Table of Contents

Cubo Markets Ltd. (“the Company”, “we”, “us” or “Our”) is committed to the prevention of money laundering, terrorist financing and other forms of financial crime. This Anti-Money Laundering and Counter-Terrorist Financing Policy (the “Policy”) sets out the framework, controls and responsibilities the Company applies to detect, deter and report attempts to use its products and services for illicit purposes.

The Company adopts a risk-based approach proportionate to the nature, scale and complexity of its activities. Compliance with this Policy is mandatory for all directors, officers, employees, contractors and agents of the Company.

1. Purpose and Objectives

The objectives of this Policy are to: protect the Company, its clients and the integrity of the financial system from being used to launder the proceeds of crime or to finance terrorism; establish clear roles, responsibilities and escalation paths; and ensure that the Company meets its legal and regulatory obligations under the applicable laws of Saint Lucia and recognised international standards, including the recommendations of the Financial Action Task Force (FATF).

• Prevent the Company from being used, knowingly or unknowingly, for money laundering or terrorist financing.
• Identify and verify the identity of clients and, where relevant, their beneficial owners.
• Monitor business relationships and transactions on an ongoing basis.
• Detect, investigate and report suspicious activity to the relevant authorities.
• Maintain adequate records and provide regular training to staff.

2. Scope and Application

This Policy applies to all business lines, products, services and distribution channels of the Company, and to all persons acting on behalf of the Company. It applies to every client relationship and to all transactions processed through the Company’s platforms and payment arrangements, irrespective of value or channel.

3. Definitions

Money Laundering (ML) is the process by which the proceeds of criminal conduct are converted, concealed or disguised so that they appear to originate from a legitimate source. It includes concealment, arrangement, acquisition, use and possession of criminal property.

Terrorist Financing (TF) is the provision or collection of funds, by any means, with the intention or knowledge that they are to be used to carry out terrorist acts or by a terrorist organisation.

Beneficial Owner means the natural person(s) who ultimately owns or controls a client, or on whose behalf a transaction is conducted, including any person exercising ultimate effective control over a legal person or arrangement.

Politically Exposed Person (PEP) means an individual who is or has been entrusted with a prominent public function, as well as their family members and known close associates.

Customer Due Diligence (CDD) means the measures taken to identify and verify clients and beneficial owners, to understand the purpose and intended nature of the relationship, and to monitor it on an ongoing basis.

Suspicious Transaction Report (STR) means a report submitted to the relevant Financial Intelligence Unit (FIU) where there are grounds to suspect money laundering, terrorist financing or related criminal activity.

4. Regulatory Framework

The Company operates in accordance with the anti-money laundering and counter-terrorist financing legislation applicable in Saint Lucia and with relevant international standards. Where the Company processes activity connected to other jurisdictions, it has regard to applicable sanctions regimes and to the FATF recommendations as the prevailing international benchmark. This Policy is reviewed whenever there is a material change in the applicable legal or regulatory framework.

5. Governance and the Compliance Function

5.1 Money Laundering Reporting Officer (MLRO)

The Company appoints a Money Laundering Reporting Officer (“MLRO”) of sufficient seniority and independence. The MLRO is responsible for the day-to-day oversight of the Company’s AML/CTF programme, for receiving internal suspicion reports, for deciding whether an external report should be made, and for acting as the primary point of contact with the relevant authorities.

5.2 Responsibilities of the MLRO

• Maintaining and updating this Policy and supporting procedures.
• Receiving, assessing and documenting internal suspicious activity reports.
• Determining whether to submit a Suspicious Transaction Report to the relevant FIU.
• Overseeing client due diligence, ongoing monitoring and sanctions screening.
• Ensuring staff receive appropriate AML/CTF training and maintaining training records.
• Reporting periodically to senior management and the board on the effectiveness of the programme.

5.3 Senior Management Responsibility

Senior management is ultimately accountable for the Company’s compliance with its AML/CTF obligations, for fostering a culture of compliance, and for ensuring that the compliance function is adequately resourced and empowered to act independently.

6. Risk-Based Approach

The Company assesses and documents the money laundering and terrorist financing risks to which it is exposed, taking into account client, product, delivery-channel, transaction and geographic risk factors. Controls are calibrated to the assessed level of risk: lower-risk situations may attract simplified measures, while higher-risk situations attract enhanced measures. The Company’s business-wide risk assessment is reviewed at least annually and following any material change to the business.

