Anti-Money Laundering (AML) Policy

At Trinity Funding, we are committed to maintaining the highest standards of integrity and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. Our policy is designed to prevent and mitigate the risks of money laundering, terrorism financing, and other financial crimes, in accordance with applicable laws and international guidelines.

1. Compliance with Laws and Regulations

Trinity Funding adheres to the anti-money laundering legislation of [Your Location] and complies with international standards set forth by organizations such as the Financial Action Task Force (FATF). Our AML program is designed to meet or exceed these legal requirements to ensure we operate securely and ethically.

2. Customer Due Diligence (CDD) and Know Your Customer (KYC)

We employ a rigorous Know Your Customer (KYC) process to verify the identity of our customers. During onboarding and periodically throughout the customer relationship, Trinity Funding requires customers to provide valid identification and proof of address. This information helps us assess and manage the risk of money laundering and terrorist financing.

• Enhanced Due Diligence (EDD) is performed for higher-risk clients, such as politically exposed persons (PEPs) or clients from high-risk jurisdictions.
• The customer’s risk profile is assessed and regularly reviewed to ensure ongoing compliance.

3. Monitoring and Reporting of Suspicious Activities

Trinity Funding continuously monitors transactions and account activities to identify unusual or suspicious behavior. This includes, but is not limited to, irregular transaction patterns, large or unusual withdrawals, and transactions from high-risk jurisdictions.

If any suspicious activities are identified, we are required to:

• Report such activities to the appropriate regulatory authorities without notifying the client (in compliance with local and international laws).
• Our AML Compliance Officer is responsible for ensuring that suspicious transactions are escalated and reported appropriately.

4. Record Keeping

We maintain comprehensive records of customer identification, transactions, and related documents as required by law. These records ensure full traceability and accountability of all financial transactions and activities within Trinity Funding.

5. Restricted Jurisdictions

Trinity Funding restricts access to its services from certain high-risk jurisdictions. The list of restricted countries is periodically updated based on regulatory requirements and internal risk assessments. Customers from these jurisdictions are not permitted to open accounts or engage in trading activities with Trinity Funding.

6. Training and Awareness

All employees at Trinity Funding undergo regular AML and CTF training. This training ensures that staff members are equipped to:

• Identify potential signs of money laundering and terrorist financing.
• Follow proper procedures for reporting suspicious activity.
• Understand the legal obligations surrounding AML compliance.

7. Risk-Based Approach

We employ a risk-based approach to manage our AML program effectively. This approach allows Trinity Funding to:

• Identify and assess the money laundering and terrorist financing risks specific to our business.
• Implement proportionate measures to mitigate those risks.
• Prioritize resources to focus on higher-risk customers and transactions.

8. Non-Compliance and Disciplinary Actions

Non-compliance with this AML policy, or any applicable AML laws and regulations, may result in disciplinary actions for employees, termination of customer accounts, and legal consequences as applicable. Trinity Funding reserves the right to refuse or terminate business relationships if a customer is found to be involved in money laundering or any other criminal activity.

9. Ongoing Review and Updates

Trinity Funding is committed to ensuring that our AML policies and procedures are up to date and effective. The AML Compliance Officer conducts periodic reviews of the policy to ensure it remains aligned with evolving regulatory requirements and industry best practices.