Legal Documentation

1. Introduction

Hola Prime Markets ("the Company") is committed to full compliance with all applicable Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and sanctions laws and regulations in every jurisdiction in which it operates. This policy outlines the Company's framework for preventing, detecting, and reporting any suspected money laundering or terrorist financing activity. It applies to all employees, officers, directors, contractors, agents, and business partners. Compliance with this policy is mandatory to protect our business, clients, and the integrity of the global financial system.

1.1 Between the Company and its clients.

1.2 Between one client and another.

Our objective is to ensure that all clients are treated fairly, that no client is disadvantaged over another, and that any potential conflicts are handled in a way that protects client interests and complies with applicable laws and regulations.

2. Scope

This AML Policy applies to:

2.1 All Company employees, management, and directors.

2.2 All associated persons, including contractors, consultants, intermediaries, and business partners.

2.3 All client interactions, transactions, and services offered by Hola Prime Markets.

The Company adopts a risk-based approach that may exceed local legal requirements to ensure robust financial crime prevention.

3. Policy Objectives

The main objectives of this AML Policy are to:

3.1 Prevent the use of the Company's services for money laundering, terrorist financing, or sanctions evasion.

3.2 Detect and investigate suspicious transactions or client behavior.

3.3 Comply with all relevant international AML/CTF obligations.

3.4 Maintain the highest level of operational, ethical, and financial integrity.

4. Definitions

4.1 Money Laundering (ML) - Concealing the origin of funds derived from criminal activities, typically through three stages:

4.1.1 Placement - Introducing illicit funds into the financial system.

4.1.2 Layering - Moving funds through multiple transactions to obscure their source.

4.1.3 Integration - Reintroducing funds into the economy to make them appear legitimate.

Terrorist Financing (TF) - Providing funds or financial support to terrorist organizations or activities.

5. Risk Assessment

The Company continuously evaluates potential risks associated with:

5.1 Complex or unusual transactions without clear economic purpose.

5.2 Clients from high-risk jurisdictions or using high-risk payment methods.

5.3 Use of third-party accounts or intermediaries.

5.4 Sudden, unexplained changes in trading volume or patterns.

6. Prohibited Clients and Transactions

The Company will not conduct business with:

6.1 Individuals or entities on international sanctions lists (OFAC, EU, UK, UN, FATF).

6.2 Clients providing false, stolen, or unverifiable identity documents.

6.3 Clients refusing to disclose the source of funds.

6.4 Clients involved in criminal activity, including ransomware, fraud, or corruption.

All suspicious accounts will be reported to the Chief Compliance Officer (CCO) and may be referred to relevant authorities.

7. Customer Due Diligence (CDD) and Know your Customer (KYC)

7.1 The Company applies a Know Your Customer (KYC) process before establishing a business relationship, including:

7.1.1 Verification of identity using government-issued documents.

7.1.2 Verification of residential address.

7.1.3 Verification of Liveliness

7.1.4 Assessment of the source of funds and wealth.

7.2 Enhanced Due Diligence (EDD) applies to high-risk clients, such as:

7.2.1 Politically Exposed Persons (PEPs).

7.2.2 Clients from FATF-listed jurisdictions.

7.2.3 Clients engaging in unusually large or complex transactions.

7.3 EDD measures may include:

7.3.1 Additional documentation (bank statements, tax returns, proof of income).

7.3.2 Ongoing monitoring of transactions.

7.3.3 Senior management approval before account opening.

8. Transaction Monitoring

The Company monitors client transactions on an ongoing basis to identify:

8.1 Large, frequent, or unusual deposits/withdrawals.

8.2 Transactions inconsistent with the client's profile.

8.3 Movement of funds through multiple jurisdictions without clear justification.

9. Payments and Withdrawals

9.1 All withdrawals must be made to the same payment method and account used for deposits.

9.2 Payments to or from third parties are strictly prohibited.

9.3 Any deviation from standard withdrawal procedures will require compliance review and approval.

10. Vendor and Partner Due Diligence

Before engaging with payment processors, liquidity providers, or other service partners, the Company:

10.1 Verifies their AML/CTF compliance framework.

10.2 Conducts risk assessments on the partner's operations.

10.3 Requires contractual AML compliance commitments.

11. Training and Awareness

All employees engaged in financial operations receive regular AML training covering:

11.1 Legal and regulatory obligations.

11.2 How to identify suspicious activity.

11.3 Internal reporting procedures.

12. Reporting Suspicious Activity

Employees and associated persons must report suspected money laundering or terrorist financing activities to the Chief Compliance Officer immediately.

Reports can be sent confidentially to: contactus@holaprimemarkets.com.

13. Investigation and Enforcement

13.1 All reports are reviewed by the CCO and may be escalated to the appropriate regulatory or law enforcement agencies.

13.2 Employees found in breach of this policy may face disciplinary action, including termination.

13.3 The Company enforces a zero-retaliation policy against whistleblowers acting in good faith.

14. Amendments and Updates

Hola Prime Markets reserves the right to update or amend this AML Policy in line with regulatory changes or internal risk assessments.