ANTI MONEY LAUNDERING POLICY

Fortuno Markets collects and verifies the personal identification data of our account holders, while
logging and tracking itemised statements of all the transactions that are carried out by our clients. Prior
to opening an account with Fortuno Markets a valid form of government-issued identification (Driver's
License, State ID, or Passport), a proof of residence, and bank account information is required, along
with your completed account application. Additionally, Fortuno Markets tracks all suspicious transactions
of our clients, and transactions executed under non-standard trading conditions.

The International Money Laundering Abatement and Anti-Terrorist Financing Act 2001 (“Act”) which
commit of responsibility on all financial institutes for detection, prevention and report any disguise
activities illegal money. Under this Act, money laundering is explained as the act of converting money or
other material values gained from illegal activities such as terrorism, drug dealing, illegal arms trade,
corruption, human traffic and etc. into money or investments that appear to be legitimate. Fortuno
Markets vows to comply with the above regulation with full attention and no compromise with any of the
above illegal activities.

In order to confront the penetration of criminal money into state economy and to prevent expansion of
terrorist activity, countries carry on a struggle against money laundering and terrorism financing. Financial
organizations are one of the easiest of access and convenient instruments that allow to legalise revenue
from illegal activity. The increased integration of financial markets and liberty of capital mobility between
them make market penetration of criminal capital easier. Thereat Fortuno Markets applies by-law and
programs of its implementation to help international organizations to struggle against money
laundering andfinancing of terrorist activity all over the world.

1. SCOPE OF POLICY

This policy applies to all Fortuno Markets officers, employees, appointed producers and products and
services offered by Fortuno Markets. All business units and locations within Fortuno Markets will
cooperate to create a cohesive effort in the fight against money laundering. Each business unit and
location has implemented risk-based procedures reasonably expected to prevent, detect and cause the
reporting of transactions. All efforts exerted will be documented and retained. The AML Compliance
Committee is responsible for initiating Suspicious Activity Reports ("SARs") or other required reporting to
the appropriate law enforcement or regulatory agencies. Any contacts by law enforcement or regulatory
agencies related to the Policy shall bedirected to the AML Compliance Committee.

The committee shall

i. Receive internal reports of (suspicions of) money laundering
ii. Investigate reports of suspicious events

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 iii. Make reports of relevant suspicious events to the relevant authorities
iv. Ensure the adequacy of arrangements made for the awareness and training of staff and advisers
v. Report at least annually to the firm’s governing body on the operation and effectiveness of the
firm’s systems and controls.
vi. Monitor the day-to-day operation of anti-money laundering policies in relation to: the
development of new products; the taking on of new customers; and changes in the firm’s business
profile.

2. POLICY

It is the policy of Fortuno Markets to actively pursue the prevention of money laundering and any activity
that facilitates money laundering or the funding of terrorist or criminal activities. Fortuno Markets is
committed to AML compliance in accordance with applicable law and requires its officers, employees and
appointed producers to adhere to these standards in preventing the use of its products and services for
money laundering purposes.

For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to
conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to
have been derived from legitimate origins or constitute legitimate assets.

3. WHAT IS MONEY LAUNDERING?

Money laundering is the process by which criminally obtained money or other assets (criminal property)
are exchanged for “clean” money or other assets with no obvious link to their criminal origins.
Criminal property may take any form, including money or money’s worth, securities, tangible property
and intangible property. It also covers money, however come by, which is used to fund terrorism.

Money laundering activity includes:

i. Acquiring, using or possessing criminal property
ii. Handling the proceeds of crimes such as theft, fraud and tax evasion
iii. Being knowingly involved in any way with criminal or terrorist property
iv. Entering into arrangements to facilitate laundering criminal or terrorist property
v. Investing the proceeds of crimes in other financial products
vi. Investing the proceeds of crimes through the acquisition of property/assets
vii. Transferring criminal property.

