Introduction

This Anti-Money Laundering (AML) Policy has been established to ensure that Hola Prime Limited (the firm) fully complies with all relevant laws and regulations regarding anti-money laundering, counter-terrorism financing, and sanctions. The policy details the firm’s commitment to combating financial crime and outlines proactive measures to prevent, detect, and report any suspicious activities related to money laundering or terrorist financing. It applies to all employees, traders, and associates, and compliance with this policy is mandatory to safeguard our firm’s reputation and meet international AML standards.

Scope 

This Policy applies to all individuals associated with the Company, including employees, directors, agency workers, volunteers, and interns (collectively “Covered Persons”), as well as agents, contractors, external consultants, and business partners. Given the fast-changing regulations in our industry, the Company has adopted a cautious approach. Therefore, some AML Policy procedures may exceed legal requirements. 

Policy Objective

The objective of this Anti-Money Laundering (AML) Policy is to create a comprehensive framework for preventing, detecting, and reporting money laundering and terrorist financing. Hola Prime Limited complies with all pertinent legal and regulatory standards, upholds its reputation, and maintains the highest level of financial integrity. 

Definitions Applicable To The Policy

Money laundering, also known as ML, refers to the act of concealing or disguising the illegal origins of funds obtained through criminal activities. This process usually involves three distinct:

Placement: It involves introducing illegal funds into the financial system, often by depositing cash into bank accounts

Layering: The process of layering involves separating the funds from their criminal origin through complex transactions to obscure their trail and appear legitimate.

Integration: It reintroduces the laundered funds into the legitimate economy through investments or purchases, making the illegal money appear legal. 

Assistance: It involves a person who assists the person who committed the felony/misdemeanour to escape punishment. 

Risk Assessment

The Company employs a risk-based approach to manage money laundering, terrorist financing, and sanctions violations risks related to transactions on the Platform, using available data to assess user activity. 

Specific Risks

Illicit funds may be used to pay evaluation fees, complicating tracking without thorough verification. Fraudsters might exploit fake or stolen identities to establish accounts and launder money. Unusual trading activities, such as high-frequency trades without financial justification, could indicate money laundering. Clients might use intermediaries or third-party payment services to obscure the source of funds.

Analysis

Risk assessments show that the main risks arise when the Platform is used outside its intended educational and trading purposes. While these activities generally pose minimal risk, deviations from standard use increase the likelihood of money laundering or sanctions evasion. Therefore, the AML Policy focuses on identifying and addressing misuse of the Platform that deviates from normal business practices.

Guidelines

The guidelines outline how this AML Policy addresses the aforementioned risks, and it is applicable to all Platform users.

Sources Of Information

The Company uses both internal and external sources to identify if individuals are subject to sanctions or restrictions that could impact their trading activities. These sources include, but are not limited to:

• OFAC Specially Designated Nationals (SDN) and Sectoral Sanctions Identification (SSI) lists
• EU Consolidated Sanctions List
• UK sanctions list
• UN sanctions list
• Politically Exposed Persons (PEP) list
• Special Interest Persons or Entities (SIP, SIE) list
• Media coverage

Customer Verification (KYC)

The firm is committed to executing detailed verification procedures for customers at the time of onboarding and conducting periodic assessments of current clients. This involves securing and confirming identification details, understanding the origins of the customer’s funds, and evaluating the associated risks of each client.

Enhanced Due Diligence (EDD)

For clients deemed high-risk, such as politically exposed persons (PEPs) or those from high-risk regions, the firm will implement more stringent due diligence measures to ensure thorough scrutiny.

The Company may request additional documentation  such as bank statements, pay slips, tax declarations, and legal documents. Electronic providers may be used for identity verification and sanctions list screening. Changes in transaction values will require approval from the CCO in consultation with external legal advisors.

Prohibited Users

• Users involved in extortion or ransomware activities will be listed on the Sanctions List.
• Users from IP addresses deemed non-trusted, located in FATF-black or gray-listed jurisdictions, or previously flagged as suspicious will be closely monitored.
• If a user refuses to provide KYC documents or answer questions about their source of funds, further investigation will be conducted.
• Users who submit KYC documents or use account credentials belonging to someone else will be banned from the Platform.

In all cases, users will be promptly banned, and the Chief Compliance Officer (CCO) will be notified to assess whether the incident should be reported to the authorities.

Payout

The Company enforces a strict policy against payments or withdrawals to third parties. Funded Users must withdraw trading profits to the same payment method used for transactions on the Platform. Attempts to use alternative accounts will be closely examined, and additional documentation may be required for review.

Vendor Due Diligence

We rely on various third-party services, including payment services and trading simulation providers. Each vendor is thoroughly assessed to ensure compliance with AML policies. The Chief Compliance Officer (CCO) will review and update internal AML regulations based on vendor evaluations.

Training

Every employee and relevant personnel engaged in financial services will be provided with ongoing AML training. This training will cover the critical nature of AML compliance, techniques for spotting unusual or suspicious activities, and the procedures for reporting these activities within the company. 

Reporting Violations

The Company encourages Covered Persons to report any complaints or concerns about the AML Policy to the Chief Compliance Officer (CCO) or their supervisor. Covered Persons should also report any known or suspected violations of laws, regulations, or Company policies. Reports can be submitted to contactus@holaprime.com.

Investigation of Violations

All reports will be thoroughly investigated, and appropriate actions, including disciplinary measures and potential notification of relevant authorities, will be taken based on the investigation’s outcome. Individuals should not conduct their own investigations.

Whistleblowing Practice

The Company strictly prohibits retaliation, harassment, or intimidation against anyone who makes a good faith report of suspected misconduct or wrongdoing. If you experience any such issues, please contact the CCO.

Procedure

The Company is dedicated to enforcing the prohibitions, restrictions, and procedures outlined in this AML Policy. Violations can lead to severe legal consequences, fines, and penalties. Employees who breach this policy may face disciplinary actions, including possible termination, at the Company’s discretion. Disciplinary measures may also be applied to:

1. Individuals who knowingly fail to report a violation or suspected violation.
2. Individuals who deliberately withhold critical information related to a violation.
3. Individuals who refuse to cooperate with an investigation into a violation.
4. Supervisors or managers who show a lack of leadership, oversight, or diligence regarding policy enforcement. 

No Rights Created

The AML Policy outlines the basic principles, policies, and procedures that regulate the use of the Platform. It does not aim to, nor does it establish any legal rights for any customer, supplier, vendor, competitor, investor, or any other non-covered Person or entity.

Amendments, Waivers and Public Disclosure

The Company has the authority to make changes or exceptions to this AML Policy as it sees fit. Any changes or exceptions may be made public if mandated by relevant laws, rules, and regulations.

Contact

Feel Free to reach out to us in case you have any queries by sending an email at contactus@holaprime.com.