AML Policy

1. Introduction

United Traders Limited (trading as UnitedFXA) is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance. This policy sets out our approach to detecting, preventing, and reporting money laundering and terrorist financing activities.

As a firm authorised and regulated by the Financial Conduct Authority (FCA) with FRN 946000, we are subject to the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and all associated FCA rules and guidance.

2. Our Commitment

UnitedFXA is committed to:

• Preventing our services from being used to launder money or finance terrorism.
• Complying fully with all applicable AML/CTF laws and regulations.
• Maintaining robust systems and controls to identify and manage financial crime risks.
• Training all relevant staff on AML/CTF obligations and procedures.
• Cooperating fully with law enforcement and regulatory authorities.

3. Customer Due Diligence (CDD)

We apply Customer Due Diligence measures to all clients before establishing a business relationship. Our CDD process includes:

• Identity Verification: Collecting and verifying government-issued photo identification (passport, national ID card, or driving licence).
• Address Verification: Confirming residential address through utility bills, bank statements, or other acceptable documents dated within the last three months.
• Source of Funds: Understanding the origin of funds deposited into trading accounts.
• Beneficial Ownership: Identifying the ultimate beneficial owner(s) of corporate accounts.

4. Enhanced Due Diligence (EDD)

We apply Enhanced Due Diligence in higher-risk situations, including:

• Clients identified as Politically Exposed Persons (PEPs) or their close associates.
• Clients from high-risk jurisdictions as identified by the Financial Action Task Force (FATF).
• Transactions that are unusually large or complex without apparent legitimate purpose.
• Clients with unusual or inconsistent transaction patterns.

5. Ongoing Monitoring

We continuously monitor client accounts and transactions to detect suspicious activity. Our monitoring systems are designed to identify:

• Unusual transaction patterns inconsistent with a client's known profile.
• Large cash deposits or withdrawals without clear business justification.
• Rapid movement of funds through accounts.
• Transactions involving high-risk jurisdictions or sanctioned entities.

6. Suspicious Activity Reporting

Where we identify or suspect money laundering or terrorist financing activity, we are legally obligated to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) via the UK Financial Intelligence Unit. We are prohibited by law from disclosing ("tipping off") to the client or any third party that a SAR has been filed.

7. Sanctions Compliance

We screen all clients and transactions against applicable sanctions lists, including those maintained by HM Treasury, the Office of Financial Sanctions Implementation (OFSI), the United Nations, the European Union, and the US Office of Foreign Assets Control (OFAC). We will not conduct business with sanctioned individuals, entities, or jurisdictions.

8. Record Keeping

We maintain records of all client identification documents, transaction records, and AML-related documentation for a minimum of five years from the end of the client relationship, in accordance with FCA requirements. These records are available to regulatory authorities upon request.

9. Staff Training

All relevant staff receive regular AML/CTF training to ensure they understand their obligations, can recognise suspicious activity, and know how to report concerns internally. Our Money Laundering Reporting Officer (MLRO) oversees our AML compliance programme and is responsible for receiving and evaluating internal suspicious activity reports.

10. Contact

For AML-related enquiries or to report concerns, please contact our compliance team: