Anti-Money Laundering (AML) Policies

1. Introduction

Purpose

Stepone Group LTD is firmly committed to preventing money laundering, terrorist financing, and other financial crimes and acts in strict adherence to applicable law and international standards. This Anti-Money Laundering (AML) Policy outlines the procedures and controls Stepone Group LTD has in place to detect, prevent, and report money laundering activities. It aims to protect our financial system's integrity and comply with relevant Bulgaria anti-money laundering legislation, which is aligned with the standards set by the Financial Action Task Force (FATF) and other applicable laws.

Scope

This policy applies to all employees, officers, directors, and agents of Stepone Group LTD operating in Bulgaria. It covers activities including purchasing challenges, trading on simulated demo accounts, and any related financial transactions.

2. Regulatory Framework

Legal Requirements

Stepone Group LTD complies with all relevant AML laws and regulations in Bulgaria, including, but not limited to:

• The Bulgarian Measures Against Money Laundering Act (MAMLA)
• European Union's Anti-Money Laundering Directives (AMLD)
• The Bulgarian Measures Against Financing of Terrorism Act (MAFTA)

3. Roles and Responsibilities

Designated Compliance Team

Stepone Group LTD shall appoint a designated compliance team responsible for:

• Implementing and Overseeing AML Policies and Controls: Ensuring all AML measures are effectively implemented and adhered to.
• Main Point of Contact for Reporting Suspicious Activities: Acting as the central contact for all AML-related issues.
• Investigating and Documenting Suspicious Activities: Thoroughly investigating any suspicious transactions and maintaining detailed records.
• Filing Suspicious Activity Reports (SARs): Submitting SARs to the relevant authorities as required by federal AML legislation.
• Liaising with Bulgaria Authorities and Regulators: Coordinating with regulatory bodies to ensure compliance with AML laws.
• Maintaining an AML Training Program: Developing and implementing training programs to educate employees on AML policies and procedures.
• Conducting Regular Compliance Testing: Periodically testing AML controls and procedures to ensure effectiveness.

4. Customer Due Diligence (CDD)

Identification and Verification

Employees shall verify the identity of all customers who have successfully completed the challenge(s) and are eligible to receive payouts from Stepone Group LTD. This verification process shall include the collection and verification of personal information, including but not limited to full name, nationality, address, date of birth, and identification documents (e.g., passport, national ID). Customers who do not successfully complete the challenge(s) shall not be subject to this Know Your Customer (KYC) process.

Ongoing Verification

Employees must continuously monitor customer information to ensure compliance with relevant resolutions or sanctions under Bulgaria laws. This involves updating customer records regularly and conducting periodic reviews. To ensure a complete KYC procedure, Stepone Group LTD is using ondato.com services, which include:

• People Registry Screening
• Proof of Address Screening
• Sanctions Screening
• Politically Exposed Person Screening
• IP and Email Risk Screening
• Adverse Media Screening
• Ultimate Beneficiary Owner Detection and Screening
• Business Registry Screening

High-Risk Clients

Employees assess customers for high-risk factors, such as unusual business relationships, presence in high-risk jurisdictions, and high-value transactions, and take appropriate measures.

Prohibited Countries

The list of prohibited countries is based on the current lists of OFAC and FATF and should be updated accordingly at any time. The users coming from the below list of countries are considered high-risk and are strictly forbidden to use the services of Stepone Group LTD:

• Albania
• Barbados
• Burkina Faso
• Cambodia
• Cuba
• Haiti
• Iran
• Jamaica
• Jordan
• Mali
• Mozambique
• Myanmar
• Nigeria
• North Korea
• Panama
• Russia
• Senegal
• South Africa
• South Sudan
• Syria
• Turkey
• Ukraine (Crimea and occupied regions)
• Venezuela
• Yemen

5. Record Keeping

Employees maintain the following records:

• Customer Due Diligence (CDD) Documents: Information obtained during initial and ongoing CDD.
• Business Correspondence and Transaction Records: Communication with customers and records of transactions.
• Internal Findings and Analyses: Reports on unusual or suspicious transactions, even if they do not result in a SAR.
• Suspicious Activity Reports (SARs): Internal notifications and submitted SARs with supporting documents.
• Communications with the Financial Intelligence Unit (FIU): Records of all communications with the FIU.

These records shall be retained for at least six years from the date of the notification, report, end of the business relationship, or completion of the transaction, whichever is latest.

6. Reporting and Escalation

Suspicious Activity Reports (SARs)

Internal Reporting

Employees are trained to immediately notify the compliance team if they suspect any money laundering or terrorist financing activities. They must provide all relevant details to support their suspicion.

External Reporting

The compliance team is trained to investigate internal SARs, determine if an external SAR is required, and file it with the FIU if necessary.

7. Training and Awareness

Employee Training

Stepone Group LTD is committed to having all employees receive AML training soon after they start and periodically thereafter. AML training includes:

• Understanding the responsibilities of the compliance team.
• Familiarizing with AML legislation.
• Recognizing and managing transactions related to money laundering.
• Identifying and reporting suspicious activities.

Risk-Based Approach to Training

Training is tailored to the specific roles and responsibilities of each employee and provided at intervals appropriate to their duties.

8. Auditing

Audits are conducted internally and/or by independent auditors to:

• Test Compliance with CDD Arrangements: Ensure all customer due diligence procedures are followed.
• Analyze Notifications Made to the Compliance Team: Review internal reports of suspicious activities.
• Review the Effectiveness of the AML Program: Evaluate the overall effectiveness of AML controls and procedures.

9. Consequences of Non-Compliance

Employees who fail to comply with AML policies or report suspicious activities will face disciplinary actions, which may include warnings, suspension, demotion, or termination.

10. Policy Review and Updates

Stepone Group LTD is committed to ensuring that its AML policy remains current, effective, and aligned with regulatory requirements and industry best practices. A comprehensive review of the AML policy will be conducted at least once a year. Updates to the AML policy will be implemented based on internal audit findings, employee feedback, operational improvements, and evolving regulatory standards to address any identified weaknesses or gaps in the AML framework.

Ondato.com is our trusted partner in staying updated with AML laws, providing us with the latest regulatory information and expert insights to ensure our policies and practices remain compliant and effective.