SCOPE OF POLICY
This AML policy applies to all officers, employees, appointed producers, and the products and services offered by QTX Markets. It is applicable to all business units and locations within QTX Markets, and all efforts will be made to create a cohesive approach in combating money laundering.

QTX Markets has implemented risk-based procedures across its business units and locations to prevent, detect, and report suspicious transactions. All efforts made in this regard will be documented and retained. The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (SARs) or any other required reporting to the relevant law enforcement or regulatory agencies. Any communication from law enforcement or regulatory agencies concerning the Policy will be directed to the AML Compliance Committee.

THE COMMITTEE SHALL

The AML Compliance Committee will perform the following functions:
Receive internal reports of (suspicions of) money laundering.
Investigate reports of suspicious events.
Report relevant suspicious events to the appropriate authorities.
Ensure adequate arrangements for staff and advisor awareness and training.
Provide at least annual reports to the company’s governing body on the operation and effectiveness of AML systems and controls.
Monitor the day-to-day operation of anti-money laundering policies concerning the development of new products, onboarding new customers, and changes in the company’s business profile.

POLICY
QTX Markets is committed to actively preventing money laundering and any activity that supports money laundering or funds terrorist or criminal activities. The company adheres to AML compliance in accordance with applicable laws and requires all officers, employees, and appointed producers to follow these standards to prevent the misuse of its products and services for money laundering purposes.

DEFINITION OF MONEY LAUNDERING
Money laundering is the process of disguising the origins of criminally obtained money or assets, making them appear to be from legitimate sources. It involves exchanging criminal proceeds for "clean" money or assets that have no obvious link to their criminal origins. Criminal property can take various forms, including money, securities, tangible and intangible assets, and it can also include funds used to support terrorism.

COUNTER TERRORIST FINANCING (CTF)
Terrorist financing refers to legitimate businesses or individuals providing funds to support terrorist activities or organizations for ideological, political, or other reasons. QTX Markets ensures that its customers are not terrorist organizations themselves and that the company does not facilitate the funding of terrorist organizations.

RISK-BASED APPROACH

QTX Markets adopts a risk-based approach to determine the level of due diligence required for anti-money laundering procedures. The company allocates resources for due diligence in proportion to the magnitude of risk associated with each relationship. Risk is assessed in three main areas:
Customer Risk: Different customer profiles pose varying levels of risk, and due diligence is adjusted accordingly.
Product Risk: The risk associated with the products or services offered by the company is considered, with different risk categories established.
Country Risk: Geographic location and the origin of business activity are evaluated for associated risk levels.

CUSTOMER IDENTIFICATION PROGRAM (CIP)
QTX Markets has implemented a Customer Identification Program to collect and verify customer identification information, as required by law. Customers are notified of the need to provide such information.

KNOW YOUR CUSTOMER (KYC)
To establish a business relationship, QTX Markets obtains information about the nature of the customer’s business and expected transactions. Ongoing business relationships are assessed against the customer’s expected pattern of activity. Any unexplained or suspicious activity is thoroughly examined.

SOURCE OF FUNDS
QTX Markets always ascertains and records the source of funds for each transaction to identify the origin and legitimacy of the payment.

REPORTING SUSPICIOUS ACTIVITY
QTX Markets maintains vigilance for suspicious activity and red flags associated with money laundering. If a red flag is detected, additional due diligence is conducted before proceeding with the transaction. Any suspicion of money laundering is reported to the AML Compliance Committee for investigation and potential filing of a Suspicious Activity Report.

INVESTIGATION
Upon notification to the AML Compliance Committee, an investigation is initiated to determine the necessity of reporting to the relevant law enforcement or regulatory agencies. Investigation results are kept confidential and only disclosed to those with a legitimate need to know. No information will be shared with the subject of the investigation or any unauthorized persons.

FREEZING OF ACCOUNTS
Accounts known to derive from criminal activity or fraudulent instructions will be frozen. In cases where the account holder may be involved in the fraudulent activity, the account may also be frozen.

QTX Markets is fully committed to upholding the principles of this AML policy and will take all necessary measures to combat money laundering effectively.