Know Your Customer (KYC)

II. Objectives of the KYC Programme

The primary objectives of the KYC programme are:

1. Client Identification and Verification: To positively and unequivocally establish the legal identity of all clients, whether natural or legal persons.
2. Risk Profiling: To develop a comprehensive understanding of the client's source of wealth, source of funds, investment objectives, and professional background to assign a specific risk rating.
3. Legitimacy of Activity: To ensure that the client's intended trading activities in stocks, indices, currencies, and commodities are legitimate and consistent with their disclosed profile.
4. Ongoing Due Diligence: To implement continuous monitoring of client accounts and transactions for consistency with known patterns and to identify any unusual or suspicious activity.
5. Record-Keeping: To maintain accurate, current, and secure records of all identification data, verification documents, and transactional history as required by applicable law.

III. Mandatory Client Identification Procedures

Prospective clients must provide the following documentation and information to initiate the onboarding process:

For Individual Investors:

• Full legal name, date of birth, and residential address.
• A certified copy of a government-issued photographic identity document (e.g., valid international passport, national identity card).
• A recent certified copy of a utility bill, bank statement, or similar official document verifying the declared residential address.
• Documentation evidencing the client's Tax Identification Number (TIN) or equivalent from their country of fiscal residence.
• Declaration of beneficial ownership (if applicable).

For Corporate Entities, Trusts, or Institutional Investors:

• Certified copies of the Certificate of Incorporation/Registration and constitutional documents (Memorandum & Articles of Association, Trust Deed, etc.).
• Proof of the entity's registered address and principal place of business.
• Full details of all individuals holding a beneficial interest of 10% or more, or who exercise ultimate effective control over the entity, along with the required identification documents for each such beneficial owner.
• Identification and verification documents for all authorised directors, signatories, and account controllers.
• A certified copy of a recent corporate registry extract or certificate of good standing.
• Resolution authorising the opening of the account and conferring authority upon specified individuals to act on behalf of the entity.

IV. Enhanced Due Diligence (EDD)

Enhanced Due Diligence measures are mandatorily applied to clients classified as presenting a higher risk. This classification may arise from, but is not limited to, the following factors:

• Clients residing in or conducting business connected to jurisdictions identified by credible international bodies as having strategic AML/CFT deficiencies.
• Clients involved in sectors or activities deemed inherently higher risk (e.g., certain cash-intensive businesses, trading in high-value physical commodities).
• Clients whose source of wealth is complex, opaque, or derives from high-risk jurisdictions.
• Politically Exposed Persons (PEPs), their immediate family members, and close associates.

EDD involves obtaining additional independent information to corroborate the client's source of wealth and funds, securing senior management approval for the relationship, and conducting more intensive ongoing transaction monitoring.

V. Nature of Investment Activity and Financial Profile

Given the Company's specialisation in dynamic and sometimes volatile markets (stocks, indices, currencies, commodities), clients are required to provide a detailed financial profile. This includes:

• A clear statement of the client's investment objectives and risk tolerance.
• Disclosure of the anticipated origin of funds to be deposited (Source of Funds), such as salary, business revenue, inheritance, sale of assets, or investment returns.
• Documentation or a credible narrative evidencing the client's Source of Wealth (the activities that generated the total net worth).
• Information regarding the client's profession, employment, or business activities.

This information is critical for ensuring that the requested trading activities in leveraged instruments, foreign exchange, or commodity futures are appropriate and understood by the client.

VI. Ongoing Monitoring and Updates

KYC is not a one-time exercise. Simplified Financial Frontier employs automated surveillance systems and manual reviews to continuously monitor client transactions for patterns inconsistent with the client's profile, such as unexplained large deposits, rapid turnover of funds without clear financial purpose, or transactions with sanctioned entities.

Clients are obligated to inform the Company promptly of any material change in their circumstances, including changes in beneficial ownership, residential address, or financial situation. The Company reserves the right to periodically request updated documentation to ensure all KYC records remain current and valid.

VII. Client Consent and Data Protection

By engaging with the onboarding process, the client explicitly consents to the collection, processing, and secure retention of their personal data for the purposes of compliance with AML/CFT regulations, identity verification, and risk management.

Simplified Financial Frontier adheres to strict data protection principles, ensuring that all client information is handled confidentially and securely, in line with applicable data privacy legislation. Information will only be disclosed to third parties where required by law or regulatory obligation.

VIII. Non-Compliance

Failure to provide complete, accurate, and satisfactory documentation or information as requested by Simplified Financial Frontier will result in the inability to establish a business relationship.

Furthermore, the Company reserves the absolute right, at its discretion and without liability, to refuse onboarding, suspend trading activity, or terminate an existing relationship if it is unable to satisfactorily complete its KYC or ongoing due diligence obligations. In such cases, accounts may be blocked, and transactions halted, with any remaining funds returned only to a verified account in the client's name, subject to all legal restrictions.