There is no single stage of money laundering; methods can range from the purchase and resale of luxury
items such as a car or jewellery to passing money through a complex web of legitimate operations. Usually
the starting point will be cash but it is important to appreciate that money laundering is defined in terms
of criminal property. This can be property in any conceivable legal form, whether money, rights, real estate
or any other benefit, if you know or suspect that it was obtained, either directly or indirectly, as a result
of criminal activity and you do not speak up then you too are taking a part in the process.

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The money laundering process follows three stages:
i. Placement
Disposal of the initial proceeds derived from illegal activity e.g. into a bank account.
ii. Layering
The money is moved through the system in a series of financial transactions in order to disguise
the origin of the cash with the purpose of giving it the appearance of legitimacy.
iii. Integration
Criminals are free to use the money as they choose once it has been removed from the system
as apparently “clean” funds.

No financial sector business is immune from the activities of criminals and Firms should consider the
money laundering risks posed by the products and services they offer.

4. WHAT IS COUNTER TERRORIST FINANCING (CTF)?

Terrorist financing is the process of legitimate businesses and individuals that may choose to provide
funding to resource terrorist activities or organizations for ideological, political or other reasons. Firms
must therefore ensure that: (i) customers are not terrorist organizations themselves; and (ii) they are not
providing the means through which terrorist organizations are being funded.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the
origin or intended use of the funds, which will later be used for criminal purposes.

5. RISK BASED APPROACH

The level of due diligence required when considering anti-money laundering procedures within the firm, it
should take a risk-based approach. This means the amount of resources spent in conducting due diligence
in any one relationship that is subject risk should be in proportion to the magnitude of the risk that is
posed by that relationship.

These can be broken down into the following areas:

i. Customer Risk
Different customer profiles have different levels of risks attached to them. A basic Know your
Customer (KYC) check can establish the risk posed by a customer. For example, near-retired
individuals making small, regular contributions to a savings account in line with their financial
details poses less of a risk than middle-aged individuals making adhoc payments of ever-changing
sizes into a savings account that does not fit into the profile of the customers’ standing financial
data. The intensity of the due diligence conducted on the latter would be higher than that carried
out on the former as the potential threat of money laundering in the second case would be
perceived as being greater. Corporate structures can be used as examples of customers that could
carry a higher risk profile than the one just seen, as these can be used by criminals to introduce

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 layers within transactions to hide the source of the funds, and like that, clients can be categorized
into different risk bands.
ii. Product Risk
This is the risk posed by the product or service itself. The product risk is driven by its functionality
as a money-laundering tool. The Joint Money Laundering Steering Group has categorized the
products with which Firms typically deal into three risk bands – reduced, intermediate and
increased. Typically, pure protection contracts are categorized as reduced risk and investments
in unit trusts as increased risk. Additionally, a factor that will contribute to the classification of the
risk category is sales process associated with the product. If the transaction in the product takes
place on an advisory basis as a result of a KYC, this will carry less risk than an execution only
transaction, whereby you know significantly less about the customer.
iii. Country Risk
The geographic location of the client or origin of the business activity has a risk associated with
it, this stem from the fact that countries around the globe have different levels of risk attached to
them.
iv. A firm would determine the extent of their due diligence measure required initially and on an
ongoing basis using the above four risk areas.

6. CUSTOMER IDENTIFICATION PROGRAM

Fortuno Markets has adopted a Customer Identification Program (CIP). Fortuno Markets will provide
notice that they will seek identification information; collect certain minimum customer identification
information from eachcustomer, record such information and the verification methods and results.

7. FORTUNO MARKETS’S AML POLICIES

i. Client funds are held in separate, segregated accounts that are designated only for client deposits
and withdrawals.
ii. Monitors funding from various bank accounts outside of the account holder's home country.
iii. Neither accepts cash deposits nor disburses cash under any circumstances.
iv. Does not accept third-party deposits of any kind.
v. Matches each deposit to the account name on file for that customer.

Fortuno Markets reserves the right to refuse processing a transaction at any stage where it believes the
transaction to be connected in any way to money laundering or criminal activity. In accordance with
international law, Fortuno Markets is not obligated to inform the client if suspicious activity is reported to
any corresponding regulatory or legal bodies.

