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AML & CTF Policy

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Purpose

The purpose of this AML & CTF Policy is to ensure that FlipTrade Group and its employees comply with legal and regulatory obligations to prevent money laundering, terrorist financing, and financial crime. It promotes staff awareness and defines internal controls to detect and deter such activities.

Being used in connection with financial crime exposes a firm to reputational, legal, and regulatory risk. This Policy supports our Code of Conduct (integrity, transparency, compliance) and is approved by the Board. It is reviewed annually or as needed for effectiveness.

  • FlipTrade Group’s KYC & Due Diligence Procedures
  • Client Onboarding & Risk Assessment (incl. PEPs & Sanctions)
  • Compliance Monitoring Procedures
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    AML Requirements

    FlipTrade Group operates globally and maintains strict AML standards aligned with international laws. We implement effective measures to prevent, detect, and report any instances of money laundering.

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    What is Money Laundering?

    Money laundering is the process of disguising the origins of illegally obtained funds to make them appear legitimate. Financial institutions are often targeted, so employees must remain vigilant.

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    Stages of Money Laundering

    The three stages typically are:

  • Placement: Introducing illicit funds into the financial system (e.g., large cash deposits).
  • Layering: Moving funds through multiple transactions to obscure origin (e.g., transfers across accounts/jurisdictions/assets).
  • Integration: Reintroducing laundered funds as apparently legitimate assets.

    • FlipTrade Group is most exposed at the layering stage due to trading and fund transfer activities.

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    Suspicious Activity

    Employees must remain alert to suspicious behavior:

  • Deposits inconsistent with known trading activity or profile
  • Third-party payments or unexplained withdrawals
  • Unusual trading patterns or excessive wire transfers
  • Reluctance to provide identification or proof of funds
  • Activity from/to high-risk jurisdictions

    • All suspicious activities must be reported immediately to the Head of Compliance (AML/CTF Reporting Officer), who determines if escalation to authorities/regulators is required.

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    Account Opening & Due Diligence

  • Risk-based approach to customer verification (individual & corporate).
  • Identify & verify clients using reliable, independent documentation and sources.
  • Screen all clients against PEP and Sanctions lists; any positive matches are referred to Compliance before approval.
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    Training

  • Mandatory AML & financial-crime training during onboarding.
  • Regular refresher courses to maintain awareness and competence.
  • Ad-hoc/specialized training when new regulations or risks arise.
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    Record Keeping

  • Maintain accurate records for client identity, transactions, and compliance checks.
  • Retain client identification records for five years after the relationship ends.
  • Retain transaction records for five years from completion.
  • Training records are securely stored by Compliance.
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    Terrorist Financing

  • Terrorism involves actions intended to influence governments or intimidate the public to advance political, religious, or ideological causes.
  • ‘Terrorist property’ includes funds or assets likely to be used to fund terrorism; sources may be illicit or legitimate (donations/business revenue).
  • FlipTrade Group must monitor, detect, and report activity potentially linked to terrorist financing; suspicious findings are escalated to authorities.
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    Fraud – Intro & Prevention

  • Fraud is deliberate misrepresentation or concealment of material facts to obtain unlawful gain; risks include identity theft/impersonation.
  • Code of Conduct: employees must act with honesty and integrity.
  • Client Authentication: no instruction processed without proper verification.
  • Payment Controls: transactions verified against registered account details.
  • Awareness & Training: fraud prevention included in AML education.
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    Fraud – Detection & Reporting

  • Employees must immediately report suspected fraud to the AML/CTF Reporting Officer.
  • The Reporting Officer reviews and determines whether external reporting is necessary.
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    Anti-Bribery & Corruption

  • Bribery: offering/giving/receiving value to improperly influence actions. Corruption: misuse of entrusted power for personal gain.
  • Whistleblowing Policy enables confidential reporting.
  • Gifts & Hospitality: all gifts/entertainment from clients must be reported to Compliance.
  • Regular policy reviews by Compliance; mandatory anti-bribery training for all staff.
  • PEP & Sanctions screening is mandatory for all clients; no risk-based exemption.
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    Market Abuse – Intro & Examples

    Market abuse is behavior that manipulates markets or gives a false impression of supply, demand, or price. As FlipTrade Group offers CFDs and OTC instruments, it remains subject to market-abuse regulations.

    Examples include:

  • Insider trading or misuse of confidential information
  • Manipulative trading (e.g., false orders, spoofing)
  • Spreading false or misleading market information
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    Market Abuse – Indicators & Reporting

    Suspicious transaction indicators:

  • Unusual trading volumes before news releases
  • Sudden, inconsistent trades vs. historical activity
  • Urgent large trades without clear rationale
  • Instructions inconsistent with financial capability

    • Reporting:

  • All suspected market abuse must be reported immediately to the AML/CTF Reporting Officer or the Compliance Department.
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    Responsibilities

  • The Board of Directors oversees implementation of this Policy.
  • AML/CTF matters are reviewed quarterly; Annual Risk Assessment is approved by the Board.
  • The AML/CTF Reporting Officer prepares annual AML control reports, maintains the AML Risk Assessment, investigates internal SARs, and reports well-founded suspicions to authorities/FIU.
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    Ongoing Monitoring

  • Compliance conducts weekly reviews of newly opened accounts.
  • Daily monitoring of deposits above set thresholds.
  • Continuous transaction monitoring to identify anomalies.
  • No third-party deposits are accepted; deposits must match the verified client name.
  • FlipTrade may decline or block any transaction suspected of financial crime.
  • By law, we may be prohibited from informing clients if a report is made to authorities.
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    Declaration

  • All employees must sign that they have read, understood, and agree to comply with FlipTrade Group’s AML & CTF Policy and related procedures.
  • Signed declarations must be submitted to the Compliance Department for record keeping.

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    Head Quarter

    Giorgi Leonid Ze Street, Tbilisi 0105,
    Georgia Office 38.

    Registered Address

    Ground Floor, The Sotheby
    Building, Rodney Village, Rodney
    Bay, Saint Lucia

    Registration No.

    2025-00621

    Contact No.

    +41 2650 06818

    Email

    support@fliptradegroup.com

    Risk statement : An investment in derivatives and financial markets involves high risk and may result in losses greater than your initial investment. Trading in securities, forex, commodities, options, and futures is not suitable for everyone, and you should only invest money you can afford to lose. Before investing, ensure such activities are permitted in your country and seek independent financial, legal, or tax advice. FlipTrade Group Limited does not provide services to residents of the United States, Cuba, Iraq, Myanmar, North Korea, or Sudan, and its services are not intended for jurisdictions where they would contravene local laws or regulations. Nothing on this site should be considered financial advice.
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