Anti-Money Laundering Policy


Funds Deposit and Withdrawal

With this AML Policy, The Sun Aura Limited has the following policy regarding the deposit and withdrawal of funds from customer trading accounts:

A customer may have only more than one trading account with The Sun Aura Limited. However, each trading account may have only one beneficiary/owner. Only the account beneficiary/owner may deposit or withdraw funds to or from the trading account. Funds may be deposited by Credit or Debit Card, Wire Transfer, Union Pay, Alipay, Wechat Pay and South East Asean Local Debit card. Upon withdrawal of funds from the trading account, the funds will be sent to the same method by which they were deposited, or to a verified method owned by the trading account beneficiary/owner. The account beneficiary/owner must be the verified owner of any method used to deposit or withdraw funds from a customer trading account.

Suspicious Activity

There are signs of suspicious activity that suggest money laundering. Additional due diligence will be performed before proceeding with the transaction for customer. If a reasonable explanation is not met, the suspicious activity shall be reported to Compliance Team. For examples of the possible signs:

  • The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
  • The customer wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the customer’s stated business strategy.
  • Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
  • The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or violations.
  • The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
  • The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person.
  • The customer attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents, or asks for exemptions from the firm’s policies relating to the deposit of cash and cash equivalents.

Upon notification of the list of possible suspicious activity, an investigation will be commenced to determine. The investigation will include, but not necessarily be limited to, review of all available information, such as payment history and personal data. If the results of the investigation warrant, a recommendation will be made to AML Compliance team to file a blocked access. Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. Under no circumstances shall any officer, employee or appointed agent disclose or discuss any AML concern, investigation, notice with the person or persons subject of such, or any other person, including members of the officer’s, employee’s or appointed agent’s family.

Recordkeeping

The AML Compliance team will be responsible for ensuring that AML records are maintained properly and blocked account reports are filed as appropriate.


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