1.      Introduction and Purpose   
        
 i. This Anti-Money Laundering &Counter-Terrorist Financing Policy (“Policy”) sets out the standards, procedures, and obligations adopted by Amari Markets Ltd. (the “Company”, “Amari Markets”, “we”, “us”, or “our”) to prevent its services from being used for money laundering, terrorist financing, or other unlawful purposes.
           
ii. This Policy applies to all Clients(“Client”, “you”, “your”), transactions, deposits, withdrawals, and related activities conducted on the Company’s trading platform (the “Platform”).     
   
iii. The Company is committed to strict compliance with the laws of Saint Lucia, international standards established by the Financial Action Task Force (FATF), and global industry best practices. By opening an account and using the Platform, the Client confirms their acceptance of this Policy as an integral part of the Client Agreement.

2.     Regulatory Framework   
        
The Company operates under the AML/CTF framework of Saint Lucia. While it is not licensed by, or subject to, foreign regulators, the Company may adopt internationally recognized practices for risk management purposes. The Client acknowledges that AML/CTF requirements applicable to them in their jurisdiction remain their sole responsibility, and the Company shall not be liable for any breach of such obligations.

3.     Client Due Diligence(CDD)
        
3.1   Standard Verification
The Company shall collect, verify, and maintain accurate Client information before account activation, including:
a)     full name, date of birth, and nationality;
b)    valid government-issued photo identification;
c)     proof of residence (utility bill, bank statement, or similar document);
d)   source of funds and source of wealth declarations.

3.2    Enhanced Due Diligence (EDD)
The Company shall apply enhanced due diligence measures to Clients deemed high-risk, including:
a)     politically exposed persons (PEPs);
b)    Clients from high-risk or sanctioned jurisdictions;
c)     Clients engaged in high-value or unusually complex transactions.
d)    EDD may include requiring additional documents, conducting background checks, or imposing stricter monitoring conditions.

3.3   Ongoing Obligation
The Client agrees to provide updated information upon request and acknowledges that failure to do so may result in suspension, freezing, or termination of their account

4.     Source of Funds and Wealth Verification
        
4.1    Requirement
The Client must ensure that all funds deposited into their account originate from lawful, transparent, and verifiable sources.

4.2   Company’s Rights
The Company may, at any time and without notice:
a)     request supporting documentation regarding the origin of funds or wealth;
b)    delay or withhold deposits or withdrawals until such documentation is provided;
c)     rejector reverse transactions where the source of funds cannot be satisfactorily verified.

4.3   No Liability
The Company shall not be liable for delays, losses, or opportunity costs resulting from verification processes, investigations, or refusal of transactions.

5.     Ongoing Monitoring  
        
The Company shall continuously monitor trading activity, deposits, withdrawals, and other account behavior for suspicious or unusual patterns. The Company reserves the right to:

a)       suspend or block transactions pending review;
b)       freeze funds where suspicious activity is detected;
c)       request additional information or documentation at any stage;
d)       close accounts where activity is inconsistent with this Policy.

6.     Prohibited Transactions and Clients
        
6.1   Absolute Prohibition of Certain Clients and Activities
The Company expressly prohibits the following, and shall not accept or continue any Client relationship or transaction involving:1.1    Absolute Prohibition of Certain Clients and Activities
a)    anonymous or fictitious accounts, or Clients using false, stolen, or unverifiable identities;
b)   third-party deposits or withdrawals unless expressly pre-approved in writing by the Company;
c)    Clients domiciled in, or conducting business from, countries subject to sanctions, embargoes, or FATF black/grey lists;
d)   Clients identified as politically exposed persons (“PEPs”), close associates, or family members of PEPs, without enhanced due diligence;
e)    Clients engaged in shell banking, unlicensed money service businesses, or other high-risk sectors such as casinos, gambling operators, or virtual asset mixers/tumblers;
f)     transactions involving funds reasonably suspected to be derived from criminal conduct, fraud, corruption, narcotics trafficking, human trafficking, terrorism, tax evasion, or any other unlawful activity;
g)   Clients or transactions designed to evade reporting obligations, hide beneficial ownership, or disguise the origin of funds.

6.2  Company’s Right of Refusal
The Company reserves the unrestricted right, at its sole and absolute discretion, to:
a)    refuse onboarding of a Client without explanation;
b)    decline deposits or block withdrawals suspected to involve prohibited activity;
c)   suspend, freeze, or close accounts associated with prohibited transactions;
d)    report such accounts or transactions to relevant authorities in Saint Lucia or elsewhere, as required.
e)   The Client acknowledges that the Company is not required to provide reasons for rejecting or terminating a relationship under this clause.

