Anti-Money Laundering Policy

NXG Markets Limited is committed to effective anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. This policy outlines our procedures for preventing, detecting, and reporting money laundering and terrorist financing activities.

NXG Markets Limited holds brokerage licence T2022091 issued by the Mwali International Services Authority (MISA). Our AML programme follows the Financial Action Task Force (FATF) Recommendations and applicable international AML/CTF standards.

All employees, officers, and contractors of NXG Markets are required to comply with this policy. Failure to do so may result in disciplinary action, termination, and referral to law enforcement authorities.

NXG Markets performs Customer Due Diligence on all clients before establishing a business relationship. This includes verifying the client's identity, understanding the nature and purpose of the relationship, and assessing the risk profile.

Standard CDD measures include collecting and verifying a government-issued photo identification document, proof of residential address dated within the last 3 months, and a declaration of the source of funds.

Enhanced Due Diligence (EDD) is applied to higher-risk clients, including Politically Exposed Persons (PEPs), clients from high-risk jurisdictions, and clients with complex or unusual transaction patterns. EDD involves additional documentation, more frequent monitoring, and senior management approval.

NXG Markets conducts continuous monitoring of client transactions to detect unusual or suspicious activity. Our automated monitoring systems flag transactions that deviate from established patterns or exceed predefined thresholds.

Key monitoring indicators include: unusually large deposits or withdrawals, frequent deposits followed by immediate withdrawal without significant trading activity, deposits from multiple unrelated sources, and transactions inconsistent with the client's stated financial profile.

Our compliance team reviews flagged transactions and conducts periodic reviews of client accounts, with higher-risk accounts reviewed more frequently. Client risk assessments are updated regularly based on ongoing monitoring results.

All employees are required to report any suspected money laundering or terrorist financing activity to the designated Money Laundering Reporting Officer (MLRO). Reports should be made immediately upon forming the suspicion.

The MLRO evaluates all internal reports and, where appropriate, files Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) with the relevant Financial Intelligence Unit (FIU) in the applicable jurisdiction.

Tipping off — informing a client or third party that a suspicious activity report has been made or that a law enforcement investigation is underway — is a criminal offense. All employees must exercise extreme caution in their communications.

NXG Markets maintains comprehensive records of all client identification documents, transaction records, account files, and internal correspondence related to AML compliance for a minimum period of 5 years following the termination of the business relationship.

Records are stored securely in encrypted databases with access restricted to authorized compliance personnel. Records must be sufficient to permit reconstruction of individual transactions and to support any regulatory inquiry or investigation.

All clients and beneficial owners are screened against international sanctions lists at the time of onboarding and on an ongoing basis. Lists screened include the United Nations Security Council sanctions, OFAC Specially Designated Nationals (SDN) list, EU Consolidated List, and UK HM Treasury sanctions.

Matches or potential matches are escalated to the compliance team for review and resolution. Services are not provided to individuals or entities on any applicable sanctions list, and existing relationships are terminated immediately upon confirmation of a sanctions match.

NXG Markets identifies Politically Exposed Persons (PEPs) through screening during onboarding and through ongoing monitoring. PEPs include current or former senior government officials, their family members, and close associates.

PEP relationships require senior management approval, Enhanced Due Diligence, verification of the source of funds and source of wealth, and ongoing enhanced monitoring. PEP status is reviewed annually.

All NXG Markets employees receive comprehensive AML/CTF training upon joining the company and annual refresher training thereafter. Training covers the legal framework, red flags for suspicious activity, internal reporting procedures, and the consequences of non-compliance.

Specialized training is provided to employees in client-facing, compliance, and senior management roles. Training records are maintained and reviewed as part of our internal audit program.

Our AML program is subject to independent internal audit on an annual basis. The audit assesses the effectiveness of our controls, the adequacy of our monitoring systems, and compliance with regulatory requirements.

Audit findings are reported to senior management and the board. Corrective actions are tracked and implemented within defined timelines. The MLRO provides quarterly compliance reports to the board of directors.