Anti-Money Laundering &
Counter-Terrorism Financing Policy

2Regulatory Framework

Capitals.au states that its compliance framework includes:

3KYC — Know Your Customer

All clients may be required to complete identity verification before accessing regulated or restricted services. KYC may include:

• Government-issued photo identification
• Proof of address
• Source of funds
• Source of wealth
• Financial information
• Beneficial ownership
• PEP screening
• Sanctions screening

4Identity Verification

Acceptable identification may include:

• Passport
• National identity card
• Driver's licence
• Other government-issued identification

Documents must generally be:

• Valid
• Unexpired
• Authentic
• Readable
• Consistent with information provided

5Proof of Address

We may require:

• Utility bills
• Bank statements
• Government correspondence
• Other acceptable documents

Documents may generally be required to be issued within the preceding three months. These requirements reflect the current Capitals.au AML Policy.

6Source of Funds

We may require evidence demonstrating the legitimate origin of funds. Examples include:

• Salary records
• Bank statements
• Business records
• Investment proceeds
• Asset-sale documentation
• Inheritance documentation

7Source of Wealth

Higher-risk clients may be required to explain the origin of their overall wealth.

8Customer Risk Classification

Clients may be classified as:

The current Capitals.au policy uses Standard, Medium and High Risk/EDD categories.

9Enhanced Due Diligence

EDD may be required for:

• PEPs
• High-risk jurisdictions
• Complex ownership structures
• Adverse media
• Unusual activity
• High-value transactions

10Politically Exposed Persons

PEPs include certain:

• Government officials
• Political figures
• Senior military officials
• Senior state-owned enterprise executives
• Family members
• Close associates

PEPs may require:

• Senior management approval
• Enhanced due diligence
• Enhanced transaction monitoring

11Sanctions Screening

Clients may be screened against:

• OFAC
• United Nations
• European Union
• Australian DFAT
• HM Treasury
• Other applicable sanctions lists

Screening may take place:

• During onboarding
• Periodically
• During transactions
• Following sanctions-list updates

12High-Risk and Prohibited Jurisdictions

Capitals.au may refuse clients from jurisdictions subject to:

• Comprehensive sanctions
• Applicable regulatory restrictions
• FATF high-risk designations
• Other significant AML/CTF concerns

The current site states that its prohibited-jurisdiction list is reviewed and updated regularly.

13Beneficial Ownership

For corporate Accounts, we may identify:

• Directors
• Shareholders
• Controlling persons
• Beneficial owners
• Authorised representatives

Complex or opaque ownership may trigger EDD.

14Transaction Monitoring

Capitals.au may continuously monitor Accounts and transactions for unusual or suspicious behaviour. Monitoring may identify:

• Unusual deposits
• Rapid deposits and withdrawals
• Unexplained transfers
• Third-party payments
• Inconsistent trading activity
• Structuring
• Unusual cryptocurrency transactions
• Activity inconsistent with the client's profile

The current AML Policy states that automated transaction monitoring and periodic KYC/risk-profile reviews are used.

15Suspicious Activity

Potentially suspicious activity may include:

• Unexplained deposits
• Third-party funding
• Withdrawal to unrelated accounts
• Structuring
• Fraudulent identification
• Sanctions matches
• Unexplained cryptocurrency activity
• Attempts to circumvent KYC
• Transactions inconsistent with stated financial circumstances

16Third-Party Funding

Capitals.au may restrict or reject deposits originating from third parties where ownership or source cannot be established. Additional documentation may be required.

17Withdrawals

Withdrawals may be subject to:

• Identity verification
• Payment-method verification
• AML review
• Sanctions screening
• Fraud checks

Withdrawals may be delayed or restricted where legally necessary.

18Cryptocurrency AML

Where cryptocurrency functionality is provided, additional monitoring may include:

• Blockchain transactions
• Wallet addresses
• Transaction history
• Source of cryptocurrency
• Destination addresses
• Exposure to sanctioned entities
• Exposure to high-risk services

19Fraud Prevention

Our AML controls may operate alongside fraud controls addressing:

• Account takeover
• Stolen payment methods
• Identity theft
• Fraudulent documentation
• Multiple Accounts
• Payment fraud
• Unauthorised transactions

20Suspicious Transaction Reporting

Where required by law, Capitals.au may report suspicious transactions or activity to competent authorities. The current policy identifies:

• AUSTRAC in Australia
• The National Crime Agency (NCA) for relevant UK SAR reporting

21No Tipping Off

Where prohibited by law, Capitals.au will not inform a Client that:

• A suspicious activity report has been submitted
• A regulatory investigation is taking place
• Information has been provided to authorities

22Account Restrictions

Where compliance concerns arise, Capitals.au may:

• Suspend Accounts
• Restrict transactions
• Delay withdrawals
• Request additional documents
• Reject transactions
• Terminate Accounts
• Report suspicious activity

23Ongoing Due Diligence

KYC is an ongoing process. We may request updated:

• Identity documents
• Address documents
• Source-of-funds information
• Source-of-wealth information
• Ownership information

High-risk clients may be reviewed more frequently.

24Record Keeping

We retain appropriate:

• KYC records
• Transaction records
• AML correspondence
• Risk assessments
• Compliance records

25Staff Training

Employees involved in client-facing or compliance activities receive AML/CTF training covering:

• KYC
• Suspicious activity
• Sanctions
• PEPs
• Reporting obligations
• AML procedures
• Legal consequences of non-compliance

The current policy states that training records are maintained and reviewed annually.

26Compliance Officer

The AML Compliance Officer is responsible for supporting:

• AML programme implementation
• Compliance monitoring
• Suspicious activity escalation
• Regulatory reporting
• Policy review
• Staff training

27Regulatory Cooperation

Capitals.au may cooperate with:

• ASIC
• AUSTRAC
• FCA
• AFCA where relevant
• Law enforcement
• Courts
• Tax authorities
• Sanctions authorities
• Other competent regulators

28Client Responsibilities

Clients must:

• Provide accurate information
• Provide genuine documentation
• Disclose beneficial ownership
• Provide requested source-of-funds information
• Update personal information
• Use legitimate payment methods
• Comply with AML requirements
• Not attempt to circumvent monitoring
• Not use the platform for unlawful activity

29Non-Compliance

Failure to satisfy AML requirements may result in:

• Account rejection
• Account suspension
• Transaction restrictions
• Withdrawal delays
• Account closure
• Regulatory reporting

30Policy Review

This Policy may be reviewed and amended to reflect:

• Legislative changes
• Regulatory developments
• Sanctions changes
• Emerging financial-crime risks
• New products
• New technologies
• Changes to the Capitals.au business

31Contact

32Regulatory Statement

Capitals.au currently identifies the following regulatory and compliance relationships:

These regulatory references are based on the current Capitals.au website disclosures.