AML/KYC Policy

1. General Provisions and Scope

1.1. This Anti-Money Laundering and Know Your Customer Policy (the “Policy”) establishes rules for the registration, verification and monitoring of users and operations on the Atlant Trade platform (the “Platform”) to manage the risks of money laundering, terrorist financing, fraud, sanctions evasion and other financial crime.

1.2. The Policy applies to atlant-trade.net (the “Company”), Platform users (the “User” or “Client”), and engaged payment and verification providers to the extent of their respective functions.

1.3. This Policy forms an integral part of the Terms and Conditions and must be read together with the Privacy Policy, Risk Disclosure, Trading Rules and the terms applicable to the relevant payment method.

1.4. The purpose of the Policy is to reduce the risk that the Platform is used for laundering criminal proceeds, terrorist financing, fraud, sanctions evasion, unlawful movement of funds, payment abuse or other illegal activity.

1.5. Unless expressly confirmed in the Legal Information section, the Company does not hold a financial-services regulatory licence. This Policy is an internal contractual risk-control framework and does not make the Company a bank, payment institution, licensed broker or other regulated financial institution.

1.6. The Company applies this Policy with reference to the law of the Operator’s jurisdiction, the requirements of servicing banks and payment providers, contractual obligations and a generally accepted risk-based approach. Mandatory applicable law prevails in the event of conflict.

2. Definitions

AML: measures designed to prevent money laundering, terrorist financing and other financial crime.

KYC: procedures used to identify and verify a User.

Non-Trading Operation: a deposit, withdrawal, return, conversion, payment cancellation or dispute, change of payment details or any other funds-related operation that is not a trading transaction.

Payment Instrument: a bank card, bank account, electronic wallet or another supported payment method belonging to the User.

Payment Provider: a bank, processor, payment system, electronic-wallet provider or other supplier involved in processing a payment.

Beneficial Owner: the natural person who ultimately owns or controls the User or on whose behalf an operation is conducted.

Source of Funds: the origin of the specific funds used for a deposit or another operation.

Source of Wealth: the general origin of the User’s assets and financial position.

PEP: a politically exposed person, a family member or a close associate, as understood under the applicable screening procedures.

Suspicious Operation: an operation or pattern of conduct that, because of its nature, amount, frequency, participants or surrounding circumstances, creates a reasonable risk of a breach of law, this Policy or third-party rights.

3. AML/KYC Objectives and Risk-Based Approach

3.1. The Company seeks to prevent the Platform from being used to conceal the origin of funds, transfer funds for third parties, finance unlawful activity, obtain fraudulent reversals, use forged documents or circumvent applicable restrictions.

3.2. The level of review is determined by risk and may depend on the country of residence, payment method, amount and frequency of operations, source of funds, Account history, technical access indicators and other available information.

3.3. The Company may use automated and manual reviews, data matching, document checks, sanctions and PEP screening, device and network analysis, and information received from payment and verification providers.

3.4. The absence of a verification request at one stage does not prevent the Company from requesting documents later, including before a deposit, before a withdrawal, after a data change or when increased risk is identified.

4. User and Source-of-Funds Requirements

4.1. The User confirms that they act in their own name and for their own benefit unless another arrangement has been approved by the Company in writing in advance.

4.2. The User represents that all funds and Payment Instruments used on the Platform:

  • belong to the User or are lawfully controlled by the User;

  • derive from lawful sources;

  • are not connected with criminal activity, fraud, terrorist financing, sanctions violations or third-party claims;

  • are not used to conceal the identity of the actual payer or recipient.

4.3. Anonymous payments, third-party cards or accounts, deposits or withdrawals for another person, sale or transfer of an Account, and use of the Platform primarily as a funds-transmission service are prohibited.

4.4. The User must provide true, complete and current information, promptly notify the Company of changes and explain the economic purpose of an operation when reasonably requested.

4.5. The User must not split operations, create multiple Accounts or use related persons to avoid limits, reviews, jurisdictional restrictions, the one-Account rule or payment-provider requirements.

5. Identification and Verification

5.1. For registration and access to certain Platform functions, the Company may request:

  • full name, date of birth, citizenship and country of residence;

  • address, telephone number and email address;

  • a government-issued identity document;

  • proof of residential address;

  • a photograph of the User holding the document, a selfie or a liveness check;

  • proof of ownership of a bank card, bank account or electronic wallet;

  • information about employment, income, source of funds and source of wealth;

  • a tax number or other information required for a lawful review.

5.2. Documents must be valid, legible, complete and not altered in a way that prevents verification. The User may conceal information that the Company expressly permits to be concealed, such as a card security code.

5.3. The Company may verify information through specialist providers, public registers, payment systems and other lawful sources and may request a translation, certified copy or additional document.

5.4. Until verification is completed, the Company may restrict deposits, trading functions, withdrawals or Account access. Failure to provide requested documents within the stated period may result in rejection of an operation or closure of the Account, with return of the verified remaining balance where not prohibited by law.

5.5. The Company may repeat verification when a document expires, personal or payment data changes, the country changes, unusual activity occurs, access is restored or a payment provider requires it.

6. Enhanced Due Diligence and Ongoing Monitoring

6.1. In higher-risk cases, the Company may conduct enhanced due diligence and request additional information, including evidence of source of funds, source of wealth, purpose of operations, relationship to a payer or recipient, and documents supporting the relevant activity.

6.2. Higher risk may arise from, among other things, large or unusual operations, PEP status, sanctions or high-risk jurisdictions, inconsistent information, complex ownership, frequent changes of payment details or other relevant circumstances.