6.3   No Liability of the Company
The Client expressly agrees that the Company shall not be liable for any loss, delay, cost, opportunity loss, reputational harm, or damages suffered by the Client as a result of:
a)    refusal to open or maintain an account;
b)   suspension, freezing, or termination of services;
c)    blocking or reversal of deposits or withdrawals;
d)   reporting of Client details to competent authorities.
e)    The Client waives any right to claim damages, refunds, or restitution against the Company for actions taken in accordance with this clause.

6.4   Client’s Sole Responsibility
The Client bears sole responsibility for ensuring that:
a)    their funds are derived from lawful sources;
b)   their activities comply with AML/CTF and related regulations in their jurisdiction;
c)    they are not subject to sanctions, restrictions, or prohibitions;
d)    their transactions do not involve third-party beneficiaries or undisclosed beneficial owners.
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6.5    Indemnity
The Client agrees to indemnify and hold harmless the Company, its directors, officers, employees, affiliates, and service providers from any investigation, claim, penalty, fine, or expense (including legal fees) arising out of or in connection with:
a)    the Client’s breach of this clause;
b)   false or misleading representations regarding the origin of funds;
c)    the Client’s involvement in prohibited transactions;
d)   enforcement actions by regulators or third parties against the Company due to the Client’s activities.

6.6    Survival
The prohibitions, disclaimers, waivers, and indemnity obligations set forth in this clause shall survive termination of the Client’s account and remain binding indefinitely.

7.     Reporting Obligations

7.1    Legal Obligation to Report
‍The Company is legally required under the laws of Saint Lucia to monitor transactions and report suspicious activity to the competent regulatory, enforcement, or judicial authorities. This includes but is not limited to filing Suspicious Activity Reports (SARs) or equivalent notifications where the Company has knowledge, suspicion, or reasonable grounds to suspect that a transaction may involve proceeds of crime, terrorist financing, or other unlawful activity.

7.2    Right to Report Without NoticeThe Client acknowledges and agrees that the Company may, at its sole discretion and without notice to the Client:
a)    file SARs or equivalent reports with local or international authorities;
b)   disclose Client information, account records, and transaction details as required by law;
c)    cooperate fully with regulators, financial intelligence units, law enforcement agencies, or courts;
d)   share information with banks, payment providers, or other financial institutions where required for compliance purposes.

7.3    Waiver of LiabilityThe Client irrevocably waives any right to claim damages, compensation, restitution, or loss of reputation against the Company in connection with:
a)   the filing of reports, disclosures, or notifications to authorities;
b)   the freezing, delay, or blocking of transactions pending review;
c)   adverse consequences, investigations, or enforcement actions initiated as a result of such reporting.

7.4    No Obligation to Inform ClientThe Company is under no obligation to inform the Client of:
a)   the filing of SARs or reports;
b)   investigations or inquiries initiated by regulators or authorities;
c)   restrictions or monitoring imposed on he Client’s account;
d)  communications exchanged with banks, payment processors, or government agencies.

7.5    Confidentiality of Reports
‍The Client acknowledges that SARs and related disclosures are legally protected and confidential. The Client shall not request access to such reports and the Company shall not be required to provide copies or confirm whether a report has been filed.

7.6    Indemnity
The Client agrees to indemnify and hold harmless the Company, its directors, officers, employees, affiliates, and service providers against any cost, penalty, liability, investigation, or expense (including legal fees) arising out of:
a)   regulatory, banking, or governmental actions triggered by the Client’s activities;
b)   claims or proceedings initiated against the Company due to its compliance with reporting obligations;
c)   the Client’s attempt to challenge, obstruct, or interfere with the Company’s legal reporting duties.

7.7    Survival
‍The rights of the Company and the obligations of the Client under this clause shall survive termination of the Client’s account and remain binding indefinitely, regardless of whether the Client continues to use the Platform.
 

8.     Freezing, Suspension, and Termination Rights

8.1    Right to Freeze or Suspend
‍The Company reserves the absolute right, at its sole discretion and without prior notice, to freeze, suspend, or restrict a Client’s account, funds, or transactions where:
a)    suspicious or unusual activity is detected;
b)    AML/CTF verification documents are incomplete, outdated, or unsatisfactory;
c)    the Client is suspected of providing false, misleading, or fraudulent information;
d)   the Client appears to be in breach of applicable AML/CTF laws, regulations, or this Policy;
e)    the Company is required to do so under law, court order, or regulatory directive.

