Positive Compliance Policy

Introduction and Purpose

At “ITU Financial Services”, we are committed to fostering a robust and positive compliance culture that aligns with our values, mitigates risks, and ensures adherence to regulatory requirements.

This Positive Compliance Policy outlines our commitment to maintaining the highest standards of regulatory compliance, ethical conduct, and transparency in our operations as a crypto derivatives company. We strive to foster a culture of compliance that goes beyond merely adhering to legal requirements, actively promoting integrity, responsibility, and accountability at all levels of our organization.

The purpose of this policy is to:

● Establish a comprehensive framework for compliance with applicable laws, regulations, and industry best practices.

● Ensure the prevention of money laundering, terrorist financing, and other illicit activities.

● Protect the rights and interests of our users and stakeholders.

● Maintain the trust and confidence of our customers, partners, and regulators.

● Continuously improve our compliance program and adapt to evolving regulatory requirements.

Scope and Applicability

This policy applies to all employees, officers, directors, and representatives of our company, as well as any third parties acting on our behalf. It governs all aspects of our operations, including the provision of our trading platform, user onboarding, transaction monitoring, and interactions with customers and regulators.

Compliance Governance and Oversight We have established a robust compliance governance structure to oversee the implementation and effectiveness of our compliance program:

● Compliance Committee: Our Compliance Committee, composed of senior executives and compliance professionals, is responsible for setting the strategic direction of our compliance program, reviewing policies and procedures, and ensuring adequate resources are allocated to compliance functions.

● Chief Compliance Officer (CCO): The CCO is responsible for the day-to-day management of our compliance program, reporting to the Compliance Committee and the Board of Directors. The CCO has the authority and independence to effectively implement and enforce compliance policies and procedures.

● Compliance Department: Our dedicated Compliance Department, led by the CCO, is staffed with experienced professionals who are responsible for various aspects of compliance, including policy development, risk assessment, training, monitoring, and reporting.

Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT)

We are committed to preventing our platform from being used for money laundering, terrorist financing, or other illicit activities. Our AML/CFT program includes:

● Customer Due Diligence (CDD): We conduct thorough CDD on all our users, including identity verification, beneficial ownership determination, and risk assessment. Enhanced due diligence measures are applied to high-risk customers.

● Transaction Monitoring: We employ sophisticated transaction monitoring systems to detect and report suspicious activities, such as unusual transaction patterns, large volume transactions, or transactions involving high-risk jurisdictions.

● Suspicious Activity Reporting (SAR): We promptly file SARs with the relevant authorities when we identify suspicious activities or transactions that may indicate money laundering, terrorist financing, or other criminal activities.

● Sanctions Screening: We screen our users and transactions against applicable sanctions lists, including those issued by the United Nations, European Union, United Kingdom, and United States, to ensure we do not engage with sanctioned individuals or entities.

● Recordkeeping: We maintain comprehensive records of customer information, transactions, and compliance activities for the required retention periods, ensuring the availability of information for regulatory reporting and investigations.

User Onboarding and Eligibility

We have established strict user onboarding procedures and eligibility criteria to ensure the integrity of our platform and compliance with regulatory requirements:

● Age Restriction: Users must be at least 18 years old to register for an account on our platform.

● Restricted Jurisdictions: We do not provide services to users located in or residents of the Restricted Jurisdictions and Sanctioned Jurisdictions, as specified in our Restricted Jurisdiction Policy. This includes restrictions on US citizens, US residents, and Russian citizens or residents accessing our services from certain jurisdictions.

● Identity Verification: All users must undergo identity verification, providing government-issued identification documents and proof of address. We employ advanced verification technologies to validate the authenticity of user-provided information.

● Terms and Conditions: Users must agree to our Terms and Conditions, which outline their rights and responsibilities, the risks associated with trading digital assets, and the applicable legal and regulatory requirements. User Agreement Compliance We have established a comprehensive User Agreement that outlines the terms and conditions governing the use of our platform and the relationship between our company and our users:

● User Acceptance: All users are required to read, understand, and agree to our User Agreement before registering for an account and accessing our services. The User Agreement is prominently displayed during the onboarding process and is easily accessible on our website.

● Legal Binding: The User Agreement forms a legally binding contract between our company and each user. By accepting the User Agreement, users acknowledge and agree to comply with its terms and conditions, as well as any additional policies incorporated by reference.

● Key Provisions: The User Agreement covers essential aspects of the user relationship, including user eligibility, account registration, user responsibilities, trading rules, risk disclosures, intellectual property rights, data privacy, dispute resolution, and governing law. It also incorporates our AML/CFT Policy, Privacy Policy, and Restricted Jurisdiction Policy.

● Updates and Amendments: We reserve the right to update and amend the User Agreement from time to time to reflect changes in our services, regulatory requirements, or industry best practices. Any material changes to the User Agreement will be communicated to users through email, in-app notifications, or other appropriate channels, and users will be required to accept the updated agreement to continue using our services.

● Compliance Monitoring: We actively monitor user compliance with the User Agreement, using automated systems and manual reviews to detect and investigate any violations or breaches. Users found to be in violation of the User Agreement may be subject to warnings, account restrictions, suspensions, or terminations, depending on the severity and frequency of the violations.

Transaction Monitoring Compliance

We have implemented a robust transaction monitoring program to detect, investigate, and report suspicious activities and potential violations of AML/CFT regulations:

● Monitoring Systems: We employ advanced transaction monitoring systems that utilize rule-based algorithms, statistical analysis, and machine learning techniques to identify unusual or suspicious transaction patterns. These systems are calibrated to detect red flags such as structuring, layering, smurfing, and transactions involving high-risk jurisdictions or sanctioned entities.