8. ACCOUNT OPENING PROCEDURES

Prior to opening an account, Fortuno Markets shall document the identity, nature of business, income,
sourceof assets, and investment objectives of each prospective customer.

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While we welcome clients from all over the globe, governmental restrictions along with our company
policies prohibit Fortuno Markets from opening accounts originated from restricted and/or OFAC
sanctioned countries.

9. ACCOUNT OPENING REQUIREMENTS

Photo ID - The following are acceptable forms of photo identification

i. A valid Passport
ii. A valid Government ID (Driver's License or State issued ID)
iii. A valid National Identity Card

Proof of Residence - The following are acceptable forms of proof or residence

i. A utility or phone bill, or a bank statement containing your current address
ii. All proof of residences must be current and no older than 90 days

10. BANK ACCOUNT REQUIREMENTS

All Fortuno Markets account holders must have a valid bank or credit card account in their name. The
bank statement should show their name and the same registered address as their application.

11. NOTICE TO CUSTOMERS

Fortuno Markets will provide notice to customers that it is requesting information from them to verify
their identities, as required by applicable law.

12. KNOW YOUR CUSTOMER

When a business relationship is formed, in order to establish what might constitute normal activity later
in the relationship, it is necessary for the company to ascertain the nature of the business a client expects
to conduct.

Once an on-going business relationship has been established, any regular business undertaken for that
customer can be assessed against the expected pattern of activity of the customer. Any unexplained
activity can then be examined to determine whether there is a suspicion of money laundering or terrorist
financing.

Information regarding a client’s income, occupation, source of wealth, trading habits and the economic
purpose of any transaction is typically gathered as part of the provision of advice. At the start of the
relationship personal information is also obtained, such as, nationality, date of birth, and residential
address. These pieces of information should also be considered in respect to the risk of financial crime

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(including AML and CTF). For high-risk transactions, it might be appropriate to seek verification of the
information the client has provided.

13. CUSTOMERS WHO REFUSE TO PROVIDE INFORMATION

If a customer either refuses to provide the information described above when requested, or appears to
have intentionally provided misleading information, the appointed agent shall notify their New Business
team. Fortuno Markets will decline the application and notify the AML Compliance Committee.

14. SOURCE OF FUNDS

When a transaction takes place, the source of funds, i.e. how the payment is to be made, from where and
by whom, must always be ascertained and recorded in the client file (this would usually be achieved
through retaining a copy of the cheque or direct debit mandate).

15. VERIFICATION

Fortuno Markets will document its verification, including all identifying information provided by the
customer, the methods used and results of the verification, including but not limited to sign- off by the
appointed producer of matching photo identification.

In verifying customer identity, appointed producers shall review photo identification. Fortuno Markets
shall not attempt to determine whether the document that the customer has provided for identification
has beenvalidly issued.

For verification purposes, Fortuno Markets shall rely on a government-issued identification to establish a
customer’s identity. Fortuno Markets however, will analyse the information provided to determine if
there are any logical inconsistencies in the information obtained.

Verification of the information obtained must be based on reliable and independent sources– which might
either be documents produced by the customer, or electronically by the firm, or by a combination of both.
Where business is conducted face-to-face, firms should see originals of any documents involved in the
verification.

If documentary evidence of an individual’s identity is to provide a high level of confidence, it will typically
have been issued by a government department or agency, or by a court, because there is a greater
likelihood that the authorities will have checked the existence and characteristics of the persons concerned.
In cases where such documentary evidence of identity may not be available to an individual, other
evidence of identity may give the firm reasonable confidence in the customer’s identity, although the firm
should weigh these against the risks involved.

