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AML Policy

Know Your Customer (KYC) Policy

Effective Date: 12th June 2025

Company Name: Global Magnate Capital Ltd.

Company Registration Number: 2025-00329

Business Address: Foster Capital Inc., Robin Kelton Building, Choc Bay, Castries, Saint Lucia

1. Introduction

This Know Your Customer (KYC) Policy (“Policy”) sets forth the internal framework and legal obligations under which Global Magnate Capital Ltd. (“Company,” “we,” “our,” or “us”) identifies and verifies the identities of its clients and beneficial owners in accordance with applicable Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) legislation in Saint Lucia and internationally recognized standards (e.g., FATF Recommendations, EU AML Directives, and FCA guidelines).

This Policy forms a fundamental component of our broader AML/CTF Compliance Program and is applicable to all individuals and entities engaging with the Company in any financial capacity.

2. Regulatory Framework

Global Magnate Capital Ltd. operates under the International Business Companies Act of Saint Lucia and adheres to the Money Laundering (Prevention) Act, as well as other applicable local and international regulatory obligations, including but not limited to:

  • Financial Action Task Force (FATF) Recommendations
  • European Union Anti-Money Laundering Directives (AMLDs)
  • General Data Protection Regulation (GDPR) where applicable
  • International sanctions regulations (e.g., OFAC, UN, UK Sanctions Lists)

3. Objective of the KYC Policy

The objectives of this KYC Policy are to:

  • Prevent the Company from being used for money laundering, terrorism financing, and other illicit financial activities
  • Establish robust procedures for client identity verification and ongoing monitoring
  • Ensure risk-based client classification and enhanced due diligence (EDD) where appropriate
  • Promote transparency and accountability in the onboarding and transaction lifecycle

4. Scope of Application

This Policy applies to all clients of Global Magnate Capital Ltd., including:

  • Individual clients
  • Corporate and institutional clients
  • Ultimate beneficial owners (UBOs)
  • Intermediaries, introducers, and third-party service providers

The KYC process is conducted prior to account activation and is maintained through ongoing compliance monitoring and periodic review.

5. Client Identification and Verification

5.1 Individual Clients

Clients must provide the following documentation for identity verification:

  • Government-issued photo identification (passport, national ID, or driver’s license)
  • Proof of residential address (utility bill, bank statement, or government-issued correspondence not older than 3 months)
  • Selfie with ID for biometric verification, where required
  • Source of funds declaration

5.2 Corporate Clients

Entities must submit:

  • Certificate of Incorporation or Registration
  • Memorandum and Articles of Association or equivalent
  • Directors’ Resolution/Board Authorization
  • Proof of registered office address
  • List of directors and shareholders
  • Identification and KYC documents of all Ultimate Beneficial Owners (UBOs) holding 25% or more equity or voting rights

6. Risk-Based Client Due Diligence (CDD/EDD)

Clients are classified into three risk tiers: Standard Risk, Medium Risk, and High Risk, based on factors such as geographic location, nature of business, transaction behavior, and source of funds.

  • Standard Due Diligence (SDD): Applied to low-risk individuals/entities
  • Customer Due Diligence (CDD): Applied to the majority of clients
  • Enhanced Due Diligence (EDD): Mandatory for high-risk clients, including politically exposed persons (PEPs), clients from high-risk jurisdictions, or those engaged in complex structures or opaque transactions

EDD measures may include:

  • In-depth source of wealth verification
  • Senior management approval
  • Ongoing transaction monitoring
  • Adverse media screening

7. Ongoing Monitoring and Review

Global Magnate Capital Ltd. performs continuous monitoring of client accounts and transactions to detect suspicious or unusual activity. Key practices include:

  • Real-time transaction alerts
  • Periodic client data re-verification (KYC refresh cycles)
  • Risk re-assessment upon material change in client profile
  • Automated screening against global sanctions and watchlists

All client records are maintained for a minimum of seven (7) years from the date of last activity or account closure, in compliance with applicable record-keeping regulations.

8. Data Privacy and Confidentiality

All client data collected during the KYC process is handled in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act of Saint Lucia, ensuring:

  • Secure storage of personal information
  • Restricted access based on need-to-know principles
  • Use of data strictly for legal, regulatory, and compliance purposes
  • Timely data subject rights (access, rectification, erasure, restriction)

9. Sanctions Compliance and PEP Screening

Global Magnate Capital Ltd. strictly prohibits onboarding or transacting with:

  • Individuals or entities on OFAC, UN, EU, or UK sanctions lists
  • Jurisdictions classified as high-risk or non-cooperative by the FATF
  • Politically Exposed Persons (PEPs) without completing EDD and senior-level approval
  • Shell banks or anonymous accounts

10. Client Obligations

Clients are required to:

  • Provide accurate and truthful information during onboarding
  • Cooperate fully with all identity verification and documentation requests
  • Promptly inform the Company of any material changes to their KYC information
  • Acknowledge that failure to comply with KYC obligations may result in account suspension, restriction, or termination

11. Reporting Suspicious Activity

Global Magnate Capital Ltd. is legally obligated to report any suspicious activity or transactions to the appropriate authorities in Saint Lucia, including the Financial Intelligence Authority (FIA), without prior notice to the client. This may include:

  • Unusual or disproportionate transaction volume
  • Structuring or evasion of thresholds
  • Incomplete or falsified KYC documentation
  • Activity inconsistent with stated client profile

12. Policy Review and Amendments

This Policy is subject to annual review or more frequently where regulatory developments or internal risk assessments necessitate amendment. Updates shall be communicated via our official channels, and continued use of our services shall constitute acceptance of the revised Policy.

13. Contact Information

Compliance Department – Global Magnate Capital Ltd.

  • Business Address: Foster Capital Inc., Robin Kelton Building, Choc Bay, Castries, Saint Lucia
  • Email: compliance@magnatefx.com
  • Website: https://magnatefx.com