BIS Markets Ltd is committed to the highest standards of anti-money laundering compliance and counter-terrorist financing. This policy outlines our procedures for identifying, verifying, and monitoring all clients.
BIS Markets Ltd · January 2026 · Reg. No. 2025-00929
Contents
BIS Markets Ltd (the "Company") is incorporated in Saint Lucia in accordance with the International Business Company's Act Cap 12.14 (IBC Act) with the organizational and legal form of a limited liability company as an international business company (hereinafter referred to as "IBC"), with registration number 2025-00929 and having its registered address at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia. The Company operates under the fully owned domain BIS Markets Ltd. The Business activities of the Company are in particular but not exclusively, commercial, financial, lending, borrowing, trade, services activities, Forex brokerage, and managed accounts services in currency Contract for Difference agreements, namely precious metals, Contract for Difference agreements, index Contract for Difference agreements, and any other contract for difference agreements entered into, but does not include (a) shares and stock in the share capital of the company; (b) any instrument creating or acknowledging indebtedness, in particular, debentures, debenture stock, loan stock, bonds and notes; and (c) bonds and other instruments creating or acknowledging indebtedness issued by or on behalf of any participating Government and excluding any security as defined by The Securities Act CAP 12.18 of the revised laws of Saint Lucia or any 'securities' as defined by The Securities Act CAP 12.18 of the revised Laws of Saint Lucia, do not require a particular license and can be carried out by the Company in accordance with its Articles of Association and Memorandum (Articles of Association). The Company shall not carry out on any named financial service in or from any jurisdiction in which a license for that named financial service is required. The Company aims to prohibit, detect and actively pursue the prevention of money laundering, terrorism financing, and all other predicate offences and vows to comply with all related laws, rules, and regulations with full attention and no compromises with any of the abovementioned illegal activities. The Company recognizes the critical importance of Anti-Money Laundering ("AML") and Counter-Terrorism Financing ("CTF") and is dedicated to implementing and adhering to the highest international AML and CTF standards, while fully complying with the laws of Saint Lucia.
This AML Policy aims to provide clear guidance and transparency regarding the procedures and protocols followed by the Company to detect and prevent Money Laundering (ML) and Terrorism Financing (TF) activities, in full compliance with the applicable laws of Saint Lucia. This AML policy applies to all Company officers, employees, introducing brokers, affiliated entities, as well as the products and services offered. All company's employees are required to perform their duties in accordance with the principles outlined in this Policy. The Company is committed to taking all necessary steps to ensure compliance with its obligations, and any employee who fails to adhere to these policies and procedures will be subject to strict disciplinary actions.
The Company is required to adhere with the provisions of the applicable laws relating to the prevention of ML and TF. The main objective of those laws is to define and criminalize the activities related to ML and TF. Legal entities carrying on financial and other business activities must establish and maintain certain policies and procedures to safeguard their business from being used for the purposes of ML. For the purposes of this AML policy the applicable Legal Framework of the Company is comprised inter alia of the following:
Money laundering includes all procedures to conceal the origins of criminal proceeds so that they appear to originate from a legitimate source. For this Policy, ML is also taken to encompass activities related to TF, including handling, or possessing funds to be used for terrorist purposes as well as proceeds from terrorism. The Company is alert of the risk of its clients, counterparties and others laundering money in any of its possible forms. The Company or its client does not have to be a party to money laundering for a reporting obligation to arise. There are three stages of money laundering:
Placement
The physical disposal of cash proceeds. In the case of many serious crimes the proceeds take the form of cash which the criminal wishes to place in the legitimate business system. This may include placing cash on deposit at a bank, physically moving cash between jurisdictions, making loans in cash to businesses, purchasing high value goods for personal use, or placing cash in the client account of a professional intermediary.
Layering
The separating of the proceeds of crime from their source by creating sometimes complex layers of transactions designed to mask their origin and hamper the investigation, reconstruction and tracing of the proceeds — for example, by international wire transfers using nominees or 'shell companies', by moving in and out of investment schemes or by repaying credit from the direct or indirect proceeds of crime.
Integration
The placing of the laundered proceeds back into the economy as apparently legitimate business funds — for example, by realizing property or legitimate business assets, redeeming shares or units in collective investment schemes acquired with criminal proceeds, switching between forms of investment, or by surrendering paid up insurance policies.
A money laundering offence is committed by:
Tipping Off
It is an offence for anyone who knows, suspects or has reasonable grounds to suspect that a disclosure has been made, or that the authorities are acting or are proposing to act in connection with an investigation into money laundering, to prejudice an investigation by so informing the person who is the subject of a suspicion, or any third party of the disclosure, action or proposed action.