8.2    Consequences of Freezing or Suspension
‍Where an account is frozen or suspended, the Client acknowledges and accepts that:
a)    deposits and withdrawals may be delayed, locked, or reversed;
b)    open positions may be liquidated at prevailing market prices without prior consent;
c)    funds may be withheld pending the outcome of investigations or regulatory reviews;
d)   the Company bears no liability for losses, opportunity costs, or reputational harm arising from such actions.

8.3    Right to Terminate
‍The Company may, in its sole discretion and without liability, terminate the Client’s relationship permanently where:
a)    AML/CTF concerns cannot be satisfactorily resolved;
b)    prohibited activities or jurisdictions are identified;
c)    the Client fails to cooperate with AML/CTF requests;
d)   the Client’s continued relationship poses legal, financial, or reputational risk to the Company.

8.4    No Obligation to Refund
‍Termination or suspension under this clause shall not entitle the Client to any refund, compensation, or restitution of fees, costs, or losses incurred. Funds with held pending regulatory clearance may be retained until release is authorized by the competent authority.

8.5    Indemnity
‍The Client agrees to indemnify and hold harmless the Company, its directors, officers, employees, affiliates, and service providers from and against any liability, claim, penalty, fine, or expense (including legal fees) arising from:
a)    enforcement actions resulting from the Client’s activities;
b)    third-party or regulatory claims linked to frozen or terminated accounts;
c)    the Client’s failure to comply with AML/CTF requirements.

8.6    Waiver of Claims
‍The Client irrevocably waives any right to bring claims, demands, or legal proceedings against the Company for freezing, suspension, or termination of accounts or funds under this clause, regardless of the consequences to the Client.

8.7    Survival
The rights of the Company and the obligations of the Client under this clause shall survive termination of the Client’s account and remain binding indefinitely.

9.   Client Responsibilities

9.1    The Client is solely responsible for ensuring that all information, documents, and declarations provided to the Company are true, accurate, complete, and not misleading in any respect. The Client undertakes to promptly notify the Company of any change in personal, financial, or business circumstances that may affect AML/CTF compliance.

9.2    Duty to Cooperate
The Client agrees to fully cooperate with the Company’s AML/CTF procedures, including but not limited to:
a)    submitting verification documents, proof of residence, and beneficial ownership information;
b)   providing source of funds and source of wealth evidence upon request;
c)    responding to requests for clarification or additional information within the time period specified by the Company.
d)   Failure to cooperate may result in immediate suspension, freezing, or termination of the Client’s account.

9.3    Prohibition on Unlawful Use
The Client shall not use the Platform, directly or indirectly, for any unlawful purpose, including but not limited to money laundering, terrorist financing, sanctions evasion, fraud, tax evasion, or concealment of illicit proceeds. The Client acknowledges that violation of this obligation constitutes a material breach of this Policy and may be reported to competent authorities.

9.4    Responsibility for Third-Party Dealings
The Client shall not permit third parties to deposit or withdraw funds on their behalf without the Company’s prior written approval. The Client is solely responsible for ensuring that no third party gains unauthorized access to their account.

9.5    Tax and Legal Compliance
The Client is solely responsible for complying with all tax, financial, and legal obligations in their jurisdiction in connection with the use of the Platform. The Company shall have no liability for the Client’s failure to fulfill such obligations.

9.6    Liability for Breach
The Client acknowledges and agrees that any breach of this clause may result in:
a)    freezing or termination of their account;
b)    reporting of their details and transactions to competent authorities;
c)    forfeiture of funds where required bylaw;
d)   permanent loss of access to the Platform.

9.7    Indemnity
The Client agrees to indemnify, defend, and hold harmless the Company, its directors, officers, employees, affiliates, and service providers against any penalty, fine, investigation, cost, or expense (including legal fees) arising from or connected to:
a)    inaccurate, false, misleading, or incomplete information provided by the Client;
b)   the Client’s failure to comply with AML/CTF obligations in their jurisdiction;
c)    unlawful transactions, deposits, or withdrawals conducted through the Client’s account.

9.8    Waiver of Claims
The Client irrevocably waives any right to bring claims, demands, or legal proceedings against the Company for losses, reputational harm, or penalties incurred as a result of their own breach of AML/CTF obligations. 

9.9    Survival
The responsibilities, indemnities, and waivers set out in this clause shall survive termination of the Client’s account and remain binding indefinitely.

