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AML & CTF Policy

Anti-Money Laundering and Counter-Terrorism Financing Policy

1. Introduction

YaOptions (the "Platform"), operated by YaMarkets Limited, is incorporated in St. Vincent & the Grenadines as an International Business Company with the registration number 26065 BC 2020. Our registered office is located at Suite 305, Griffith Corporate Centre, Kingstown, St. Vincent and the Grenadines.

We are committed to maintaining the highest standards in Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and overall financial crime compliance.

This Policy outlines how we detect, mitigate, and report financial crime risks as part of our operational and legal obligations.

2. Objective of YaOptions' Anti-Money Laundering (AML) / Counter-Terrorism Financing (CTF) Policy

2.1 Prevention of Money Laundering, Terrorism Financing, and Other Criminal Activities

The principal objective of YaOptions' AML/CTF Policy is to prevent and prohibit the use of its platform for any activities related to money laundering, terrorism financing, or any other illicit or criminal activities. This includes, but is not limited to, ensuring that customers do not engage in any transactions or conduct that is designed to conceal, disguise, or legitimize proceeds derived from criminal activities.

2.2 Prompt Identification and Reporting of Suspicious Transactions

YaOptions is obligated to maintain a robust mechanism for the identification, detection, and reporting of suspicious transactions. This includes monitoring user activities for patterns indicative of potential money laundering, terrorism financing, or other criminal behaviors.

2.3 Risk-Based Compliance Framework

YaOptions adopts a risk-based approach to ensure that its compliance framework is commensurate with the specific risks associated with digital options trading and virtual assets.

2.4 Training, Auditing, and Support

YaOptions recognizes that a robust compliance culture can only be achieved through a well-trained and properly supported team. All relevant staff will receive continuous AML/CTF training, regular audits will be conducted, and ongoing support will be provided.

3. Who This Policy Applies To

3.1 Users and Customers of YaOptions

All individual and institutional users who engage in digital options trading or virtual asset transactions on the YaOptions platform must comply with all relevant regulations under this policy, including adhering to KYC procedures and ensuring the legitimacy of the source of their funds.

3.2 Employees, Officers, and Directors

This policy applies to all employees, officers, and directors of YaMarkets Limited. These individuals are responsible for ensuring that all activities within the organization adhere to the principles outlined in this AML/CTF policy.

3.3 Contractors and Third-Party Service Providers

This policy extends to contractors and third-party service providers who engage with YaOptions in any capacity. These external entities must undergo appropriate due diligence and comply with AML/CTF procedures.

4. AML Compliance Oversight

YaOptions has established a dedicated AML Compliance Program managed by our AML Compliance Officer (AMLCO), who holds ultimate responsibility for ensuring that all internal procedures, policies, and operations align with applicable national and international regulations.

The AMLCO oversees day-to-day AML/CTF operations, liaises with global financial regulators and law enforcement, ensures required filings are timely and accurate, and conducts compliance training and internal audits.

5. Know Your Customer (KYC) & Customer Due Diligence (CDD)

5.1 For Individual Users

  • Full Legal Name and Date of Birth
  • Valid Government-Issued ID (passport, national ID card, or driver's license)
  • Residential Address with proof of address
  • Nationality declaration
  • Source of Funds and Occupation details

5.2 For Business Users

  • Proof of Incorporation and Registration
  • Details of Directors and Beneficial Owners
  • Registered Business Address
  • Nature of Business and Financial Operations

5.3 Enhanced Due Diligence (EDD)

For high-risk users such as Politically Exposed Persons (PEPs), users from high-risk countries, or those engaged in high-risk industries, we conduct Enhanced Due Diligence involving more detailed reviews and additional monitoring.

6. Risk-Based Approach

6.1 Customer Risk

  • Politically Exposed Persons (PEPs) - Enhanced Due Diligence required
  • Offshore Clients - Additional scrutiny for high-risk jurisdictions
  • High-Risk Clients - Case-by-case assessment and stricter measures

6.2 Geographical Risk

  • Countries with Weak AML Laws - Enhanced monitoring
  • Sanctioned and High-Risk Jurisdictions - Restricted access or denial of service

6.3 Product Risk

  • Leveraged Trading - Additional transaction monitoring
  • Digital Options - Comprehensive KYC and enhanced monitoring

7. Transaction Monitoring

YaOptions implements a comprehensive Transaction Monitoring system designed to detect, analyze, and mitigate the risk of illicit activities. The system continuously monitors all trading and wallet activity in real time:

7.1 Structuring (Smurfing)

Detection of multiple small transactions that aggregate to suspiciously large sums to avoid reporting thresholds.

