Scope of policy

This policy applies to all EarnTM FX officers, employees, appointed producers and products and services offered by EarnTM FX. All business units and locations within EarnTM FX will cooperate to create a cohesive effort in the fight against money laundering. Each business unit and location has implemented risk-based procedures reasonably expected to prevent, detect and cause the reporting of transactions. All efforts exerted will be documented and retained. The AML Compliance Committee is responsible for initiating Suspicious Activity Reports ('SARs') or other required reporting to the appropriate law enforcement or regulatory agencies. Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Compliance Committee.

The committee shall:

Receive internal reports of (suspicions of) money laundering

Investigate reports of suspicious events

Make reports of relevant suspicious events to the relevant authorities

Ensure the adequacy of arrangements made for the awareness and training of staff and advisers

Report at least annually to the firm’s governing body on the operation and effectiveness of the firm’s systems and controls.

Monitor the day-to-day operation of anti-money laundering policies in relation to: the development of new products; the taking on of new customers; and changes in the firm’s business profile.

Policy

It is the policy of EarnTM FX to actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. EarnTM FX is committed to AML compliance in accordance with applicable law and requires its officers, employees and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.