Anti-Money Laundering (AML) Policy

1. Introduction:

Brackly Capital ("Dealer") is committed to upholding the highest standards of integrity, ethics, and regulatory compliance in its operations. This Anti-Money Laundering (AML) Policy outlines the measures and procedures we have implemented to prevent money laundering and the financing of terrorism in accordance with the laws of The Islamic Republic of Pakistan.

2. Purpose:

The purpose of this AML Policy is to:

1. Prevent the use of our services for money laundering, terrorist financing, or any other illegal activities.
2. Ensure compliance with relevant AML and counter-terrorism financing (CTF) laws, regulations, and guidelines.
3. Safeguard our platform's reputation and integrity by maintaining a strong stance against financial crime.
3. Customer Due Diligence (CDD):
1. Brackly Capital conducts thorough customer due diligence when onboarding new clients. This includes the verification of the customer's identity, address, and other relevant information.
2. Enhanced due diligence is performed for higher-risk customers, such as politically exposed persons (PEPs) and high-risk jurisdictions.
3. Ongoing monitoring of customer transactions and behavior is conducted to detect any unusual or suspicious activities.
4. Know Your Customer (KYC) Procedures:
1. Brackly Capital maintains comprehensive KYC procedures to identify and verify the identity of its customers and beneficial owners.
2. Customers are required to provide valid identification documents, proof of address, and other relevant information as part of the KYC process.
3. For corporate clients, we obtain information about the company's ownership structure and beneficial owners.
5. Suspicious Activity Reporting:
1. Brackly Capital has established mechanisms for employees to report any unusual or suspicious activities that may indicate money laundering or terrorist financing.
2. Employees are trained to recognize and report red flags associated with suspicious transactions.
6. Record Keeping:
1. Brackly Capital maintains accurate and up-to-date records of customer information, transactions, and due diligence measures.
2. Records are securely stored and retained as required by applicable laws and regulations.
7. Training and Awareness:
1. Regular training programs are conducted to educate employees about AML and CTF laws, policies, and procedures.
2. Employees are trained to identify suspicious activities and report them appropriately.
8. Sanctions Compliance:

Brackly Capital screens customers against relevant sanctions lists to prevent doing business with individuals or entities associated with prohibited activities.

9. Reporting Obligations:

Brackly Capital complies with its legal obligations to report suspicious activities to the appropriate regulatory authorities as required by law.

10. Non-Retaliation:

Brackly Capital prohibits any form of retaliation against employees who report suspicious activities in good faith.

11. Management Oversight:

Senior management is responsible for ensuring the effectiveness of the AML program and its continuous improvement.

12. Cooperation with Authorities:

Brackly Capital cooperates fully with law enforcement agencies and regulatory authorities in matters related to AML and CTF investigations.

By adhering to this AML Policy, Brackly Capital demonstrates its commitment to maintaining a secure and transparent environment for its customers while contributing to the global effort to combat money laundering and terrorist financing.

For any inquiries or concerns related to this AML Policy, please contact our AML Compliance Officer at [email protected].