6.1 Client Risk Categorisation

Each client is assigned a risk rating (for example, standard, medium or high) based on factors including the client’s profile and jurisdiction, the nature and expected level of activity, the presence of PEP status, and any adverse information identified. The risk rating determines the level of due diligence and the intensity of ongoing monitoring applied.

7. Customer Due Diligence

The Company applies Customer Due Diligence in accordance with its separate Customer Due Diligence (KYC) Policy. CDD is conducted before establishing a business relationship, where there is a suspicion of money laundering or terrorist financing, and where there are doubts about the veracity or adequacy of previously obtained identification data. The Company does not provide services to anonymous clients or clients using fictitious names.

7.1 Enhanced Due Diligence

Enhanced Due Diligence (EDD) is applied to higher-risk relationships, including PEPs, clients connected to higher-risk jurisdictions, and situations presenting unusual or complex characteristics. EDD measures may include obtaining senior management approval, establishing source of funds and source of wealth, and applying more frequent and intensive monitoring.

8. Ongoing Monitoring and Transaction Monitoring

The Company monitors business relationships and transactions throughout their lifecycle to ensure that activity is consistent with its knowledge of the client, the client’s risk profile and the expected nature of the relationship. Monitoring is designed to identify transactions that are unusual, lack an apparent economic or lawful purpose, or are otherwise inconsistent with the client’s profile.

8.1 Examples of Red Flags

• Transactions inconsistent with the client’s stated profile, activity or financial standing.
• Reluctance to provide identification information or provision of information that cannot be verified.
• Frequent or unexplained funding from, or withdrawals to, unrelated third parties.
• Requests to route funds through, or in connection with, higher-risk or sanctioned jurisdictions.
• Rapid movement of funds with no apparent trading rationale or attempts to obscure the source of funds.
• Use of multiple accounts or structuring of transactions to avoid thresholds or detection.

9. Sanctions Screening

The Company screens clients, beneficial owners and, where appropriate, counterparties against applicable sanctions lists at onboarding and on an ongoing basis. The Company will not establish or maintain a relationship with, or process transactions for, any person subject to applicable sanctions, and will take such freezing or reporting action as may be required by law.

10. Suspicious Activity Reporting

Any employee who knows or suspects, or has reasonable grounds to know or suspect, that a person is engaged in money laundering or terrorist financing must report the matter promptly and internally to the MLRO using the Company’s internal reporting procedure. The MLRO will assess each internal report and, where appropriate, submit a Suspicious Transaction Report to the relevant Financial Intelligence Unit. Internal reports must not be filtered or suppressed; the obligation to escalate a genuine suspicion to the MLRO rests with each individual.

10.1 Prohibition on Tipping-Off

Employees must not disclose to a client or to any third party that an internal report has been made, that an external report has been or may be submitted, or that an investigation is being or may be carried out, where such disclosure is likely to prejudice an investigation. Unauthorised disclosure may constitute a criminal offence.

11. Record Keeping

The Company retains records of client identification and verification, due diligence information, transactions, internal and external suspicious activity reports, and training, for the minimum period required by applicable law and in any event for not less than five (5) years from the end of the business relationship or the date of the relevant transaction, whichever is later. Records are stored securely and are retrievable on a timely basis to support inquiries from competent authorities.

12. Training and Awareness

All relevant staff receive AML/CTF training on appointment and at regular intervals thereafter. Training is designed to ensure that staff understand the law and their obligations, can recognise activity that may indicate money laundering or terrorist financing, and know how and to whom to report suspicions. Training records are maintained by the compliance function.

13. Independent Review

The adequacy and effectiveness of the Company’s AML/CTF systems and controls are subject to periodic independent review. Findings and recommendations are reported to senior management, and remedial actions are tracked to completion.

14. Consequences of Non-Compliance

Failure to comply with this Policy may expose the Company and individuals to civil and criminal liability, regulatory sanction and reputational harm. Breaches of this Policy by staff may result in disciplinary action up to and including termination of employment or engagement, and may be reported to the relevant authorities where required.

15. Review of this Policy

This Policy is reviewed at least annually, and additionally following any material change in the Company’s business, in the applicable legal or regulatory framework, or in the Company’s risk profile. The MLRO is responsible for maintaining the Policy and for recording the date and substance of each review.

16. Governing Law

This Policy forms part of the Company’s internal control framework and is governed by, and shall be construed in accordance with, the laws of Saint Lucia. It is to be read together with the Company’s Customer Due Diligence (KYC) Policy, Risk Management Policy, Terms and Conditions and other applicable policies.