INTRODUCTION and (KYC,AML,CFT) Policy

The trade name “Real For Investment Ltd” and the website www.real4invest.com are fully owned and operated by Real For Investment Ltd, which is authorized and licensed to carry on business and financial trading services activities, including participation in other enterprises to provide brokerage services in foreign exchange, currencies, commodities, indexes, CFDs, and leveraged financial instruments.

Real For Investment Ltd aims to prohibit, detect, and actively pursue the prevention of money laundering and terrorism financing activities. The company vows to comply with all related laws, rules, and regulations with full attention and without compromise regarding any of the aforementioned illegal activities. The management of the company is committed to Anti-Money Laundering (“AML”) and Counter Terrorism Financing (“CFT”) compliance in accordance with applicable laws and places extremely high importance on assisting in discovering any money laundering scheme and/or terrorism financing activities. Real For Investment Ltd also requires its officers, employees, introducing brokers, and affiliated companies to adhere to these standards in preventing the use of the company’s products and services for the purposes of money laundering and terrorism financing activities.

PURPOSE

The purpose of the “AML, CFT & KYC Policy” (“the Policy”) is to provide guidance on the Anti-Money Laundering (“AML”), Counter Terrorism Financing (“CFT”), and Know Your Client (“KYC”) procedures which are followed by the company in order to achieve full compliance with the relevant AML and CTF legislation. This policy applies to all company officers, employees, introducing brokers, affiliated companies, and products and services offered by the company. Any employee found not adhering to these policies and procedures will face severe disciplinary action.

LEGAL FRAMEWORK

The company is required to comply with the provisions of the applicable laws regarding the prevention of money laundering and terrorist financing. The main purpose of these laws is to define and criminalize the laundering of proceeds generated from all serious criminal offenses, aiming at depriving criminals of the profits of their crimes. In accordance with the AML and CTF laws, the company is obliged to set out policies and procedures for preventing money laundering and terrorist financing activities. The AML and CFT procedures, which are implemented by the registered office in (AIFC) Astana International Financial Centre, are based on AML and CFT laws applicable in Saint Vincent, the recommendations of the Investment Task Force (ITF), in addition to other documents and information.

DEFINITIONS

4.1 Money Laundering

Money laundering is the process of creating the appearance that large amounts of money obtained from serious crimes, such as drug trafficking or terrorist activity, originated from a legitimate source. There are three steps involved in the process of laundering money: Placement, Layering, and Integration.

4.1.1 Placement

Placement refers to the act of introducing “dirty money” (money obtained through illegitimate, criminal means) into the financial system in some way.

4.1.2 Layering

Layering is the act of concealing the source of that money by way of a series of complex transactions and bookkeeping gymnastics.

4.1.3 Integration

Integration refers to the act of acquiring that money in purportedly legitimate means.

4.2 Terrorism Financing

Terrorism financing (proceeds of crime) is the process by which funds are provided for financing or financial support to individual terrorists or terrorist groups. A terrorist, or terrorist group, is one that has a purpose or activity to facilitate or carry out any terrorist action and can involve individuals or groups.

4.3 AML/CTF

The term AML/CTF refers to “Anti-Money Laundering and Counter-Terrorism Financing” or “Anti-Money Laundering and Combating Terrorism Financing.”

4.3.1 Anti-Money Laundering

Anti-Money Laundering (“AML”) refers to a set of procedures, laws, or regulations designed to stop the practice of generating income through illegal actions.

4.3.2 Counter Terrorism Financing

Counter Terrorism Financing (“CTF”) refers to a set of procedures, laws, or regulations designed to prevent financing or providing financial support to individual terrorists or terrorist groups.

4.4 Financial Action Task Force (FATF)

The Financial Action Task Force (FATF), also known by its French name, Groupe d’action financière (GAFI), is an intergovernmental organization established in July 1989 by a Group of Seven (G-7) Summit in Paris. Initially, it was created to examine and develop measures to combat money laundering. In October 2001, the FATF expanded its mandate to include efforts to combat terrorist financing, in addition to money laundering.

The objectives of the FATF are to set standards and promote effective implementation of legal, regulatory, and operational measures for combating money laundering, terrorist financing, and other related threats to the integrity of the international financial system. Starting with its own members, the FATF monitors countries' progress in implementing the FATF Recommendations; reviews money laundering and terrorist financing techniques and counter-measures; and promotes the adoption and implementation of the FATF Recommendations globally.

The Task Force was given the responsibility of examining money laundering techniques and trends, reviewing the actions already taken at national or international levels, and setting out the measures that still needed to be taken to combat money laundering. In April 1990, less than one year after its creation, the FATF issued a report containing a set of Forty Recommendations, intended to provide a comprehensive plan of action to fight against money laundering.