● Risk-Based Approach: Our transaction monitoring program follows a risk-based approach, applying enhanced scrutiny to transactions and users that present higher risks of money laundering, terrorist financing, or other illicit activities. Risk factors considered include user profile, transaction volume, transaction frequency, country of origin, and counterparty information.

● Alert Investigation: When our monitoring systems generate alerts for potentially suspicious activities, our trained compliance analysts conduct thorough investigations to determine the nature and legitimacy of the transactions. Investigations may involve reviewing user information, transaction history, source of funds, and other relevant data points. Analysts document their findings and escalate cases to senior compliance staff as necessary.

● Suspicious Activity Reporting: If, after investigation, a transaction or series of transactions is deemed suspicious, we file a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) with the relevant authorities, such as the Financial Intelligence Unit (FIU) or law enforcement agencies. We provide detailed information about the suspicious activity, including user information, transaction details, and the reasons for suspicion.

● Recordkeeping: We maintain comprehensive records of all transactions, alerts, investigations, and SARs/STRs for the required retention periods, typically five years or more. These records are securely stored and readily accessible for regulatory reporting and investigations.

● Continuous Improvement: We continuously assess the effectiveness of our transaction monitoring program, incorporating feedback from regulators, industry best practices, and emerging typologies. We regularly update our monitoring systems, risk models, and investigative procedures to adapt to the evolving threats and regulatory requirements.

Trading and Risk Management

We have implemented robust trading and risk management controls to ensure the integrity of our platform and protect the interests of our users:

● Margin and Leverage: We offer perpetual futures contracts with margin trading and leverage. Users are required to maintain adequate initial and maintenance margins to sustain their positions. We provide educational resources to help users understand the risks associated with leveraged trading.

● Price Integrity: We employ advanced algorithms and market surveillance tools to detect and prevent manipulative trading practices, such as spoofing, layering, or wash trading. We actively monitor our markets to ensure fair and orderly trading.

● Risk Disclosure: We provide comprehensive risk disclosures to our users, highlighting the potential risks associated with trading digital assets and derivatives, including market volatility, counterparty risk, and leverage risks. Users are required to acknowledge and accept these risks before engaging in trading activities.

● Trade Monitoring: We continuously monitor trading activities on our platform to identify and investigate any suspicious or unusual trading patterns. We have the authority to suspend or terminate user accounts and report suspicious activities to the relevant authorities.

Compliance Training and Awareness

We are committed to fostering a culture of compliance through ongoing training and awareness initiatives:

● Employee Training: All employees, including senior management, undergo mandatory compliance training upon joining the company and on a regular basis thereafter. Training covers topics such as AML/CFT, data privacy, market integrity, and ethical conduct.

● User Education: We provide educational resources and materials to our users to help them understand the regulatory requirements, trading risks, and best practices for safe and responsible trading. This includes user guides, tutorials, and risk disclosure statements.

● Compliance Updates: We regularly communicate compliance updates and regulatory developments to our employees and users through various channels, such as email, in-app notifications, and our website, to ensure they stay informed of their compliance obligations.

Collaboration with Regulators and Law Enforcement

We maintain open and collaborative relationships with regulators and law enforcement agencies to combat financial crime and ensure the integrity of the digital asset ecosystem:

● Regulatory Engagement: We proactively engage with regulators and participate in industry initiatives to shape the evolving regulatory landscape for digital assets and derivatives. We provide input and feedback on proposed regulations and share our expertise to promote effective and proportionate regulation.

● Information Sharing: We promptly respond to requests for information from regulators and law enforcement agencies, providing the necessary data and documentation to support investigations and enforcement actions. We have established secure and efficient channels for information sharing while protecting user privacy.

● Suspicious Activity Reporting: We have procedures in place to identify and report suspicious activities to the relevant authorities, including suspicious transaction reports (STRs) and suspicious activity reports (SARs). We cooperate fully with regulators and law enforcement in their investigations and provide additional information as required.

Continuous Improvement and Review

We are committed to continuously improving our compliance program and adapting to the evolving regulatory landscape:

● Risk Assessment: We conduct regular risk assessments to identify and evaluate the compliance risks facing our business, including money laundering, terrorist financing, market abuse, and data privacy risks. The results of these assessments inform the enhancement of our compliance controls and procedures.

● Compliance Audits: We engage independent third-party auditors to conduct periodic audits of our compliance program, assessing its effectiveness and identifying areas for improvement. Audit findings are reported to the Compliance Committee and the Board of Directors, and corrective actions are promptly implemented.

● Compliance Technology: We invest in advanced compliance technology solutions, such as automated transaction monitoring systems, risk assessment tools, and data analytics platforms, to enhance the efficiency and effectiveness of our compliance program. We continuously evaluate and upgrade our technology to keep pace with industry best practices.

Conclusion

This Positive Compliance Policy reflects our unwavering commitment to maintaining the highest standards of regulatory compliance, ethical conduct, and transparency in our operations as a crypto derivatives company. We believe that a strong culture of compliance is essential for the long-term success of our business and the trust and confidence of our users, partners, and regulators.

All employees, officers, directors, and representatives of our company are required to adhere to this policy and actively contribute to the maintenance and continuous improvement of our compliance program. Violations of this policy may result in disciplinary action, up to and including termination of employment or business relationships.

We will regularly review and update this policy to ensure its continued relevance and effectiveness in light of evolving regulatory requirements and industry best practices. Any material changes to this policy will be communicated to all relevant stakeholders in a timely manner.