AML & KYC Policy

The purpose of this policy is to prevent the platform and its payout rails being used to launder criminal proceeds, finance terrorism, evade sanctions or move funds on behalf of a third party.

It applies to every registered trader, every payment instrument used to purchase an evaluation, every payout destination, and every member of staff involved in onboarding, payments or account administration.

Our controls are modelled on the United Arab Emirates federal anti-money-laundering framework, the rules applicable in the Dubai International Financial Centre, and the Financial Action Task Force Recommendations.

The programme is risk-based. The depth of due diligence applied to a given trader is proportionate to the risk that trader presents, assessed on residence and nationality, the payment instruments used, the size and pattern of payouts requested, screening results, and any adverse information identified.

Risk ratings are reviewed when a material change occurs, such as a change of residence, a new payment instrument, a scaling upgrade or an unusual payout pattern.

Standard due diligence is completed before a funded account is issued and before any payout is released. It cannot be deferred past those points, and an evaluation cannot be converted to a funded account while verification is outstanding.

Documents are uploaded once inside the client portal over an encrypted connection and are reviewed by the compliance desk, usually within a few hours on a business day. We do not accept identity documents by email.

• A valid government-issued photo identity document: passport, national identity card or driving licence
• A proof of address dated within the last three months: utility bill, bank statement or government correspondence
• Confirmation of date of birth, nationality and country of residence
• A liveness or selfie check where the document image quality or the risk rating requires it
• Confirmation that the payment instrument used is held in the same name as the verified identity

Enhanced due diligence is applied where a trader is resident in or connected to a higher-risk jurisdiction, where a screening result indicates a politically exposed person or a close associate of one, where adverse media is identified, or where transaction patterns are inconsistent with the profile.

Enhanced measures include obtaining additional identity evidence, establishing source of funds and where relevant source of wealth, senior compliance approval before the relationship proceeds, and more frequent ongoing review.

Being identified as a politically exposed person is not by itself a reason for refusal. It is a reason for additional scrutiny and for a documented approval decision.

Every applicant is screened at registration against United Nations, United Arab Emirates, European Union, United Kingdom and United States sanctions lists, along with politically exposed person and adverse media data. Screening is repeated periodically and whenever list data is updated.

A potential match places the account on hold immediately, before any funded status or payout is granted. Holds are investigated by the compliance desk, and a false positive is cleared with the reason recorded.

A confirmed match results in the relationship being refused or terminated, the assets concerned being frozen where required, and a report being made to the competent authority. In those circumstances we may be legally prohibited from explaining the reason to you.

Where the risk rating, the payment pattern or a screening result requires it, we will ask you to evidence the source of the funds used to purchase an evaluation, and in higher-risk cases the origin of your wealth more generally.

Acceptable evidence includes recent salary statements, an employment contract, audited business accounts, a tax return, a sale-of-asset document or a bank statement showing the originating credit. Requests are proportionate and we will explain what we need and why.

Where evidence is not provided within a reasonable period, the account is suspended and any pending payout is held until it is.

We do not open or maintain accounts for persons subject to sanctions, for persons resident in a comprehensively sanctioned jurisdiction, or for persons in a jurisdiction where offering this programme would breach local law.

We also refuse relationships involving shell entities, bearer arrangements, anonymising services that obscure the origin of a payment, and any applicant who declines to complete verification.

The restricted list is reviewed regularly and can change at short notice. Where a change makes an existing relationship impermissible, the account is closed and any legitimately earned and approved profit is paid to a verified destination where it is lawful to do so.

Payments must be made from an instrument held in the name of the registered trader. Third-party payments are rejected and will be returned to the originating instrument where possible.

Payouts are released only to an instrument or wallet already verified as belonging to the registered trader, and wherever possible to the same rail used for the original purchase. A request to pay out to a new destination triggers additional verification.

Cryptocurrency payouts are screened for exposure to sanctioned addresses, mixing services and known illicit sources before release.

Account activity is monitored on a continuing basis for patterns inconsistent with a genuine trading relationship. That includes rapid purchase and refund cycles, purchases funded from multiple unrelated instruments, payout destinations that change repeatedly, and clusters of accounts sharing device, address or payment characteristics.

Monitoring alerts are reviewed by the compliance desk. Most are resolved with a simple explanation from the trader. Where they are not, the account is escalated.

Where we know or suspect, or have reasonable grounds to suspect, that funds are the proceeds of crime or relate to terrorist financing, a suspicious activity report is filed with the competent financial intelligence unit.

Reporting obligations override our duty of confidentiality to you. Where a report has been made, applicable law generally prohibits us from telling you that it has been made or from disclosing the content of it. This is commonly described as the prohibition on tipping off.

A report is not an accusation and does not by itself result in account closure. It is a legal obligation triggered by a threshold of suspicion.

Identity documents, verification decisions, screening results, source-of-funds evidence and transaction records are retained for a minimum of six years after the end of the business relationship, or longer where an authority directs it or where records are relevant to ongoing proceedings.

Records of internal escalations and of suspicious activity reports are retained on the same basis and held with restricted access.

Retention under this policy takes precedence over a deletion request made under the Privacy Policy. Where that applies we restrict processing to the compliance purpose and tell you which category the restriction falls under.

We may refuse an application, suspend an account or terminate a relationship where verification cannot be completed, where documents appear altered, where a sanctions match is confirmed, where source of funds cannot be evidenced, or where the pattern of activity remains unexplained after enquiry.

Where an account is closed for a compliance reason and it is lawful to do so, verified profit already approved is paid to a verified destination and any unused evaluation fee is treated under the Refund Policy. Where the law prohibits payment, funds are held or remitted as directed by the competent authority.

Every member of staff with access to onboarding, payments or account administration completes anti-money-laundering training on joining and at least annually thereafter, covering typologies relevant to funded trading, sanctions obligations and internal escalation.

Controls are documented, access to compliance systems is restricted to named individuals with multi-factor authentication, and every compliance decision is recorded in an audit trail with its reason.

The compliance function within the Payments and Treasury desk is accountable for this programme, reports to the firm's senior management, and maintains independence in escalation and reporting decisions.

The policy is reviewed at least annually and whenever the applicable framework changes materially. Independent testing of the controls is commissioned periodically and findings are tracked to closure.

Questions about verification, a document request or an account hold should be raised as a ticket in the client portal or sent to support@connectfunded.com, marked for the attention of the compliance desk.

Where we cannot explain the reason for a decision, it is because disclosure is legally restricted rather than because a reason does not exist.