This Anti-Money Laundering and Know-Your-Customer Policy (the “Policy”) sets out the principles, standards, and procedures adopted by Kohle Capital Markets Limited (the “Company”, “we”, “us”, or “our”) in connection with the provision of services under the KCM Trade platform (the “Services”).
This Policy forms part of the Company’s overall compliance framework and is intended to ensure compliance with applicable anti-money laundering (“AML”), counter-terrorism financing (“CTF”), and financial crime prevention laws, regulations, regulatory guidance, and platform governance requirements, including those applicable to mobile application distribution platforms.
1. Purpose and Objectives
The objectives of this Policy are to:
- Prevent the use of the Services for money laundering, terrorism financing, fraud, or other financial crimes
- Establish robust client identification and verification procedures
- Apply a risk-based approach to customer due diligence
- Monitor transactions and user activity on an ongoing basis
- Ensure compliance with applicable regulatory and legal obligations
2. Scope and Application
This Policy applies to:
- All users who register for, access, or use the Services
- All accounts, transactions, deposits, withdrawals, and trading activity
- All products and services made available through the KCM Trade platform
Compliance with this Policy is a condition of access to and continued use of the Services.
3. Risk-Based Approach
The Company applies a risk-based approach to AML and KYC compliance, whereby the nature, extent, and frequency of due diligence measures are determined based on an assessment of relevant risk factors, including but not limited to:
- Customer profile and behaviour
- Geographic location and jurisdictional risk
- Nature and volume of transactions
- Product and service risk
4. Client Identification and Verification (KYC)
4.1 Mandatory Verification
Users may be required to complete identity verification procedures prior to accessing certain features of the Services, including account activation, deposits, withdrawals, and trading.
4.2 Information Collected
For identification and verification purposes, the Company may collect, verify, and process information including, but not limited to:
- Full legal name
- Date of birth
- Nationality and country of residence
- Residential address
- Government-issued identification documents
- Proof of address documentation
- Source of funds and/or source of wealth information
The Company reserves the right to request additional information or documentation at any time.
5. Verification Methods
Identity verification may be conducted using one or more of the following methods:
- Manual document review
- Automated verification technologies
- Third-party identity verification and compliance service providers
The Company currently utilises ShuftiPro (shuftipro.com) as its primary identity verification and KYC service provider. ShuftiPro performs document verification, biometric identity checks, liveness detection, and sanctions/PEP screening on behalf of the Company. Data processed through ShuftiPro is handled in accordance with ShuftiPro’s data processing agreements and the Company’s Privacy Policy.
Verification methods may evolve in line with technological developments and regulatory expectations.
6. Ongoing Monitoring
The Company conducts ongoing monitoring of customer activity to:
- Detect unusual, suspicious, or potentially unlawful transactions
- Ensure consistency between customer activity and the declared profile
- Identify changes in risk level
Monitoring may include transaction analysis, behavioural monitoring, and periodic re-verification.
7. Enhanced Due Diligence (EDD)
Enhanced Due Diligence measures may be applied in higher-risk situations, including but not limited to:
- Politically Exposed Persons (PEPs)
- Customers from high-risk or sanctioned jurisdictions
- Complex, unusual, or large transactions
- Other circumstances identified through risk assessment
EDD may involve additional documentation, approvals, and enhanced monitoring procedures.
7.1 FATF-Designated Jurisdictions
The Company applies heightened scrutiny and EDD to customers, transactions, and counterparties connected to jurisdictions designated by the Financial Action Task Force (FATF). The Company’s jurisdiction-risk classifications are reviewed and updated on an ongoing basis in line with FATF plenary outcomes.
High-Risk Jurisdictions Subject to a Call for Action (FATF Blacklist)
As of 13 February 2026, the FATF identifies the following jurisdictions as having significant strategic deficiencies in their AML/CFT/CPF regimes and calls on all jurisdictions to apply counter-measures or enhanced due diligence:
- Democratic People’s Republic of Korea (North Korea)
- Iran
- Myanmar
The Company applies its most restrictive controls to accounts and transactions connected with these jurisdictions, consistent with the Sanctions Policy.
Jurisdictions Under Increased Monitoring (FATF Grey List)
As of 13 February 2026, the FATF identifies the following 22 jurisdictions as being subject to increased monitoring due to identified AML/CFT/CPF deficiencies:
Algeria, Angola, Bolivia, British Virgin Islands, Bulgaria, Cameroon, Côte d’Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Kuwait, Laos, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, Senegal, South Sudan, Venezuela, Vietnam, Yemen
Syria is not treated as a monitoring-only jurisdiction: the provision of Services to persons resident or incorporated in Syria is prohibited under the Sanctions Policy.
Customers connected with these jurisdictions are subject to Enhanced Due Diligence, including additional documentation requirements, enhanced source of funds and wealth verification, and heightened transaction monitoring.
8. Account Restrictions, Suspension, and Termination
The Company reserves the right, at its sole discretion and without limitation, to:
- Restrict or suspend access to the Services
- Delay, refuse, or reverse transactions
- Freeze accounts or funds
- Terminate the business relationship
Such actions may be taken where:
- Required verification has not been completed
- Information provided is inaccurate, incomplete, or misleading
- Suspicious or unlawful activity is detected
- Required by applicable laws, regulations, or regulatory authorities
9. Reporting of Suspicious Activity
Where required or permitted by applicable law, the Company may report suspicious activities to the relevant authorities.
Such reporting may occur without prior notice to the user, where disclosure is restricted or prohibited by law.
10. Data Protection and Record Retention
Personal data collected for AML and KYC purposes is processed in accordance with the Company’s Privacy Policy and applicable data protection laws.
Records relating to customer identification, verification, and transactions are retained for such periods as required by applicable legal and regulatory obligations.
11. Regulatory Compliance
The Company is committed to maintaining compliance with applicable AML, CTF, and financial crime prevention regulations, including but not limited to:
- The Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA) of the Republic of Mauritius and the Financial Intelligence and Anti-Money Laundering Regulations 2018 made thereunder
- AML/CFT Guidelines issued by the Financial Services Commission of Mauritius (FSC Mauritius) applicable to Investment Dealers licensed under the Securities Act 2005
- The United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Act 2019 and other applicable sanctions legislation of the Republic of Mauritius
- Applicable United Nations Security Council resolutions, OFAC, EU, and equivalent international sanctions regimes
- Such other applicable laws, regulations, and regulatory guidance as may be in force from time to time in the jurisdictions in which the Company operates or offers Services
Full details of the Company’s sanctions compliance framework — including the specific sanctions regimes monitored, screening procedures, and prohibited relationships — are set out in the Sanctions Policy.
Where required or permitted by applicable law, including FIAMLA, the Company may report suspicious transactions or activities to the Financial Intelligence Unit (FIU) of Mauritius and other competent authorities. Such reporting may occur without prior notice to the user where disclosure is restricted or prohibited by law.
This Policy does not create any additional rights in favour of users and does not limit the Company’s ability to take any action required to comply with legal or regulatory obligations.
12. Amendments
The Company may amend this Policy from time to time to reflect changes in laws, regulations, regulatory guidance, platform requirements, or internal practices.
Any amendments will be effective upon publication, as indicated by the updated Last Updated date.
13. Contact Information
For enquiries relating to this Policy or compliance matters, please contact:
Kohle Capital Markets Limited
Email: CS@kcmtrade.com
Website: https://www.kcmtrade.com
By accessing or using the Services, you acknowledge that you have read, understood, and agreed to this Anti-Money Laundering and Know-Your-Customer Policy.