Prejudicing the Investigation
It is an offence to cause or permit to be falsified or conceal or destroy or otherwise dispose of information which is likely to be material to an investigation into money laundering.
Failure to Disclose
It is an offence if a person fails to report a suspicious transaction relating to money laundering within seven days from the date the transaction was deemed to be suspicious.
Terrorist financing is the raising and processing of legal or illegal funds by any means, directly or indirectly, with the intention to use such funds or knowing that they will be used in whole or in part to support the activities of a terrorist or a terrorist group by any means. A terrorist, or terrorist group, is one that has the purpose to facilitate or carry out any terrorist action or activity. The intent and knowledge are enough to prove the offence of TF. TF offences should extend to any person who wilfully provides or collects funds or other assets by any means, directly or indirectly, with the unlawful intention that they should be used, or in the knowledge that they are to be used, in full or in part: to carry out a terrorist act(s); or by a terrorist organisation or by an individual terrorist (even in the absence of a link to a specific terrorist act or acts). TF offences should include financing the travel of individuals who travel to a State other than their States of residence or nationality for the purpose of the perpetration, planning, or preparation of, or participation in, terrorist acts or the providing or receiving of terrorist training. It is also a TF offence to:
The Company's adopted legal provisions implement procedures and processes designed to ensure compliance with the relevant laws concerning ML and TF. These procedures are aligned with the guidelines and measures set forth by the competent authorities in Saint Lucia. The Company maintains transaction records for a period of seven years from the date the transaction was conducted. Additionally, the Company keeps a record detailing the nature of the evidence used to identify or verify an individual's identity.
The Company is committed to ensuring that it is dealing with a legitimate individual and, as such, will obtain sufficient evidence to verify the person's identity. The Company will take all reasonable measures to confirm the identity of any individual wishing to open an account, establish a business relationship, or engage in a significant one-off transaction or a series of connected transactions. The identity of a prospective client should be established prior to the establishment of a business relationship with the Company and prior to the execution of any transaction or the provision of any service whatsoever. If the Company is unable to identify and verify a client, it will not proceed with any transactions through a bank account, establish a business relationship, or complete the transaction. Depending on the circumstances, the Company may terminate the business relationship and consider submitting a suspicious transaction report to the relevant competent authority regarding the client. The documents and information required to be collected before the establishment of a new business relationship shall include the purpose and the reasons for requesting this business relationship, the company account transactions, the origin of the incoming funds and the destinations of the outgoing funds, the clients' wealth and the estimated annual income and a detailed description of the Company's business activities. In order to have a complete economic profile the Company also obtains basic information such as the company name, country of incorporation, and head office address, personal information relating to the Company's Beneficial Owners, Company Directors and Company Shareholders. The Company strictly prohibits any client, whether retail, professional, eligible, or institutional, from engaging in a business relationship that involves the use of anonymous accounts or passbooks.
The risk assessment process within the AML framework is designed to identify, assess, and mitigate risks related to ML and TF. This process enables the Company to implement appropriate controls and ensure compliance with AML regulations. The AML risk assessment process involves the following steps:
Identify Risks
Assess and Categorize Risks
Evaluate Controls
Mitigate Risks
Monitor and Review
Document and Report
Risk Assessment Tools
This process is crucial as it ensures the Company proactively manages money laundering risks, upholds regulatory compliance, and protects its reputation.
The Know Your Customer (KYC) process is a vital component of the Anti-Money Laundering (AML) framework, involving procedures that financial institutions and registered entities follow to verify the identity of their customers. The primary goal is to prevent identity theft, financial fraud, money laundering, and terrorist financing. During the KYC process, the Company identifies potential clients and evaluates the associated risks based on the client's economic profile and risk categorization. The Customer Identification procedure is essential for gathering key information about the customer (such as name, address, date of birth, and contact details) and verifying their identity using valid documentation, such as government-issued identification.
For Individuals — Proof of Identity:
For Individuals — Proof of Address:
For Individuals — Additional Documentation (Enhanced Due Diligence):
For Businesses (Corporate KYC):
The Company must maintain records of KYC documentation for 5 years from the end of the relationship or occasional transaction.
A 'Beneficial Owner' means any natural person(s) who ultimately owns or controls the customer and/or the natural person(s) on whose behalf a transaction or activity is being conducted. The Company takes appropriate measures to verify the identity of the beneficial owner, ensuring it is confident in knowing who the beneficial owner is. For legal entities and arrangements, this includes financial institutions taking reasonable steps to understand the ownership and control structure of the customer.