6.3. The Company may continuously monitor operations and update the User’s risk profile. A review may occur before an operation or after initial acceptance by a payment provider.

6.4. The Company may decline to establish or continue a relationship where it cannot reasonably establish the User’s identity, beneficial ownership, lawful source of funds or the economic purpose of the operations.

7. Indicators of Suspicious Non-Trading Operations

7.1. An operation may be treated as suspicious where one or more of the following circumstances are identified:

  • a deposit followed by a rapid withdrawal without trading activity or with insignificant trading volume;

  • an operation has no apparent economic rationale or legitimate purpose;

  • a third-party Payment Instrument is used or the payer name does not match the Account information;

  • payments are structured to avoid limits or reviews;

  • multiple Accounts, related persons, devices or payment methods are used for coordinated activity;

  • registration data, access geography, payment information and explanations are inconsistent;

  • the User refuses verification, fails to respond to a reasonable request or supplies false, forged, expired or unreadable documents;

  • the source, amount or frequency of funds is inconsistent with the User’s known financial profile;

  • sanctions, wanted-person, PEP or other material risk matches are identified;

  • payment-data theft, Account takeover, fraudulent chargebacks or other abuse is suspected;

  • the Platform is used to move funds between Payment Instruments rather than to obtain the stated services;

  • other reasonable indicators of money laundering, terrorist financing, fraud or unlawful conduct are present.

7.2. The indicators are not exhaustive. A decision is based on the totality of circumstances, User conduct, technical data, Account history and third-party information.

8. Review of Operations and Company Measures

8.1. Where increased risk is identified, the Company may suspend processing for the period reasonably required to conduct a review and may request documents or explanations.

8.2. Depending on the circumstances, the Company may:

  • delay, reject or cancel a Non-Trading Operation before final execution;

  • restrict certain Account functions, including deposits, withdrawals and opening new trades;

  • return funds to the original Payment Instrument;

  • require repeated or enhanced verification;

  • limit use of specific payment methods;

  • temporarily block the Account;

  • terminate the contractual relationship in accordance with the Terms and Conditions;

  • retain and disclose information to competent authorities, banks or payment providers where required or permitted by law.

8.3. The Company applies measures proportionately to the identified risk and, where lawful and not prejudicial to the review, informs the User of a material delay, rejection or restriction.

8.4. The Company may be legally restricted from disclosing the reasons for a review, the details of a sanctions or AML alert, the fact of a report or its internal criteria.

8.5. Suspicion alone does not constitute confiscation of lawfully owned funds. Following the review, the verified remaining balance will be returned or withdrawn subject to applicable law, settled trading operations, the User’s obligations, actual provider charges and return-to-source requirements.

8.6. Trades accepted before an Account restriction will be executed or settled under the Trading Rules unless mandatory law or technical impossibility requires otherwise.

9. Record Retention and Data Protection

9.1. Identification documents, transaction records, correspondence, and verification results shall be retained for as long as necessary to provide the Services, fulfil contractual and applicable legal obligations, resolve disputes, manage risks, and protect the Company’s legitimate interests, but for no longer than seven years unless a longer retention period is required by applicable law.

9.2. Personal data is processed under the Privacy Policy. User documents may be shared with verification, payment, banking, cloud and other providers to the extent necessary for the relevant purpose.

9.3. The Company applies reasonable organisational and technical safeguards, but no transmission or storage system can guarantee absolute security.

9.4. The Company may retain evidence of acceptance of this Policy, operation dates and times, IP address, device information, verification results and other logs needed to investigate disputed or suspicious activity.

10. Account Restriction, Suspension and Closure

10.1. The Company may temporarily restrict or suspend an Account where a review cannot be completed, unauthorised access is suspected, this Policy is breached, a Payment Provider or competent authority requires action, or protection of the User or third parties reasonably requires it.

10.2. The contractual relationship may be terminated under the Terms and Conditions, including for false documents, third-party Payment Instruments, circumvention of restrictions, illegal activity, refusal of required verification or material payment abuse.

10.3. On closure, the Company settles completed operations and, where lawful, returns the verified remaining balance to the User or to the payment source after deduction of disclosed fees and amounts lawfully due under the contract.

10.4. The Company will not withhold lawful funds solely as a penalty for a good-faith complaint or exercise of a mandatory consumer right.

11. Notices, Enquiries and Complaints

11.1. The Company may send requests and notices through the Account area, email, push notification or another verified channel. The User must keep contact information current.

11.2. Payment- and verification-related inquiries, as well as complaints and claims, should be submitted to support@atlant-trade.net. Complaints and claims shall be reviewed in accordance with the Complaints Handling Policy.

11.3. An enquiry should include the User’s name, Account email, date, amount, payment method, transaction reference and supporting documents. The Company may request additional information to identify the applicant.

12. Amendments, Language and Final Provisions

12.1. The Company may amend the Policy because of changes in law, payment procedures, risks or Platform functions. The current version is published on the website with the last-updated date.

12.2. Material changes take effect on the date stated in the notice. Continued use after the effective date constitutes acceptance unless mandatory law requires separate consent.

12.3. If the User does not agree, the User must stop using the Platform and request Account closure under the Terms and Conditions.

12.4. The English version is the official version. Translations are provided for convenience. In the event of inconsistency, the English text prevails to the extent permitted by applicable law.

12.5. Invalidity of one provision does not affect the remaining provisions. Headings are for convenience only.

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