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16. IDENTIFICATION

The standard identification requirement for customers who are private individuals are generally governed
by the circumstances relating to the customer and the product type that is being dealt in, i.e. the level of
risk attributed to the product whether it is a reduced risk, intermediate risk or an increased risk product.
Taking that into account for reduced risk and intermediate risk products the following pieces of information
are required as a standard for identification purposes:

If the identity is to be verified from documents, this should be based on:

Either a government issued document, which incorporates:

i. The customer’s full name, and
ii. Their residential address

Photographic Government Issued Identity Documents

i. Valid passport
ii. National Identity card
Alternatively, this can be done by a non-photographic government issued document, which incorporates
the customer’s full name, supported by a second document, which incorporates:
i. The customer’s full name, and
ii. Their residential address

17. EVIDENCE OF ADDRESS

i. Current bank statements, or credit/debit card statements, issued by a regulated financial sector
firm (but not ones printed off the internet and not less than 3 months old)
ii. Utility bills (not including mobile phone bills, not ones printed off the internet and not less than 3
months old)

For increased risk level products, in addition to obtaining the standard information detailed above, the
following know your customer information should be obtained and recorded:
i. As Employment and income details
ii. Source of wealth (i.e. source of the funds being used in the transaction)

18. MONITORING AND REPORTING

Fortuno Markets collects and verifies identification data of the Client and also logs and tracks itemized
statements of all transactions carried out by the Client.

If Fortuno Markets tracks suspicious transactions of the clients and transactions executed under
nonstandard conditions. The Company performs its anti-money laundering compliance on the basis of
AML FATFrecommendations.

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Fortuno Markets neither accepts cash deposits nor disburses cash under any circumstances.

Fortuno Markets reserves the right to refuse to process a transaction at any stage, when it believes the
transaction to be connected in any way to money laundering or criminal activity. In accordance with
international law Fortuno Markets is not obligated to inform the client that they were reported to the
corresponding governing bodies due to client’s suspicious activity.

19. SUSPICIOUS ACTIVITY

There are signs of suspicious activity that suggest money laundering. These are commonly referred to as
"red flags." If a red flag is detected, additional due diligence will be performed before proceeding with the
transaction. If a reasonable explanation is not determined, the suspicious activity shall be reported to the
AML Compliance Committee.

Examples of red flags are:

i. The customer exhibits unusual concern regarding the firm's compliance with government
reporting requirements and the firm's AML policies, particularly with respect to his or her identity,
type of business and assets, or is reluctant or refuses to reveal any information concerning
business activities, or furnishes unusual or suspect identification or business documents.
ii. The customer wishes to engage in transactions that lack business sense or apparent investment
strategy, or are inconsistent with the customer's stated business strategy.
iii. The information provided by the customer that identifies a legitimate source for funds is false,
misleading, or substantially incorrect.
iv. Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or
her funds and other assets.
v. The customer (or a person publicly associated with the customer) has a questionable background
or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
vi. The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
vii. The customer appears to be acting as an agent for an undisclosed principal, but declines or is
reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive
regarding that person or entity.
viii. The customer has difficulty describing the nature of his or her business or lacks general knowledge
of his or her industry.
ix. The customer attempts to make frequent or large deposits of currency, insists on dealing only in
cash equivalents, or asks for exemptions from the firm's policies relating to the deposit of cash
and cash equivalents.
x. For no apparent reason, the customer has multiple accounts under a single name or multiple
names, with a large number of inter-account or third-party transfers.
xi. The customer's account has unexplained or sudden extensive activity, especially in accounts that
had little or no previous activity.

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 xii. The customer's account has a large number of wire transfers to unrelated third parties inconsistent
with the customer's legitimate business purpose.
xiii. The customer's account has wire transfers that have no apparent business purpose to or from a
country identified as money laundering risk or a bank secrecy haven.
xiv. The customer's account indicates large or frequent wire transfers, immediately withdrawn by
check or debit card without any apparent business purpose.
xv. The customer makes a funds deposit followed by an immediate request that the money be wired
out or transferred to a third party, or to another firm, without any apparent business purpose.
xvi. The customer makes a funds deposit for the purpose of purchasing a long-term investment
followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out
of the account.
xvii. The customer requests that a transaction be processed in such a manner to avoid the firm's
normal documentation requirements.

Transaction based monitoring will occur within the appropriate business units of Fortuno Markets.
Monitoring of specific transactions will include but is not limited to transactions aggregating $5,000 or
more and those with respect to which Fortuno Markets has a reason to suspect suspicious activity. All
reports will bedocumented.