Customer Due Diligence (CDD) is the process of verifying the identity of the client. To confirm a client's identity, independent and reliable information is required. The Company gathers information regarding the purpose and intended nature of the business relationship and performs ongoing due diligence to ensure that the transactions conducted align with the Company's understanding of the customer, their business, and risk profile. This includes, when necessary, verifying the source of funds. The Company determines the extent of the CDD measures on a risk-based approach considering the type of customer, the nature of the business relationship, and the transaction involved. Customer Due Diligence must be applied when there is doubt about veracity or adequacy of previously obtained customer identification data, or when identifying and verifying the identity of customers in the following circumstances:
The Company may apply Simplified Due Diligence (SDD) when a client is assessed to present a low level of risk. In such cases, the Company implements less stringent identification and verification measures compared to standard or enhanced due diligence. However, SDD does not exempt the client from the fundamental CDD requirements. The Company ensures adequate monitoring of transactions and business relationships to detect any unusual or suspicious activities.
When the Company is dealing with natural persons or legal entities identified as high risk for ML or TF and classified as high risk based on the client's economic profile and the risk assessment conducted, the Company applies enhanced due diligence. EDD is applied for clients with higher risks and includes:
High-Risk Client Categories
The Company shall always apply enhanced client identification and due diligence procedures for: Cross-frontier correspondent clients; Non-face-to-face clients; Accounts in names of companies whose shares are in bearer form; Trust accounts; Client accounts in the name of a third person; Politically Exposed Persons accounts; Clients from countries which inadequately apply FATF's recommendations.
Additional Customer Risk Factors
Additional customer risk factors include: Business relationships conducted in unusual circumstances; Clients resident in geographical areas of higher risk; Legal persons or arrangements that are personal asset-holding vehicles; Companies that have nominee shareholders or shares in bearer form; Businesses that are cash incentive; Ownership structure of a legal entity appears unusual or excessively complex given the nature of the company's business.
Product, Service, Transaction or Delivery Channel Risk Factors
Private banking; Products or transactions that might favour anonymity; Non-face-to-face business relationships or transactions without certain safeguards such as electronic signatures; Payment received from unknown or un-associated third parties; New products and new business practices including new delivery mechanisms and the use of new or developing technologies for both new and pre-existing products.
The Company maintains comprehensive records of all due diligence measures undertaken, including risk assessments and the rationale for the risk category assigned to each client.
The screening process involves checking clients against various risk-related lists and databases to identify potential risks. The Company screens all clients against national and international sanctions lists and employs automated systems to ensure regular screening against updated sanctions. Additionally, the Company conducts reviews and rescreens existing clients in accordance with new watchlist updates, as per current regulations. The Company's AML procedures include screening of all clients (both prospective and existing), beneficial owners, authorized signatories, and relevant counterparties against the following sanctions lists:
Sanctions Screening Timing
Sanctions screening is conducted: at onboarding, prior to establishing any business relationship; on an ongoing basis throughout the client relationship; upon updates to relevant sanctions lists; and when triggering events occur (e.g., changes in ownership, unusual activity, or risk profile changes).
Match Handling
Where a true match is confirmed, the Company will: immediately freeze or reject the transaction or business relationship, as applicable; report the matter to the relevant competent authorities in accordance with applicable laws and regulations; and maintain appropriate records of the screening results and actions taken. The Company ensures that its sanctions screening procedures are regularly reviewed and updated to remain aligned with evolving regulatory requirements and international best practices.
The Company documents and has in place specific policies and procedures to identify and manage Politically Exposed Persons (PEPs). It ensures that transactions involving PEPs are authorized by senior management, determines the source of funds and source of wealth for PEPs, and conducts ongoing EDD on all accounts held by PEPs. The Company employs automated systems to regularly screen clients against updated sanctions and PEP lists. It periodically reviews and updates its screening criteria to maintain compliance with the latest regulations. Additionally, the Company conducts ongoing reviews and rescreens existing clients in accordance with updates to the watchlist, ensuring alignment with current regulatory requirements.
