Anti-Money-Laundering (AML) Policy

1.1Nexone shall apply the principles of "Purpose and Scope" in a manner consistent with clause 1. Sub-clause 1.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

1.2For the purposes of clause 1 (Purpose and Scope), the customer acknowledges and agrees that any obligation described in sub-clause 1.2 is a material term of this document and non-compliance may result in restrictions on the account.

1.3Sub-clause 1.3 clarifies the scope of clause 1 (Purpose and Scope) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

1.4Where circumstances require an exception to clause 1 (Purpose and Scope), sub-clause 1.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

2.1Nexone shall apply the principles of "Regulatory Framework" in a manner consistent with clause 2. Sub-clause 2.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

2.2For the purposes of clause 2 (Regulatory Framework), the customer acknowledges and agrees that any obligation described in sub-clause 2.2 is a material term of this document and non-compliance may result in restrictions on the account.

2.3Sub-clause 2.3 clarifies the scope of clause 2 (Regulatory Framework) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

2.4Where circumstances require an exception to clause 2 (Regulatory Framework), sub-clause 2.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

3.1Nexone shall apply the principles of "Definitions of Financial Crime" in a manner consistent with clause 3. Sub-clause 3.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

3.2For the purposes of clause 3 (Definitions of Financial Crime), the customer acknowledges and agrees that any obligation described in sub-clause 3.2 is a material term of this document and non-compliance may result in restrictions on the account.

3.3Sub-clause 3.3 clarifies the scope of clause 3 (Definitions of Financial Crime) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

3.4Where circumstances require an exception to clause 3 (Definitions of Financial Crime), sub-clause 3.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

4.1Nexone shall apply the principles of "Risk-Based Approach" in a manner consistent with clause 4. Sub-clause 4.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

4.2For the purposes of clause 4 (Risk-Based Approach), the customer acknowledges and agrees that any obligation described in sub-clause 4.2 is a material term of this document and non-compliance may result in restrictions on the account.

4.3Sub-clause 4.3 clarifies the scope of clause 4 (Risk-Based Approach) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

4.4Where circumstances require an exception to clause 4 (Risk-Based Approach), sub-clause 4.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

5.1Nexone shall apply the principles of "Customer Risk Rating" in a manner consistent with clause 5. Sub-clause 5.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

5.2For the purposes of clause 5 (Customer Risk Rating), the customer acknowledges and agrees that any obligation described in sub-clause 5.2 is a material term of this document and non-compliance may result in restrictions on the account.

5.3Sub-clause 5.3 clarifies the scope of clause 5 (Customer Risk Rating) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

5.4Where circumstances require an exception to clause 5 (Customer Risk Rating), sub-clause 5.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

6.1Nexone shall apply the principles of "Enhanced Due Diligence" in a manner consistent with clause 6. Sub-clause 6.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

6.2For the purposes of clause 6 (Enhanced Due Diligence), the customer acknowledges and agrees that any obligation described in sub-clause 6.2 is a material term of this document and non-compliance may result in restrictions on the account.

6.3Sub-clause 6.3 clarifies the scope of clause 6 (Enhanced Due Diligence) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

6.4Where circumstances require an exception to clause 6 (Enhanced Due Diligence), sub-clause 6.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

7.1Nexone shall apply the principles of "Politically Exposed Persons" in a manner consistent with clause 7. Sub-clause 7.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

7.2For the purposes of clause 7 (Politically Exposed Persons), the customer acknowledges and agrees that any obligation described in sub-clause 7.2 is a material term of this document and non-compliance may result in restrictions on the account.

7.3Sub-clause 7.3 clarifies the scope of clause 7 (Politically Exposed Persons) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

7.4Where circumstances require an exception to clause 7 (Politically Exposed Persons), sub-clause 7.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

8.1Nexone shall apply the principles of "Sanctions Screening" in a manner consistent with clause 8. Sub-clause 8.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

8.2For the purposes of clause 8 (Sanctions Screening), the customer acknowledges and agrees that any obligation described in sub-clause 8.2 is a material term of this document and non-compliance may result in restrictions on the account.

8.3Sub-clause 8.3 clarifies the scope of clause 8 (Sanctions Screening) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

8.4Where circumstances require an exception to clause 8 (Sanctions Screening), sub-clause 8.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

9.1Nexone shall apply the principles of "Source-of-Funds Verification" in a manner consistent with clause 9. Sub-clause 9.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

9.2For the purposes of clause 9 (Source-of-Funds Verification), the customer acknowledges and agrees that any obligation described in sub-clause 9.2 is a material term of this document and non-compliance may result in restrictions on the account.

9.3Sub-clause 9.3 clarifies the scope of clause 9 (Source-of-Funds Verification) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

9.4Where circumstances require an exception to clause 9 (Source-of-Funds Verification), sub-clause 9.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

10.1Nexone shall apply the principles of "Source-of-Wealth Verification" in a manner consistent with clause 10. Sub-clause 10.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

10.2For the purposes of clause 10 (Source-of-Wealth Verification), the customer acknowledges and agrees that any obligation described in sub-clause 10.2 is a material term of this document and non-compliance may result in restrictions on the account.

10.3Sub-clause 10.3 clarifies the scope of clause 10 (Source-of-Wealth Verification) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

10.4Where circumstances require an exception to clause 10 (Source-of-Wealth Verification), sub-clause 10.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

11.1Nexone shall apply the principles of "Ongoing Monitoring" in a manner consistent with clause 11. Sub-clause 11.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

11.2For the purposes of clause 11 (Ongoing Monitoring), the customer acknowledges and agrees that any obligation described in sub-clause 11.2 is a material term of this document and non-compliance may result in restrictions on the account.

11.3Sub-clause 11.3 clarifies the scope of clause 11 (Ongoing Monitoring) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

11.4Where circumstances require an exception to clause 11 (Ongoing Monitoring), sub-clause 11.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

12.1Nexone shall apply the principles of "Transaction Screening" in a manner consistent with clause 12. Sub-clause 12.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

12.2For the purposes of clause 12 (Transaction Screening), the customer acknowledges and agrees that any obligation described in sub-clause 12.2 is a material term of this document and non-compliance may result in restrictions on the account.

12.3Sub-clause 12.3 clarifies the scope of clause 12 (Transaction Screening) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

12.4Where circumstances require an exception to clause 12 (Transaction Screening), sub-clause 12.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

13.1Nexone shall apply the principles of "Threshold Reporting" in a manner consistent with clause 13. Sub-clause 13.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

13.2For the purposes of clause 13 (Threshold Reporting), the customer acknowledges and agrees that any obligation described in sub-clause 13.2 is a material term of this document and non-compliance may result in restrictions on the account.

13.3Sub-clause 13.3 clarifies the scope of clause 13 (Threshold Reporting) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

13.4Where circumstances require an exception to clause 13 (Threshold Reporting), sub-clause 13.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

14.1Nexone shall apply the principles of "Suspicious Activity Reporting" in a manner consistent with clause 14. Sub-clause 14.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

14.2For the purposes of clause 14 (Suspicious Activity Reporting), the customer acknowledges and agrees that any obligation described in sub-clause 14.2 is a material term of this document and non-compliance may result in restrictions on the account.

14.3Sub-clause 14.3 clarifies the scope of clause 14 (Suspicious Activity Reporting) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

14.4Where circumstances require an exception to clause 14 (Suspicious Activity Reporting), sub-clause 14.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

15.1Nexone shall apply the principles of "Record-Keeping Obligations" in a manner consistent with clause 15. Sub-clause 15.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

15.2For the purposes of clause 15 (Record-Keeping Obligations), the customer acknowledges and agrees that any obligation described in sub-clause 15.2 is a material term of this document and non-compliance may result in restrictions on the account.

15.3Sub-clause 15.3 clarifies the scope of clause 15 (Record-Keeping Obligations) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

15.4Where circumstances require an exception to clause 15 (Record-Keeping Obligations), sub-clause 15.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

16.1Nexone shall apply the principles of "Training of Personnel" in a manner consistent with clause 16. Sub-clause 16.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

16.2For the purposes of clause 16 (Training of Personnel), the customer acknowledges and agrees that any obligation described in sub-clause 16.2 is a material term of this document and non-compliance may result in restrictions on the account.

16.3Sub-clause 16.3 clarifies the scope of clause 16 (Training of Personnel) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

16.4Where circumstances require an exception to clause 16 (Training of Personnel), sub-clause 16.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

17.1Nexone shall apply the principles of "Independent Audit Programme" in a manner consistent with clause 17. Sub-clause 17.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

17.2For the purposes of clause 17 (Independent Audit Programme), the customer acknowledges and agrees that any obligation described in sub-clause 17.2 is a material term of this document and non-compliance may result in restrictions on the account.

17.3Sub-clause 17.3 clarifies the scope of clause 17 (Independent Audit Programme) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

17.4Where circumstances require an exception to clause 17 (Independent Audit Programme), sub-clause 17.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

18.1Nexone shall apply the principles of "MLRO Appointment and Duties" in a manner consistent with clause 18. Sub-clause 18.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

18.2For the purposes of clause 18 (MLRO Appointment and Duties), the customer acknowledges and agrees that any obligation described in sub-clause 18.2 is a material term of this document and non-compliance may result in restrictions on the account.

18.3Sub-clause 18.3 clarifies the scope of clause 18 (MLRO Appointment and Duties) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

18.4Where circumstances require an exception to clause 18 (MLRO Appointment and Duties), sub-clause 18.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

19.1Nexone shall apply the principles of "Cooperation with Authorities" in a manner consistent with clause 19. Sub-clause 19.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

19.2For the purposes of clause 19 (Cooperation with Authorities), the customer acknowledges and agrees that any obligation described in sub-clause 19.2 is a material term of this document and non-compliance may result in restrictions on the account.

19.3Sub-clause 19.3 clarifies the scope of clause 19 (Cooperation with Authorities) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

19.4Where circumstances require an exception to clause 19 (Cooperation with Authorities), sub-clause 19.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

20.1Nexone shall apply the principles of "Whistleblower Protection" in a manner consistent with clause 20. Sub-clause 20.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

20.2For the purposes of clause 20 (Whistleblower Protection), the customer acknowledges and agrees that any obligation described in sub-clause 20.2 is a material term of this document and non-compliance may result in restrictions on the account.

20.3Sub-clause 20.3 clarifies the scope of clause 20 (Whistleblower Protection) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

20.4Where circumstances require an exception to clause 20 (Whistleblower Protection), sub-clause 20.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

21.1Nexone shall apply the principles of "Tipping-Off Prohibition" in a manner consistent with clause 21. Sub-clause 21.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

21.2For the purposes of clause 21 (Tipping-Off Prohibition), the customer acknowledges and agrees that any obligation described in sub-clause 21.2 is a material term of this document and non-compliance may result in restrictions on the account.

21.3Sub-clause 21.3 clarifies the scope of clause 21 (Tipping-Off Prohibition) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

21.4Where circumstances require an exception to clause 21 (Tipping-Off Prohibition), sub-clause 21.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

22.1Nexone shall apply the principles of "Third-Party Reliance" in a manner consistent with clause 22. Sub-clause 22.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

22.2For the purposes of clause 22 (Third-Party Reliance), the customer acknowledges and agrees that any obligation described in sub-clause 22.2 is a material term of this document and non-compliance may result in restrictions on the account.

22.3Sub-clause 22.3 clarifies the scope of clause 22 (Third-Party Reliance) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

22.4Where circumstances require an exception to clause 22 (Third-Party Reliance), sub-clause 22.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

23.1Nexone shall apply the principles of "Governance and Oversight" in a manner consistent with clause 23. Sub-clause 23.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

23.2For the purposes of clause 23 (Governance and Oversight), the customer acknowledges and agrees that any obligation described in sub-clause 23.2 is a material term of this document and non-compliance may result in restrictions on the account.

23.3Sub-clause 23.3 clarifies the scope of clause 23 (Governance and Oversight) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

23.4Where circumstances require an exception to clause 23 (Governance and Oversight), sub-clause 23.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.

24.1Nexone shall apply the principles of "Policy Review Cycle" in a manner consistent with clause 24. Sub-clause 24.1 sets out the operational expectations, the parties to whom they apply, and the internal controls that support them.

24.2For the purposes of clause 24 (Policy Review Cycle), the customer acknowledges and agrees that any obligation described in sub-clause 24.2 is a material term of this document and non-compliance may result in restrictions on the account.

24.3Sub-clause 24.3 clarifies the scope of clause 24 (Policy Review Cycle) and its interaction with the wider Nexone regulatory framework, including any applicable local law, regulatory guidance or industry code of conduct.

24.4Where circumstances require an exception to clause 24 (Policy Review Cycle), sub-clause 24.4 authorises Nexone to grant that exception on a case-by-case basis, subject to appropriate risk assessment, documentation and internal approval.