20. KNOW YOUR CUSTOMER – THE BASIS FOR RECOGNISING SUSPICIONS

A suspicious transaction will often be one, which is inconsistent with a customer's known, legitimate
business or personal activities or with the normal business for that type of customer. Therefore, the first
key to recognition is knowing enough about the customer's business to recognize that a transaction, or
series of transactions, is unusual.

Questions you must consider when determining whether an established customer’s transaction might be
suspicious are:
i. Is the size of the transaction consistent with the normal activities of the customer?
ii. Is the transaction rational in the context of the customer’s business or personal activities?
iii. Has the pattern of transactions conducted by the customer changed?

21. SUSPICIOUS SCENARIOS

Issues which should lead you to have cause for suspicion would include:
i. Clients who are reluctant to provide proof of identity;
ii. Clients who place undue reliance on an introducer (they may be hiding behind the introducer to
avoid giving you a true picture of their identity or business);
iii. Requests for cash related business, for example questions about whether investments can be
made in cash, suggestions that funds might be available in cash for investment;
iv. Where the source of funds for investment is unclear;

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 v. Where the magnitude of the available funds appears inconsistent with the client’s other
circumstances (i.e. the source of wealth is unclear). Examples might be students or young people
with large amounts to invest;
vi. Where the transaction doesn’t appear rational in the context of the customer’s business or
personal activities. Particular care should be taken in this area if the client changes their method
of dealing with you without reasonable explanation;
vii. Where the pattern of transactions changes;
viii. Where a client who is undertaking transactions that are international in nature does not appear
to have any good reason to be conducting business with the countries involved (e.g. why do they
hold monies in the particular country that the funds are going to or from? Do their circumstances
suggest that it would be reasonable for them to hold funds in such countries?);
ix. Clients who are unwilling to provide you with normal personal or financial information, for no
apparent or rational reason. (Care should be taken not to include all distance relationships as
suspicious, because most will be for genuine reasons. Suspicions will ordinarily be based upon
cumulative as opposed to stand alone issues)

A money launderer is likely to provide persuasive arguments about the reasons for their transactions.
Those should be questioned to decide whether a transaction is suspicious.

22. REPORTING A SUSPICION

Where, for whatever reason, we suspect that a client, or anybody for whom they are acting, may be
undertaking (or attempting to undertake) a transaction involving the proceeds of any crime it must be
reported as soon as practicably possible and in writing.

Internal reports must be made regardless of whether any business was, or is intended to be, actually
written.

23. INVESTIGATION

Upon notification to the AML Compliance Committee an investigation will be commenced to determine if a
report should be made to the appropriate law enforcement or regulatory agencies. The investigation will
include, but not necessarily be limited to, review of all available information, such as payment history,
birth dates, and address. If the results of the investigation warrant, a recommendation will be made to
the AML Compliance Committee to file the SAR with the appropriate law enforcement or regulatory agency.
The AML Compliance Committee is responsible for any notice or filing with law enforcement or regulatory
agency.

Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate
need to know. Under no circumstances shall any officer, employee or appointed agent disclose or discuss
any AML concern, investigation, notice or SAR filing with the person or persons subject of such, or any
other person, including members of the officer's, employee's or appointed agent's family.

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24. FREEZING OF ACCOUNTS

Where we know that the funds in an account derive from criminal activity, or that they arise from
fraudulent instructions, the account must be frozen. Where it is believed that the account holder may be
involved in the fraudulent activity that is being reported, then the account may need to be frozen.

25. OUR COMPLIANCE REGIME

Fortuno Markets implemented a compliance regime, as laws require from financial institutions, including
appointment of a compliance officer, preparation of policies and procedures, periodic review of their
effectiveness, and ongoing compliance training of our staff.

Fortuno Markets is committed to regularly update its electronic system for inspection of suspicious
transactions and for verification of client identification records, in accordance with any new regulations as
they are promulgated, as well as providing training for its employees on enhancements to anti-money
laundering procedures that may be required by new regulations.

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