Anti-Money Laundering Policy

GTX PRIME is committed to preventing financial crime and maintaining the highest standards of integrity and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.

1 Introduction

GTX PRIME ("we," "our," or "us") is committed to maintaining the highest standards of integrity and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. This policy outlines our commitment to preventing money laundering and terrorist financing activities through our services.

We are committed to complying with all applicable AML/CTF laws and regulations in the jurisdictions where we operate, including but not limited to the Financial Action Task Force (FATF) recommendations and local regulatory requirements.

2 Policy Objectives

The objectives of this AML Policy are to:

• Prevent money laundering and terrorist financing activities.
• Ensure compliance with applicable AML/CTF laws and regulations.
• Protect our company and clients from financial crime risks.
• Maintain the integrity of the financial system.
• Establish clear procedures for identifying and reporting suspicious activities.

3 Risk Assessment

We conduct regular risk assessments to identify and evaluate money laundering and terrorist financing risks associated with our business activities. Our risk assessment considers:

• Client risk factors (geography, business type, transaction patterns).
• Product and service risk factors.
• Geographic risk factors.
• Delivery channel risk factors.
• Technology and new payment methods risk factors.

4 Customer Due Diligence (CDD)

4.1 Standard CDD

We apply standard CDD measures to all clients, including:

• Verification of client identity using reliable, independent sources.
• Identification of beneficial owners.
• Understanding the nature and purpose of the business relationship.
• Ongoing monitoring of the business relationship.

4.2 Enhanced Due Diligence (EDD)

Enhanced due diligence is applied to higher-risk clients, including:

• Politically exposed persons (PEPs).
• Clients from high-risk jurisdictions.
• Clients with complex ownership structures.
• Clients with unusual transaction patterns.

5 Transaction Monitoring

We implement comprehensive transaction monitoring systems to detect suspicious activities, including:

• Unusual transaction patterns or volumes.
• Transactions inconsistent with client profiles.
• Complex or unusual transactions.
• Transactions involving high-risk jurisdictions.
• Transactions with no apparent economic or lawful purpose.

6 Suspicious Activity Reporting

Our employees are trained to identify and report suspicious activities. When suspicious activity is detected:

• Immediate reporting to the Compliance Officer.
• Documentation of all relevant details.
• Assessment of whether a suspicious activity report (SAR) is required.
• Filing of SARs with relevant authorities when necessary.
• Maintenance of confidentiality of SAR filings.

7 Record Keeping

We maintain comprehensive records in accordance with regulatory requirements:

• Client identification and verification documents.
• Transaction records for at least 5 years.
• CDD and EDD documentation.
• Suspicious activity reports and supporting documentation.
• Training records and compliance reports.

8 Employee Training

All employees receive regular AML/CTF training, including:

• Recognition of suspicious activities.
• CDD and EDD procedures.
• Reporting requirements and procedures.
• Regulatory updates and changes.
• Consequences of non-compliance.

9 Compliance Officer

We have designated a Compliance Officer responsible for:

• Overseeing AML/CTF compliance.
• Reviewing and updating policies and procedures.
• Conducting risk assessments.
• Ensuring proper training and awareness.
• Liaising with regulatory authorities.

10 Sanctions Compliance

We maintain compliance with international sanctions programs:

• Regular screening against sanctions lists.
• Blocking transactions involving sanctioned entities.
• Reporting blocked transactions to relevant authorities.
• Maintaining up-to-date sanctions screening systems.

11 Third-Party Relationships

We conduct due diligence on third-party relationships:

• Assessment of third-party AML/CTF controls.
• Regular review of third-party relationships.
• Contractual requirements for AML/CTF compliance.
• Monitoring of third-party performance.

12 Regulatory Reporting

We maintain open communication with regulatory authorities:

• Timely submission of required reports.
• Cooperation with regulatory inquiries.
• Prompt notification of material compliance issues.
• Regular regulatory updates and consultations.

13 Policy Review and Updates

This AML Policy is reviewed and updated regularly to ensure:

• Compliance with current regulatory requirements.
• Effectiveness of implemented measures.
• Integration of lessons learned from incidents.
• Alignment with industry best practices.

14 Contact Information

For questions about this AML Policy or to report suspicious activities, please contact us: