Anti-Money Laundering Policy

1. Introduction

RISEN LTD., operating under the brand name RisenFX (“RisenFX,” “the Company,” “we,” “our,” or “us”), is committed to maintaining strong controls against money laundering, terrorist financing, fraud, sanctions violations, and other forms of financial crime.

This Anti-Money Laundering (“AML”) and Counter-Terrorist Financing (“CTF”) Policy outlines the procedures, standards, and internal controls used by RisenFX to identify clients, assess risk, monitor account activity, and prevent the misuse of our products and services for unlawful financial activity.

RisenFX’s AML and CTF framework is designed with reference to recognized international standards, including principles issued by the Financial Action Task Force (“FATF”), as well as applicable laws, regulations, and compliance expectations in Saint Lucia and other relevant jurisdictions.

This policy is based on the GatesFX AML/CTF Policy you provided, rewritten for RisenFX with updated company details and unique wording.

2. Purpose

The purpose of this Policy is to:

Prevent RisenFX’s services, platforms, accounts, or payment channels from being used for money laundering, terrorist financing, fraud, sanctions evasion, or other unlawful activity;

Establish clear procedures for identifying, verifying, and monitoring clients;

Apply appropriate due diligence measures before and during the client relationship;

Monitor deposits, withdrawals, transfers, trading activity, and account behavior for suspicious patterns;

Comply with applicable AML, CTF, sanctions, recordkeeping, and reporting obligations;

Protect RisenFX, its clients, counterparties, partners, and service providers from financial crime risk;

Preserve the integrity, security, and reputation of the RisenFX trading environment.

3. Scope

This Policy applies to:

All clients, applicants, account holders, beneficial owners, authorized representatives, and counterparties of RisenFX;

All trading accounts, wallets, deposits, withdrawals, internal transfers, and payment methods used with RisenFX;

All products and services offered by RisenFX, including Forex, Commodities, Indices, Cryptocurrencies, CFDs, and other leveraged products;

All employees, officers, contractors, consultants, affiliates, representatives, introducing brokers, partners, and service providers acting for or on behalf of RisenFX;

All online systems, client portals, trading platforms, payment channels, support channels, and operational procedures used by the Company.

4. Key Definitions

Money Laundering means the process of disguising, concealing, transferring, converting, or using funds derived from illegal activity in order to make them appear legitimate.

Terrorist Financing means providing, collecting, transferring, or making funds or assets available with the intention or knowledge that they may be used to support terrorist acts, terrorist organizations, or related unlawful activity.

Beneficial Owner means the natural person who ultimately owns, controls, benefits from, or exercises effective control over an account, company, transaction, or business relationship.

Customer Due Diligence (“CDD”) means the process of identifying and verifying a client and assessing the risk associated with the client relationship.

Enhanced Due Diligence (“EDD”) means additional verification, documentation, review, or approval applied to higher-risk clients, transactions, jurisdictions, or account activity.

Politically Exposed Person (“PEP”) means an individual who is or has been entrusted with a prominent public function, including close family members or known associates of such individuals.

Suspicious Activity means any transaction, account behavior, funding pattern, trading activity, or client conduct that appears unusual, inconsistent with the client’s known profile, lacks an apparent lawful purpose, or raises concern regarding financial crime.

Sanctions means restrictions or prohibitions imposed by competent authorities against certain individuals, entities, countries, industries, transactions, or activities.

5. Customer Due Diligence

5.1 Standard Verification

Before a client may fully access RisenFX services, RisenFX may require the client to complete identity verification and provide information or documentation necessary for KYC and AML purposes.

Standard verification may include collecting and verifying:

Full legal name;

Date of birth;

Nationality;

Country of residence;

Residential address;

Email address and phone number;

Government-issued identification document;

Proof of address;

Selfie, liveness check, or biometric verification where required;

Payment method ownership;

Source of funds or source of wealth information where applicable.

RisenFX may restrict deposits, withdrawals, trading access, bonuses, leverage, account features, or platform access until verification requirements have been completed to the Company’s satisfaction.

The Company may reject, suspend, or close an account where documents are incomplete, expired, inconsistent, unclear, suspected to be false, or otherwise unacceptable.

5.2 Enhanced Due Diligence

RisenFX may apply Enhanced Due Diligence where the client, transaction, payment method, account behavior, or jurisdiction presents a higher level of risk.

EDD may apply to:

Politically Exposed Persons;

Clients from higher-risk jurisdictions;

Clients using complex ownership or corporate structures;

Clients conducting unusually large or frequent transactions;

Clients with inconsistent deposit, withdrawal, or trading behavior;

Clients linked to adverse media, sanctions concerns, fraud indicators, or suspicious activity;

Accounts requiring additional compliance approval.

Enhanced Due Diligence may include requesting additional identification documents, proof of address, payment verification, source-of-funds evidence, source-of-wealth information, business documents, corporate ownership records, bank statements, transaction explanations, or senior compliance review.

RisenFX may refuse or terminate a client relationship if Enhanced Due Diligence cannot be completed.

5.3 Simplified Due Diligence

Simplified Due Diligence may be applied only where the risk of money laundering or terrorist financing is assessed as low and where permitted by applicable law and internal risk controls.

Simplified Due Diligence will not be applied where higher-risk features exist, including suspicious activity, sanctions concerns, complex ownership structures, high-risk jurisdictions, or leveraged trading activity that requires additional scrutiny.

RisenFX reserves the right to upgrade any client relationship to standard or enhanced review at any time.

6. Liveness and Identity Verification

As part of RisenFX’s digital verification process, clients may be required to complete a liveness check, selfie verification, short video submission, or other identity confirmation method.

This process is used to confirm that:

The individual completing verification is a real, live person;

The person submitting the documents matches the identity document provided;

The documents have not been submitted by an unauthorized third party;

The verification process is not being completed using stolen, forged, altered, or synthetic identity information.

RisenFX may use third-party verification tools, manual review, or automated systems to complete this process.

Failure to complete liveness or identity verification may result in account restrictions, withdrawal delays, account suspension, or account closure.

7. Ongoing Monitoring of Transactions and Account Activity

RisenFX monitors client activity on an ongoing basis to identify unusual, suspicious, abusive, or potentially unlawful conduct.

Monitoring may include review of:

Deposit and withdrawal frequency;

Deposit and withdrawal amounts;

Payment method ownership;

Rapid movement of funds without reasonable trading activity;

Multiple accounts linked to the same individual, device, address, payment method, or IP address;

Trading patterns inconsistent with the client’s profile;

Bonus abuse, self-referrals, or commission abuse;

Transactions involving high-risk or restricted jurisdictions;

Use of suspicious crypto wallets, payment sources, or third-party accounts;

Account behavior that appears inconsistent with legitimate trading activity.

Monitoring may be conducted through automated systems, manual review, third-party tools, compliance checks, fraud detection systems, and internal risk controls.

Transactions or accounts flagged for review may be delayed, restricted, investigated, escalated, or reported where required.

8. Sanctions Screening

RisenFX screens clients, beneficial owners, counterparties, and relevant parties against applicable sanctions, watchlists, and high-risk databases.

Screening may include checks against lists issued or maintained by:

United Nations sanctions authorities;

OFAC;

European Union sanctions authorities;

United Kingdom sanctions authorities;

Other competent regulatory, governmental, or law enforcement bodies;

Commercial sanctions, PEP, and adverse media screening providers.

If a client or related party is identified as a potential sanctions match, RisenFX may freeze or restrict the account, delay transactions, reject onboarding, request further information, terminate the relationship, and/or report the matter to competent authorities where required.

RisenFX does not provide services to sanctioned individuals, sanctioned entities, or prohibited jurisdictions where doing so would violate applicable sanctions requirements or Company policy.

9. Reporting of Suspicious Activity

If suspicious activity is detected or reasonably suspected, RisenFX’s Compliance Department will review the matter and document the relevant facts, evidence, transactions, and account history.

Where required or appropriate, RisenFX may file a Suspicious Activity Report, Suspicious Transaction Report, or equivalent notification with the competent authority, including the relevant Financial Intelligence Authority or other applicable body.

Clients will not be informed when a suspicious activity report has been filed or is being considered. RisenFX strictly prohibits “tipping off” or any action that could compromise an investigation.

RisenFX may restrict accounts, freeze activity, delay transactions, cancel pending withdrawals, or terminate relationships where necessary to comply with AML, CTF, sanctions, or legal obligations.

10. Record Keeping

RisenFX retains KYC documents, verification records, transaction records, trading records, communications, risk assessments, compliance reviews, and related account information for a minimum of five (5) years after the end of the client relationship, or longer where required by law, regulation, dispute resolution, fraud prevention, or internal policy.

Records may include:

Identity documents;

Proof of address documents;

Liveness or selfie verification records;

Payment method verification;

Deposit and withdrawal records;

Trading activity;

Communication history;

Compliance notes and risk assessments;

Suspicious activity reviews;

Documents submitted for source-of-funds or source-of-wealth verification.

Records are stored securely and are accessible only to authorized personnel, service providers, auditors, regulators, or competent authorities where required.

11. Employee Training and Awareness

RisenFX provides AML and CTF awareness training to relevant employees, contractors, representatives, and operational personnel.

Training may cover:

Money laundering and terrorist financing risks;

Client identification and verification procedures;

Recognizing red flags and suspicious activity;

Sanctions screening obligations;

Escalation and reporting procedures;

Recordkeeping requirements;

Confidentiality and anti-tipping-off obligations;

Data protection and secure handling of client information;

Fraud, bonus abuse, payment abuse, and account misuse indicators.

Training may be provided during onboarding and periodically thereafter to ensure employees remain aware of current obligations, internal procedures, and emerging financial crime risks.

12. Risk-Based Approach

RisenFX applies a risk-based approach to AML and CTF compliance.

This means the Company assesses the level of risk presented by each client, transaction, account type, jurisdiction, product, payment method, and activity pattern, then applies controls proportionate to that risk.

Risk factors may include:

Client location and nationality;

Payment method used;

Transaction size and frequency;

Account type and trading behavior;

Source of funds;

Source of wealth;

Corporate ownership structure;

PEP status;

Sanctions or adverse media indicators;

Use of cryptocurrencies or high-risk payment channels;

Links to multiple accounts or suspicious referral activity.

Based on the risk assessment, RisenFX may apply standard due diligence, enhanced due diligence, increased monitoring, transaction restrictions, account limitations, or account termination.

13. Third-Party Payments and Transfers

RisenFX does not accept or process third-party deposits or third-party withdrawals.

All funds deposited into a RisenFX account must originate from a payment method, bank account, card, wallet, or other funding source held in the client’s own name.

Withdrawals must generally be returned to a verified payment method in the same client’s name, subject to AML rules, payment provider requirements, and internal procedures.

RisenFX may reject, return, delay, investigate, or require additional verification for any payment that:

Comes from an unverified source;

Comes from a third party;

Cannot be matched to the client’s verified identity;

Raises fraud, AML, sanctions, chargeback, or compliance concerns;

Uses a payment method inconsistent with the client’s profile.

If a third-party payment is received, RisenFX may return the funds to the original source where possible, less any applicable fees, and may restrict the account pending review.

14. Source of Funds and Source of Wealth

RisenFX may request information or documentation to verify the origin of funds used to deposit, trade, or transact through a RisenFX account.

Source-of-funds or source-of-wealth documentation may include:

Bank statements;

Payslips or employment income evidence;

Business income records;

Sale agreements;

Investment statements;

Tax documents;

Crypto transaction records;

Loan or inheritance documentation;

Other documents reasonably requested by the Compliance Department.

Failure to provide satisfactory evidence may result in deposit rejection, withdrawal delays, account restrictions, account closure, or reporting to competent authorities where required.

15. Non-Compliance Consequences

Clients are required to cooperate with RisenFX’s AML, CTF, sanctions, fraud prevention, and verification procedures.

Failure to provide requested information, complete verification, explain account activity, or comply with this Policy may result in:

Account restrictions;

Suspension of trading access;

Deposit or withdrawal delays;

Rejection or return of payments;

Freezing of funds pending review;

Removal of promotions, bonuses, or partner commissions;

Account closure;

Termination of the business relationship;

Reporting to competent authorities where required.

RisenFX reserves the right to refuse service, suspend transactions, terminate accounts, or take any necessary action where AML, CTF, sanctions, fraud, or compliance risks are identified.

16. Confidentiality and Anti-Tipping-Off

RisenFX and its employees, contractors, partners, and representatives must maintain confidentiality regarding AML reviews, suspicious activity investigations, sanctions checks, reporting decisions, and communications with competent authorities.

Clients, partners, or third parties will not be informed where doing so may constitute tipping off, compromise an investigation, or violate legal obligations.

Internal AML information may only be shared with authorized personnel, service providers, regulators, law enforcement, or competent authorities where appropriate or required.

17. Policy Updates

RISEN LTD. reserves the right to update, amend, replace, or modify this AML & CTF Policy at any time to reflect operational, legal, regulatory, compliance, technological, or risk management changes.

Any updated version will be published on the official RisenFX website and will become effective immediately upon publication unless otherwise stated.

Continued access to or use of RisenFX services after an updated Policy is published constitutes acceptance of the revised Policy.

18. Contact Information

For AML, verification, compliance, or policy-related questions, clients may contact:

RISEN LTD. – Compliance Department
Office 2, Golf Course Lane,
Cap. Estate, Gros Islet,
Saint Lucia

Email: support@risenfx.com
Phone: +1 (855) 792-8356