7.2 Sudden Large Deposits/Withdrawals

Flagging of large transactions that deviate significantly from user's historical transaction behavior.

7.3 Privacy Coins or Mixing Services

Detection of transactions involving privacy coins (Monero, Zcash, Dash) or mixing services that obscure fund origins.

7.4 VPNs, TOR, or Obfuscating Tools

Monitoring for signs of IP address masking or attempts to conceal user identity or location.

7.5 Blacklisted Wallets or Sanctioned Entities

Cross-referencing transactions with comprehensive blacklists and sanction lists from global regulators.

8. Suspicious Activity Detection and Reporting

8.1 Investigation of the Transaction

Thorough investigation to assess the nature of suspicious activity, including transaction amount, frequency, patterns, and user profile discrepancies.

8.2 Escalation of Findings Internally

Review by AML Compliance Officer, internal escalation to senior management, and secure documentation of all investigation records.

8.3 Reporting Suspicious Activities

Preparation of internal reports that can be submitted to relevant SVG authorities or international agencies as required.

9. Sanctions Screening

All customers are screened against updated global sanctions lists at onboarding.

Real-time transaction monitoring for potential sanctions risks.

Continuous review and automatic updates to reflect latest sanctions changes.

Account freezing and service suspension for sanctions matches.

Sanctions Lists Utilized for Screening:

  • United Nations (UN) Sanctions - UN Security Council Resolutions
  • Office of Foreign Assets Control (OFAC) - Specially Designated Nationals List
  • European Union (EU) Sanctions - EU-restricted individuals and entities
  • Other International Sanctions Lists - Based on emerging risks and business operations

All customers are screened against updated global sanctions lists at onboarding.

Real-time transaction monitoring for potential sanctions risks.

Continuous review and automatic updates to reflect latest sanctions changes.

Account freezing and service suspension for sanctions matches.

10. Training & Awareness

10.1 Onboarding AML/CTF Training

  • Overview of AML/CTF Legislation in SVG
  • YaOptions Internal Policies and Procedures
  • Identifying Red Flags and Suspicious Activities
  • Role of the AML Compliance Officer

10.2 Annual Refresher Training

  • Review of AML/CTF Fundamentals
  • Emerging Financial Crime Threats (DeFi, Privacy Coins, NFT Laundering)
  • Case-Based Learning and Real-World Scenarios
  • New Sanctions and Blacklists Updates

10.3 Specialized Training

  • DeFi Risks and Detection Methods
  • Privacy Coins and Obfuscation Tools
  • NFT Laundering Red Flags and Monitoring

11. Data Retention & Security

YaOptions retains all AML/CTF-related records for a minimum period of five (5) years from the date of the last transaction or end of customer relationship.

All sensitive data is encrypted both at rest and in transit using strong encryption standards.

Access to AML/CTF-related data is restricted to authorized personnel only with strict role-based access controls and multi-factor authentication.

Routine backups are performed and stored securely with continuous monitoring and audit trails.

12. Independent Audit & Program Review

YaOptions conducts an independent audit of its AML/CTF Program at least annually by external third-party auditors.

Audit findings and recommendations are shared with senior management, compliance committee, and regulatory authorities upon request.

Corrective actions are implemented promptly based on audit findings, including policy revisions, control enhancements, and targeted staff training.

13. Violations & Enforcement

YaOptions takes all violations of its AML/CTF policies with the utmost seriousness. All breaches are met with appropriate enforcement actions:

  • Account Suspension or Closure - For violations of AML/CTF policies or suspected illicit activities
  • Reporting to Authorities - Suspicious transactions reported to Financial Intelligence Unit (FIU) of SVG
  • Legal Action - Civil or criminal proceedings against individuals or entities engaged in financial crimes
  • Disciplinary Action - For employees, contractors, or vendors who violate AML/CTF obligations

14. Policy Governance & Updates

The AML/CTF Policy is formally reviewed at least once every 12 months to evaluate continued effectiveness and legal compliance.

Immediate updates are triggered by changes in laws, regulations, sanctions lists, new services, or emerging financial crime typologies.

All updates undergo legal review, senior-level approval, and clear communication to all stakeholders with training where required.

15. Contact Us

If you have any concerns or questions regarding this AML/CTF Policy, please contact us at:

support@yaoptions.com

Approved by:

Lalit Matta

Chief Executive Officer, YaOptions