In 2001, the development of standards in the fight against terrorist financing was added to the FATF's mission. In October 2001, the FATF issued Eight Special Recommendations to address terrorist financing. The continued evolution of money laundering techniques led the FATF to comprehensively revise its standards in June 2003. In October 2004, the FATF published a Ninth Special Recommendation, further strengthening the international standards for combating money laundering and terrorist financing—the 40+9 Recommendations.

In February 2012, the FATF completed a thorough review of its standards and published the revised FATF Recommendations. This revision aims to strengthen global safeguards and further protect the integrity of the financial system by providing governments with stronger tools to take action against financial crime. The recommendations have been expanded to address new threats such as the financing of proliferation of weapons of mass destruction and to enhance transparency and combat corruption. The nine Special Recommendations on terrorist financing have been fully integrated with the measures against money laundering, resulting in a stronger and clearer set of standards.

5. PROCEDURES

The provisions of the laws adopted by the company introduce procedures and processes that ensure compliance with the applicable laws related to money laundering and terrorism financing activities.

5.1 Risk Classification

a. Low-Risk Clients

Credit or financial institutions situated in another country that imposes requirements higher or equivalent to those laid down by the company's regulators (Registered Office in AIFC, Astana International Financial Centre).
Listed companies whose securities are admitted to trading on a regulated market of other countries subject to disclosure requirements consistent with community legislation.

b. Normal Risk Clients

All clients who do not fall under either High Risk or Low Risk categories are considered Normal Risk Clients.

c. High Risk Clients

Non-face-to-face customers
Client accounts in the name of a third person
Politically exposed persons (PEPs) accounts
Electronic gambling/gaming through the internet
Customers from countries which inadequately apply FATF's recommendations
Clients whose nature entails a higher risk of money laundering and terrorist financing
Any other client determined by the company to be classified as such

5.1.2 Client Identification (Due Diligence)

a. Due Diligence Conditions

Establishing a business relationship.
Suspicion of money laundering or terrorist financing, irrespective of the transaction amount.
Doubts about the adequacy of previously obtained client identification data.
Failure or refusal by a client to submit the requisite data and information for verification of identity and creation of their economic profile, without adequate justification.

b. Due Diligence Timing

Client identification and due diligence must take place before establishing a business relationship or carrying out a transaction.
Verification of the client's identity may be completed during the establishment of a business relationship if necessary to avoid interrupting normal business conduct and where there is a low risk of money laundering or terrorist financing. These procedures need to be completed as soon as possible.
Reviews of existing records must occur regularly to ensure documents, data, or information held are up-to-date.
Client due diligence procedures apply to all new clients and, at appropriate times, to existing clients on a risk-sensitive basis.
Upon opening a client's account, it should be closely monitored.
A review should be carried out at least twice a year, with a summary of the results kept in the customer's file.
The company should frequently compare estimated against actual account turnover.
Any serious deviation should be investigated, not only for possible action regarding the particular account but also to assess the reliability of the person or entity who introduced the customer.

c. Due Diligence Procedures

i. Normal Client Due Diligence Procedure

Identifying the client and verifying their identity using reliable, independent sources.
For legal persons, taking risk-based measures to understand the ownership and control structure.
Obtaining information on the purpose and intended nature of the business relationship.
Conducting ongoing monitoring of the business relationship, including scrutinizing transactions to ensure they are consistent with the client's profile.

ii. Simplified Client Due Diligence Procedure

Simplified procedures may apply for low-risk clients when there is no suspicion of money laundering, regardless of any derogation, exemption, or threshold.

iii. Enhanced Client Due Diligence Procedure

Applied in situations presenting a high risk of money laundering or terrorist financing. Measures include:

Establishing the client's identity through additional documents, data, or information.
Ensuring the first payment is made through an account in the client's name with a credit institution operating in a country with equivalent or higher requirements than those of the company's regulators.

d. Verification Procedure

To verify the client's identity during the establishment of the business relationship:

The company ensures the construction of the economic profile, assessment of appropriateness, and suitability before establishing the business relationship.
Clients are given a grace period of fifteen (15) days to provide identification documents. During this period:
- Deposits are capped at USD 2,000.
- Funds must come from a bank account or means linked to a bank account in the client's name.
- Notification emails are sent requesting identification documents.
- Accounts may be closed if verification is not completed after the period.
- The company does not withhold clients' funds or freeze accounts unless there is a suspicion of money laundering.

6. Personnel Education and Training

Real For Investment Ltd ensures employees are aware of their legal obligations in preventing money laundering and terrorist financing by implementing a comprehensive training program. The program educates employees on the latest developments, practical methods, and trends in combating these activities.

Employees understand they may be personally liable for failing to report suspicions.
Training content and timing are adjusted based on departmental needs.
Frequency varies with legal amendments, employee duties, and financial system changes.
The program is structured differently for new and existing employees and departments.
Ongoing training occurs regularly to reinforce responsibilities and update on new developments.