Trade with static drawdown on MT5 and earn up to 95% in performance rewards.

AML Policy

1. INTRODUCTION

PropXP Ltd (the “Company”), a limited liability company incorporated under Companies Act, Cap. 13.01 of the Revised Laws of Saint Lucia, with registration number 2025-00696, and its registered office at Ground Floor, Rodney Court Building, Rodney Bay, Gros Islet, Saint Lucia is committed to conducting its business in accordance with the highest standards of integrity and in compliance with applicable laws and regulations of Saint Lucia.

While the Company does not operate as a brokerage, provide investment services, or accept client deposits, it recognizes the importance of maintaining strong standards of responsible business conduct. To this end, the Company applies appropriate measures to safeguard the integrity of its operations and to align with international expectations of transparency and good practice.

The Company’s approach is guided by the principles of the Money Laundering (Prevention) Act, Cap. 12.20, the Counter-Terrorism Act, Cap. 3.16, and international standards set by the Financial Action Task Force (FATF), to the extent applicable to its business model.

2. DEFINITIONS

“User” means any individual who registers, accesses, or participates in any proprietary trading challenge, simulated trading program, or related service offered by the Company.

“Simulated Account” means a demonstration trading environment using virtual funds that does not involve real-market execution or the use of client capital.

“Funded Account” means a simulated account allocated to a User for evaluation or challenge purposes only and does not involve the deposit, holding, or trading of real client funds.

“Performance-Based Reward” means a discretionary payment made pursuant to a separate contractual agreement, based solely on simulated trading performance and not on real trading activity.

3. PURPOSE & SCOPE

The purpose of this Policy is to prevent the misuse of the Company’s services for money laundering, terrorist financing, or other unlawful activities. It sets out the principles and procedures for client identification, risk management, and ongoing compliance oversight in accordance with applicable Saint Lucian legislation and international standards.

This Policy applies to all individual users who register, access, or otherwise participate in any of the Company’s proprietary trading challenges, platforms, or related services. It extends to all stages of user interaction, including account registration, verification, participation in simulated or funded trading activities, use of educational or analytical tools, and any other engagement facilitated through the Company’s systems or associated websites.

For the purposes of this Policy, “Users” refers to all individuals who register, access, or participate in any proprietary trading challenge, platform, or service provided by the Company.

4. ONBOARDING PROCEDURE

All users must complete the following steps before participating in trading challenges or receiving any performance-based rewards:

4.1 Registration: Users register on the official platform by submitting their full name, email address, and country of residence.

4.2 Email Verification: A verification link is sent to confirm email validity and account ownership.

4.3 Identity Verification (KYC): Prior to receiving a simulated funded account or becoming eligible for any performance-based reward, users are required to submit:

  • Proof of Identity (POI): A valid government-issued identification document.
  • Proof of Residence (POR): A recent utility bill, bank statement, or government- issued letter showing name and address (dated within the last 3 months).

4.4 Screening: The Company applies additional due diligence measures. Such measures may include, but are not limited to, sanctions list screening, Politically Exposed Person (PEP) checks, and open-source or media reviews, particularly in relation to users originating from, or connected to, higher-risk jurisdictions.

All documents are subject to review and approval by the Company before a funded account can be granted.

5. AML MEASURES

Given the Company’s business model, which does not involve the handling of client funds or execution of real-market transactions, the Company is assessed as presenting a low inherent money laundering and terrorist financing risk. Although the Company does not process client funds or operate as a financial intermediary, it maintains compliance measures to mitigate legal and reputational risks:

5.1 Risk-Based Approach: Access to the Company’s services is strictly prohibited for individuals or entities located in, or otherwise associated with, any of the following:

  • Countries or territories subject to international sanctions imposed by the European Union (EU), United Nations (UN), or the Office of Foreign Assets Control (OFAC);
  • Jurisdictions identified by the Financial Action Task Force (FATF) as high-risk or non-cooperative (commonly referred to as the FATF “blacklist”);
  • Any jurisdiction in which proprietary trading programs, simulated trading, or educational trading challenges are prohibited or restricted under local laws or regulations.
  • The Company does not provide virtual asset services as defined under applicable laws, including but not limited to the exchange, transfer, custody, administration, or safekeeping of virtual assets or digital wallets. The Company does not operate as a Virtual Asset Service Provider (VASP).

The Company reserves the right to deny or terminate access if a user is found to be in breach of these restrictions.

5.2 Monitoring for Irregular Behavior:

The Company monitors accounts for unusual or suspicious patterns, including but not limited to:

  • Unusual login behavior (e.g., use of anonymizers, repeated IP changes)
  • Improper or abusive use of multiple accounts (e.g., coordinated hedging, attempts to bypass platform rules);
  • Suspicious or irregular payout activity
  • Any activity that raises suspicion will be documented and reviewed by the Compliance Officer. Where appropriate, internal Suspicious Activity Reports (SARs) will be prepared and, if warranted, submitted to the Financial Intelligence Authority (FIA) in accordance with local reporting obligations.

5.3 Record Retention: All submitted documents and correspondence are securely stored for a minimum of seven (7) years from the date of last activity.

5.4 No Client Funds Handling: The Company does not accept or hold client funds for trading purposes and does not act as a custodian, payment processor, or intermediary in relation to any third-party financial transactions.

5.5 Third-Party Payment Processing: Any performance-based rewards, where applicable, are processed through independent third-party payment service providers. The Company does not act as a payment intermediary, money transmitter, or financial institution and does not control or hold funds on behalf of Users at any stage.

6. COMPLIANCE OVERSIGHT

The Compliance Officer is responsible for:

  • Ensuring this policy is implemented and observed;
  • Overseeing KYC, monitoring, and reporting procedures;
  • Reviewing and updating this policy in accordance with the Money Laundering (Prevention) Act, Financial Intelligence Authority (FIA) directives, and evolving international AML/CFT standards;
  • Ensuring that any suspected misuse of the Company’s platform (e.g., identity fraud, sanctions evasion, or other unlawful activity) is internally escalated, documented, and, where applicable, reported to the relevant competent authority in Saint Lucia;
  • Cooperating fully with the FIA or other lawful authorities in the event of any inquiry or investigation;
  • Ensuring strict confidentiality and preventing any form of tipping-off in contravention of Section 37 of the Money Laundering (Prevention) Act.
  • Regular Training: Ensuring that relevant personnel receive periodic AML/CFT awareness training appropriate to their duties and level of exposure

The Company may cooperate with competent foreign authorities, where permissible by law, in the context of cross-border AML/CFT investigations.

7. DATA PROTECTION & CONFIDENTIALITY

All personal and identification data collected under this Policy are processed solely for compliance and verification purposes. The Company ensures such information is stored securely, accessed only by authorized personnel, and handled in accordance with applicable data protection laws. Confidentiality is maintained at all times, and no data are shared with third parties except as required by law or competent authorities.

8. POLICY REVIEW

This policy is reviewed at least annually, or more frequently in response to regulatory changes or operational shifts.

9. POLICY APPROVAL

This Policy was reviewed and approved by the Board of Directors of PropXP Ltd on 07.10.2025.