10.    Indemnity and Waivers

10.1   General Indemnity
‍The Client agrees to indemnify, defend, and hold harmless the Company, its directors, officers, employees, affiliates, agents, and service providers from and against any and all claims, demands, proceedings, investigations, penalties, fines, liabilities, losses, damages, costs, and expenses (including but not limited to reasonable legal and professional fees) arising directly or indirectly out of:
a)    the Client’s breach of this Policy, the Client Agreement, or applicable AML/CTF laws;
b)    the Client’s failure to provide accurate, truthful, or complete information;
c)    the Client’s involvement in, or suspected involvement in, money laundering, terrorist financing, fraud, sanctions evasion, or any other unlawful activity;
d)    regulatory, judicial, or enforcement actions brought against the Company as a result of the Client’s activities;
e)    claims or disputes raised by banks, payment processors, or financial institutions connected to the Client’s transactions.

10.2  Indemnity for Regulatory Actions
‍The Client expressly agrees to indemnify the Company against any enforcement action, penalty, sanction, asset freeze, reputational harm, or legal proceeding initiated by any government, regulator, or financial institution arising from the Client’s activities.

10.3   Recovery of Costs
‍The Company shall have the unrestricted right, without prior notice, to:
a)    debit, offset, or apply funds held in the Client’s account towards satisfaction of indemnity obligations;
b)    liquidate the Client’s open positions and apply proceeds towards outstanding liabilities;
c)    pursue additional recovery through legal proceedings if account funds are insufficient.

10.4   Waiver of Claims Against the Company
‍The Client irrevocably waives any right to bring claims, demands, or legal proceedings against the Company for:
a)    freezing, blocking, or terminating accounts under AML/CTF obligations;
b)    reporting the Client to regulators, law enforcement, or financial institutions;
c)    delays, losses, or opportunity costs caused by AML/CTF checks or investigations;
d)   reputational or financial harm suffered as a result of compliance actions.

10.5   No Limitation of Rights
‍The indemnities and waivers contained in this clause are in addition to, and not in limitation of, any other rights, defenses, or remedies available to the Company under law, equity, or contract. 

10.6   Survival
‍The indemnity obligations and waivers under this clause shall survive termination of the Client’s account and remain binding indefinitely, regardless of whether the Client continues to use the Platform.

11.    Record-Keeping

The Company shall retain Client information, transaction records, and AML/CTF documentation for a minimum of seven (7) years from the date of account closure or as otherwise required by Saint Lucia law.

12.    Amendments to the Policy

12.1  Company’s Right to Amend
TheCompany reserves the unrestricted right, at its sole discretion and withoutprior notice, to amend, update, revise, supplement, or replace this Policy, inwhole or in part, at any time. Amendments may be made to reflect changes inapplicable laws of Saint Lucia, evolving regulatory standards, internationalAML/CTF obligations, industry practices, or the Company’s internal riskmanagement requirements.

12.2  Effective Date of Amendments
Unless expressly stated otherwise, amendments shall take effect immediately upon publication on the Company’s official website or Platform. The Company is not obligated to provide individual notice of amendments to Clients, and the Client expressly waives any right to claim lack of notice.

12.3  Client’s Duty of Review
The Client acknowledges and agrees that it is their sole responsibility to periodically review the most current version of this Policy. Continued access to or use of the Platform, or the initiation of any deposit, withdrawal, or transaction after publication of an amendment, shall constitute the Client’s full and binding acceptance of the revised Policy.

12.4  No Liability of the Company
The Company shall not be liable for any loss, cost, expense, penalty, opportunity cost, or reputational damage suffered by the Client as a result of amendments to this Policy. The Client irrevocably waives any right to claim compensation, restitution, or damages from the Company in connection with such amendments.

12.5  Regulatory Priority
Where amendments are required to comply with legal, regulatory, or governmental directives, such amendments shall apply immediately and automatically, irrespective of whether the Client has reviewed or accepted them. The Client acknowledges that such changes are binding without limitation.

12.6 Survival
This clause shall survive termination of the Client’s account. The Client’s obligations under the amended Policy remain binding until fully discharged, regardless of whether such amendments were in effect at the time of account opening.

13.    Governing Law and Dispute Resolution

This Policy shall be governed exclusively by the laws of Saint Lucia. Any dispute, controversy, or claim arising out of or in connection with this Policy shall be resolved exclusively by binding arbitration in Saint Lucia, conducted under the International Arbitration Rules of the Singapore International Arbitration Centre (SIAC), as adopted by the Company. The Client irrevocably waives the right to bring claims in any other jurisdiction.