Sizex AML POLICY

1. PURPOSE

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy seeks to mitigate risks associated with money laundering and other illegal activities at Sizex LLC. This document provides a high-level overview, highlighting the essential principles of our internal policy. For the full policy details, please contact our customer support team.
Sizex is required by both domestic and international regulations to establish robust internal processes and systems that prevent money laundering, terrorist financing, drug trafficking, human trafficking, proliferation of weapons of mass destruction, corruption, and bribery. Additionally, Sizex must respond appropriately to any suspicious activity detected within its user base. This AML/KYC Policy covers the following areas:

• Designating a Money Laundering Reporting Officer (MLRO) and ensuring that employees report any suspicious activities to the MLRO.
• Clearly defining the responsibilities of senior management and updating them regularly on the risks associated with money laundering.
• Regularly reviewing and updating anti-money laundering policies, procedures, and controls.
• Reporting suspicious activities to the relevant authorities.
• Establishing policies to incorporate anti-money laundering awareness into the company’s daily operations.
• Providing comprehensive training to relevant personnel on their roles in combating money laundering.
• Responding promptly to any inquiries from regulatory authorities.

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2. ANTI-MONEY LAUNDERING OFFICER

The responsibility for meeting Anti-Money Laundering (AML) compliance requirements ultimately rests with the Money Laundering Reporting Officer (MLRO). For clarity in this policy, "Money Laundering Reporting Officer" and "MLRO" refer to the same role. The MLRO is granted the necessary authority and access to essential information to perform their duties effectively.
To reach our compliance department, please contact us via email at: [email protected].

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3. CORE PRINCIPLES

Before executing any transaction for a new User, Sizex must implement and maintain the following procedures:

• AML measures including customer identity verification, record-keeping, and monitoring and handling of unusual or suspicious transactions.
• Providing training to designated employees.
• Directing any relevant inquiries from external parties to the Money Laundering Reporting Officer (MLRO).
• Ensuring that all employees are familiar with their roles and the company’s AML policies.

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4. TRANSACTION SURVEILLANCE

Continuous monitoring of customer accounts and transactions is vital for managing money laundering and terrorist financing risks. The MLRO is responsible for establishing and improving the company’s transaction monitoring procedures.
Sizex’s approach to transaction monitoring is built on principles of accuracy and timeliness to ensure the safety and integrity of client transactions.

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5. IDENTITY VERIFICATION (KYC)

Documents received for the purpose of identifying new users must credibly confirm the user’s claimed identity and demonstrate that they are a legitimate individual or legal entity. Although the company may seek external assistance in verifying identities during the onboarding process, it remains fully accountable for the verification process and compliance with regulatory requirements.
All personal information gathered will be handled in strict compliance with Sizex’s Privacy Policy and applicable legislation, including the General Data Protection Regulation (GDPR).

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6. SANCTION COMPLIANCE

Sizex LLC strictly adheres to international sanctions regulations, prohibiting business transactions with individuals, entities, or countries targeted by international sanctions. These sanctions, imposed by global authorities like the United Nations, the European Union, FATF and other relevant bodies, aim to prevent financial and commercial dealings with parties engaged in illegal activities or posing risks to global peace and security.
Sizex has implemented robust systems and procedures to screen transactions, counterparties, and users against sanction lists. These lists identify individuals, entities, and countries subject to sanctions for involvement in activities such as money laundering, terrorism, human rights abuses, or proliferation of weapons of mass destruction.
If a user, counterparty, or transaction is found to violate international sanctions, Sizex will promptly suspend it and notify the appropriate regulatory bodies. Compliance with sanctions is a top priority within Sizex's risk management strategy, and employees are trained to uphold these policies.
Through strict enforcement of sanction legislation, Sizex actively contributes to international efforts to prevent illegal activities and safeguard the integrity of the financial system.

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7. RESTRICTED JURISDICTIONS

To comply with anti-money laundering regulations, Sizex LLC does not provide services to individuals in specific countries where there is a heightened risk of money laundering or where conducting business is prohibited or illegal.
These restricted countries are identified based on evaluations by international organizations specializing in anti-money laundering and regions where Sizex’s services may be misused for illicit activities.
A detailed list of restricted jurisdictions can be found within the comprehensive AML Policy, which is available upon request. This list is subject to modification by the MLROand may be updated in response to regulatory changes or policy adjustments. Any changes to the restricted jurisdictions list will be effective immediately upon amendment.
By restricting services to users in these jurisdictions, Sizex aims to reduce the risk of money laundering and ensure compliance with all applicable regulations.

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8. RISK-BASED APPROACH

Sizex adopts a risk-based approach, focusing on areas with higher risks of money laundering and terrorist financing.
The MLROis responsible for continuously monitoring and evaluating the effectiveness of the policies and procedures within this framework.
The AML Policy outlines key components of this risk-based approach, including:

• Empowering the board of directors to modify policies, procedures, and controls to align with company needs.
• Allowing the board to categorize clients based on the specific risks each poses.
• Enhancing the cost-effectiveness of compliance systems.
• Prioritizing actions based on the assessed risk of money laundering and terrorist financing.
• Recognizing that different clients, countries, services, and financial instruments present varying levels of risk.

The risk-based approach outlined in this Policy includes targeted measures to detect and address risks associated with money laundering and terrorist financing, allowing Sizex to operate both effectively and cost-efficiently.

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9. CONTACT INFORMATION

If you have questions or concerns regarding the Anti-Money Laundering Policy, or if you need further assistance, please reach out to our dedicated compliance team via email at [email protected].
Our compliance department is available to answer policy-related questions, provide guidance on compliance matters, and assist with issues or suspicious activities as they arise. We encourage users to report any suspicious transactions or behavior related to our services promptly, as your vigilance is essential to maintaining a safe and compliant environment.
Thank you for your trust in Sizex. We are committed to adhering to the latest anti-money laundering and compliance standards to ensure a secure operational framework.