The Company monitors clients' activities based on their economic profiles, enabling employees to identify transactions that deviate from typical account behavior or appear complex, unusual, or lacking a clear economic purpose or legitimate explanation. Continuous monitoring of clients' accounts and transactions is a crucial component in effectively managing the risks of money laundering (ML) and terrorist financing (TF). The Compliance/AML Officer is responsible for maintaining and enhancing the Company's ongoing monitoring process. The Internal Auditor will review the Company's procedures related to this monitoring process at least once a year. The monitoring process is based on risk assessment categories and the estimated transaction volume for each client. Employees conduct reviews of client transactions at least once a week, or as requested by the Company's Compliance/AML Officer, and report their findings to the Compliance/AML Officer. Additionally, responsible employees provide daily records of clients' incoming and outgoing money transfers to the Compliance/AML Officer. The monitoring framework includes:
The Company has implemented and maintains internal reporting procedures to ensure that all employees know who to contact if they suspect that someone within the organization or a customer is involved in illegal activities, including money laundering (ML). This system ensures that the organization handles such concerns in a structured and organized manner, in compliance with relevant anti-money laundering (AML) and counter-terrorism financing (CFT) regulations.
The Company has established a clear protocol for employees to report any suspicious activities directly to the designated AML Compliance Officer. Additionally, it fosters an environment where employees are encouraged to raise concerns without fear of retaliation. The Company will report any suspicious transaction or business activity when there is a reasonable suspicion that it involves the proceeds of money laundering (ML) or terrorist financing (TF), regardless of the transaction amount. The external reporting process involves filing a Suspicious Activity Report (SAR) with the relevant authorities, as required by law. The Company ensures that reports are submitted promptly and accurately, including a clear documentation of the reasons for suspicion. Furthermore, the Company will terminate an account when its purpose or background is unclear, complying with the instructions of the competent authorities and facilitating any necessary inspections of transaction records.
When a person enters into a transaction with the Company or engages in any other business activity exceeding $25,000.00 must fill out a source of fund declaration in the prescribed form. It will be considered an offence if a person knowingly makes a false declaration regarding the source of funds.
The Company takes necessary steps to ensure that its employees are well-informed about the relevant anti-money laundering (AML) and counter-financing of terrorism (CFT) laws in Saint Lucia, as well as the internal policies and procedures established by the Company. To achieve this, the Company provides regular training for all employees on AML/CFT protocols, including Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures. This training helps employees understand the importance of their role in identifying and reporting suspicious transactions and activities. Furthermore, the Company offers continuous education through refresher courses and newsletters, keeping employees informed about regulatory updates and emerging risks in the brokerage industry.
The Company conducts regular internal audits of its AML/CFT procedures to evaluate the effectiveness of the measures in place. Based on audit findings, regulatory updates, and the evolving risk landscape, the Company reviews and revises its policies and procedures as needed. Additionally, the Company ensures that senior management is actively involved in overseeing AML/CFT compliance efforts, including the allocation of resources for training and ongoing monitoring.
The Company reserves the right to refuse to process a transfer of funds at any stage if it believes it to be connected in any way to criminal activities or money laundering. Third party or anonymous payments shall not be accepted. If the Company is not satisfied of who the sender of the money is, it reserves the right to reject the money and return it to the remitter less any transfer fees or other charges; the Company further reserves the right to terminate any account held with it with immediate effect. It may require the submission of additional documentation as required under applicable AML obligations or any similar applicable regulations. The Company is prohibited from accepting any client business if the funds are sourced from criminal activities or if the nature of the account transactions is illegal in any manner whatsoever. The Company is required to report all suspicious transactions and is prohibited from notifying the client that their transactions or account activity have been suspected or reported as suspicious. Account misuse may result in criminal prosecution. The Company may terminate its business relationship with the client either with, or without notice, for a series of severe reasons, deriving from Regulatory Obligations, including taking measures against ML and extending (but not limited to) breach of the client agreement and terms and conditions, bad faith, attempt to commit fraud, etc.
Any personal information collected from a client, such as name, address, date of birth, and contact details, will be kept confidential by BIS Markets Ltd and used solely for business purposes. Additional information, including client transactions, passport copies, and proof of address, will also be treated confidentially and shared exclusively between our account services and compliance departments. This information will be securely maintained, either physically or electronically, with strict access controls. The Company may share client information with internal departments or affiliated offices that handle marketing, back-office, and customer service functions as part of regular business operations. All employees of BIS Markets Ltd have signed a Confidentiality Agreement, ensuring that client information is maintained with the utmost confidentiality. The Company is dedicated to continuously improving this policy. It will be reviewed and updated regularly, at a minimum every six months, to ensure its effectiveness. The Company has the authority to review or modify its Anti-Money Laundering Policy at its discretion, whenever it considers necessary or suitable, without prior notification to the client. For further questions regarding this Anti-Money Laundering Policy, please contact us at bismarketofficial@gmail.com.