ilverulls.io

ANTI-MONEY LAUNDERING (AML) POLICY

Entity Information

Entity: SILVERBULLS TECH - FZCO

Operational Name: Silverbulls.io

License Number: 60147

Jurisdiction: Dubai Integrated Economic Zones Authority (DIEZ), UAE

Introduction

SILVERBULLS TECH - FZCO ("Silverbulls.io", "we", "our") is committed to maintaining the highest standards of anti-money laundering (AML) compliance in line with the UAE Central Bank regulations, Financial Action Task Force (FATF) recommendations, and globally recognized best practices.

This AML Policy establishes principles and standards to prevent Silverbulls.io's services from being used for money laundering, terrorist financing, or other illicit financial activities.

Scope and Applicability

  • All employees, agents, and partners of Silverbulls.io.
  • All users engaging with Silverbulls.io services globally.
  • All financial transactions related to subscription charges, commission deductions, and referral payments.

Governance

  • Money Laundering Reporting Officer (MLRO): Will be appointed as customer volume scales.
  • Board Oversight: The company's directors shall oversee AML program implementation and review it annually.

Customer Acceptance Policy (CAP)

  • Only individuals/entities who fully complete registration (Name, Email, Phone) are accepted.
  • Users from sanctioned/high-risk jurisdictions (as per FATF lists) are not permitted.
  • No users engaging in privacy-enhanced cryptocurrencies (Monero, Zcash, mixers) are accepted.

Customer Due Diligence (CDD)

  • As of current operational size, only basic data (Name, Email, Phone) is collected.
  • Full KYC (government ID verification) shall be implemented upon reaching 1000 active users or $500,000 managed volume.
  • Users may be required to provide additional information if flagged manually by the internal risk team.

Enhanced Due Diligence (EDD)

  • Users demonstrating high-risk behavior (large deposits, suspicious patterns) may be subject to manual EDD procedures.
  • EDD procedures will be formalized and expanded as user volume and regulatory obligations grow.

Fund Handling and Transaction Monitoring

  • Silverbulls.io collects a pre-funded deposit (typically suggested at 10% of intended trading capital but flexible).
  • Deposits are collected through licensed payment gateways.
  • Trading funds remain directly with users at their chosen brokers (e.g., Binance).
  • No peer-to-peer transactions between users are permitted on the platform.
  • Internal ledger entries are maintained only for display and operational purposes ("wallet" statements).

Sanctions Compliance

  • Users from high-risk and sanctioned jurisdictions (e.g., Iran, North Korea, Syria) are manually restricted.
  • No active IP or VPN detection is implemented currently; this will be upgraded as necessary.

Reporting Obligations

  • Suspicious Transaction Reports (STRs) will be filed through a licensed compliance consultant when needed.
  • Staff are trained to escalate any unusual or suspicious activities to senior management.

Record Keeping

Customer data (Name, Email, Phone) and transaction records will be retained for a minimum of five (5) years after account closure, in accordance with FATF recommendations and UAE Central Bank requirements.

Internal Controls and Training

  • A formal AML Training Program will be implemented for all employees and agents as the organization scales.
  • Internal audits and risk assessments of the AML program will be conducted annually or as needed.

Future Compliance Enhancements

  • Full KYC/AML software solutions and transaction monitoring systems (e.g., ComplyAdvantage, Chainalysis) will be deployed based on user scaling or regulatory directives.
  • Sanctioned country IP geolocation blocking and VPN detection will be introduced upon operational scaling.
  • Appointment of a dedicated MLRO shall occur when user thresholds or regulatory triggers are met.

Policy Review

This policy shall be reviewed and updated annually or upon any significant change in regulatory requirements, business operations, or associated risks.

Approved by: Management of SILVERBULLS TECH - FZCO

Effective Date: May 13, 2025