This KYC & AML/CFT Policy (“Policy”) explains how Riyadex Financials (Pty) Ltd. (“the Company”, “we”, “us”) complies with the Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) requirements mandated by the Financial Services Regulatory Authority (FSCA) of South Africa and international standards (FATF).

This Policy is part of the Client Agreement and applies to all clients, partners, employees, and transactions.

  1. Purpose of This Policy

    The Policy aims to:

    • Prevent money laundering and terrorist financing
    • Ensure compliance with South Africa AML/CFT laws
    • Establish strict customer identification procedures
    • Protect the Company and its clients
    • Maintain transparency and secure financial operations
  2. Legal & Regulatory Framework

    RIYADEX complies with:

    • South Africa FSCA AML/CFT Regulations
    • Proceeds of Crime Act
    • Anti-Money Laundering Act
    • FATF Recommendations
    • International sanctions programs (UN, OFAC, EU, UK, etc.)
  3. Scope of the Policy

    This Policy applies to:

    • All RIYADEX clients
    • All transactions (deposit, withdrawal, trading activity)
    • Introducing Brokers (IBs), affiliates, employees, and partners
    • Third-party service providers handling client information
  4. Customer Identification Program (CIP)

    RIYADEX performs identification and verification before opening accounts or processing any financial transactions.

    4.1 Mandatory Identification Documents (Individuals)

    Clients must provide:

    • Valid government-issued photo ID (passport, national ID, or driver’s license)
    • Proof of residential address (utility bill, bank statement, or government letter not older than 3 months)
    • Proof of payment method (bank statement, card verification, etc.) if required

    4.2 Corporate Clients

    Corporate applicants must provide:

    • Certificate of incorporation
    • Memorandum & Articles of Association
    • Proof of registered address
    • List of directors
    • Shareholder register
    • Identity documents of directors & beneficial owners (20%+)
    • Authorized signatory resolution

    4.3 Enhanced Verification May Include

    • Video verification
    • Additional address confirmation
    • Phone validation
    • Biometric checks
  5. Customer Due Diligence (CDD)

    CDD procedures ensure the identity of clients is verified and that the nature of the relationship is legitimate.

    CDD includes:

    • Collection of personal information
    • Verification of identity documents
    • Assessment of risk factors
    • Understanding purpose of trading account
    • Ongoing monitoring of account activity
  6. Enhanced Due Diligence (EDD)

    EDD is applied to high-risk clients, including:

    • Politically Exposed Persons (PEPs)
    • Clients from high-risk jurisdictions
    • Clients with large or unusual transaction patterns
    • Clients with unclear source of funds
    • Clients using third-party funding

    EDD procedures include:

    • Detailed financial profiling
    • Additional document requests
    • Proof of source of wealth
    • Verification of business activities
    • Senior management approval
  7. Risk Assessment & Client Risk Scoring

    RIYADEX assigns a risk level to every client:

    Low Risk

    • Clear identity
    • Low transaction volume
    • Clean AML history

    Medium Risk

    • Moderate volume trading
    • Mixed funding methods

    High Risk

    • High-risk country
    • High trading volume
    • Unusual withdrawals
    • PEP or close associate
    • Suspicious transaction pattern

    High-risk accounts undergo EDD and regular monitoring.

  8. Ongoing Monitoring

    We continuously monitor:

    • Trading activity
    • Deposit & withdrawal behavior
    • Sudden changes in trading pattern
    • Use of multiple payment methods
    • Transfers involving third parties
    • Large or rapid movements of funds

    If suspicious activity is detected:

    • The account may be temporarily restricted
    • Documentation may be requested
    • Transactions may be delayed
    • A Suspicious Activity Report (SAR) may be filed
  9. Funding & Withdrawal Rules

    To prevent financial crime:

    9.1 Deposit Restrictions

    • Deposits must come from accounts belonging to the same client
    • Third-party deposits are prohibited
    • Suspicious or mismatched payments may be rejected

    9.2 Withdrawal Restrictions

    • Withdrawals must be made to the original funding source
    • Alternative withdrawal methods require KYC & AML approval
    • The Company may delay or refuse withdrawals if verification is incomplete
  10. Sanctions Screening

    RIYADEX screens all clients against:

    • UN sanctions lists
    • OFAC lists
    • EU/UK sanction regimes
    • Global PEP databases
    • Financial crime watchlists

    Clients appearing on sanctions lists will have access denied or terminated.

  11. Politically Exposed Persons (PEPs)

    PEPs and their associates require:

    • Mandatory EDD
    • Senior management approval
    • Ongoing monitoring of account activity
    • Verification of source of wealth
  12. Suspicious Activity Indicators

    Examples include:

    • Multiple deposits from unrelated sources
    • Rapid deposit and withdrawal cycles
    • Inconsistent trading activity
    • Attempts to conceal identity
    • Refusal to provide documents
    • Use of VPNs or false IP locations
    • Funding from high-risk jurisdictions

    The Company reserves the right to:

    • Request additional documents
    • Suspend account access
    • File SARs without notifying the client
  13. Prohibited Activities

    RIYADEX does not allow:

    • Anonymous accounts
    • Shell companies without legitimate documentation
    • Third-party payments
    • Accounts used for unlicensed money services
    • Use of trading accounts as fund transfer channels
    • Funding via illegal or unknown sources
  14. Record Keeping

    We maintain all records for a minimum of five (5) years, including:

    • KYC documents
    • Transaction history
    • Communication logs
    • Verification and screening data
    • Suspicious Activity Reports (SARs)
  15. Employee Training

    All employees receive AML/CFT training covering:

    • Detecting suspicious activity
    • KYC/EDD procedures
    • Reporting obligations
    • Customer interaction guidelines
  16. Internal Controls & Reporting

    The Company has:

    • A designated AML Compliance Officer (MLRO)
    • Internal reporting channels
    • Procedures for investigating suspicious cases
    • Escalation pathways to regulatory authorities
  17. Client Obligations

    Clients agree to:

    • Provide accurate and truthful information
    • Submit required KYC documents
    • Not engage in prohibited activities
    • Update information when changes occur
    • Cooperate with compliance requests

    Failure to comply may result in:

    • Account suspension
    • Termination
    • Report to authorities
  18. Policy Updates

    This Policy will be reviewed:

    • Annually
    • When regulations change
    • When operational processes evolve

    Updated policies will be published on the Company website.