensive records of all AML/KYC activities in accordance with regulatory requirements:

• Client identification and verification records are retained for at least ten (10) years after the termination of the business relationship
• Transaction records and supporting documentation are retained for at least ten (10) years from the date of the transaction
• Suspicious activity reports and related investigation records are retained for the period required by law
• Training records and compliance monitoring reports are retained for a minimum of five (5) years

9. Employee Training and Awareness

All employees receive AML/CTF training as part of their onboarding process and on an ongoing basis. Training covers:

• Applicable AML/CTF laws and regulations
• Our internal AML/KYC policies and procedures
• Recognition of suspicious activity indicators (red flags)
• Obligations and procedures for internal reporting of suspicious activity
• Sanctions compliance requirements
• Consequences of non-compliance for individuals and the organization

Enhanced training is provided to employees in compliance, customer-facing, and risk management roles. Training effectiveness is assessed through testing, and records are maintained by our Compliance Department.

10. Compliance Organization

Our AML/CTF compliance program is overseen by the following:

• Money Laundering Reporting Officer (MLRO): A designated senior officer responsible for receiving and assessing internal suspicious activity reports, filing SARs with MROS, and overseeing the AML/CTF program
• Compliance Department: Responsible for the day-to-day operation of the AML/KYC program, including client due diligence, ongoing monitoring, and policy development
• Senior Management: Provides oversight and governance of the AML/CTF program and allocates adequate resources for compliance
• Independent Audit: Our AML/CTF program is subject to independent review and testing at least annually

11. Your Obligations

As a client of MyAllies Trading, you are required to:

• Provide accurate, complete, and current identification and verification information
• Promptly update your information if your personal details, financial circumstances, or contact information change
• Respond promptly to any requests for additional information or documentation related to your account
• Not use your account for money laundering, terrorist financing, sanctions evasion, or any other illegal purpose
• Not allow any other person to use your account or trade on your behalf without prior authorization
• Cooperate with our compliance team in any review or investigation relating to your account

Failure to comply with these obligations may result in restrictions on your account, suspension of trading privileges, or termination of the business relationship.

12. Contact

If you have questions about our AML/KYC requirements or need assistance with the verification process, please contact our compliance team:

Aramas GmbH
Compliance Department
Zurich, Switzerland
Email: compliance@myallies.com

To report suspected financial crime or suspicious activity, please contact us at compliance@myallies.com. All reports are treated confidentially.