Anti Money Laundering (AML)
Definition This Anti-Money Laundering Policy (“AML Policy”) is testimony to the Company’s commitments against money laundering, financing of terrorism, and related illegal activities. It describes the Company’s policies and procedures instituted to ensure that the Users are not using the Services offered by the Company to facilitate the commission of any criminal offenses, including but not limited to those under Corruption, Drug Trafficking, and Other Serious Crimes (Confiscation of Benefits), Terrorism (Suppression of Financing) and relevant applicable laws. The Company has prepared this AML Policy to ensure the transparency of trading and prevent money laundering and other illegal activities.

The terms “We”, “Our”, “Company”, “Al Wiser Algo” and “Us” refer to the Company, and the terms “User”, “You” and “Your” refer to a User of our Online Platforms.

This AML Policy applies uniformly to any User desirous of availing the Services or otherwise using or benefitting from the use of the Online Platforms. It may be read as a part of the User Terms and Conditions. You must read this AML Policy before using the Online Platforms or submitting any personal information. By using the Online Platforms, you are expressly consenting to be bound by the User Terms and Conditions and consequently this AML Policy

Definitions
In this AML Policy:

“Identification Document(s)” refers to:
Passport or official Identification document (such as national Identification card, birth certificate, driver’s license) showing photograph, full name (including aliases), unique identification number, date of birth, nationality, and name change document (if applicable).
Proof of address (e.g., utility or telephone bill, bank statement, or correspondence from a government agency within the last 3 months and displaying full name). P.O. Box mailing addresses are not acceptable.
Such other documents may be notified by the Company from time to time.
“Sanction Lists” refer to lists of natural and juridical persons included under any list circulated by any country or government or international authority, including the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the US Department of State, the United Nations Security Council, the European Union, Her Majesty’s Treasury, the Hong Kong Monetary Authority, or the Monetary Authority of Singapore, and relevant applicable laws.
“Suspicious Transactions” refers to the following activities, whether attempted or executed:
Terrorist Financing: Any transactions which to a person acting in good faith appear to be any funds collected to be used, in full or in part, by any terrorist or related organization, or to carry out activities related to terrorism or terrorist acts, including all “Terrorism Financing Offence” as defined in the Terrorism (Suppression of Financing).
Unusually Complex: Transactions which to a person acting in good faith appear to have been structured in a manner of unusual or unjustified complexity.
Malafide Purpose: Transactions to a person acting in good faith appear to have not been transacted for a bonafide purpose or lack sound economic rationale.
The capitalized terms used herein, but not defined, shall have the meaning given to such terms in the Terms (defined below).

AML Policy Is Part Of Our Terms
This AML Policy is a part of and incorporated within and is to be read along with the User Terms and Conditions (the “Terms”).

Policy Changes
The Company may change and update this AML Policy from time to time. Such changes may be made without prior notice, but any changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review this AML Policy whenever you access the Online Platforms

Your Obligations
You acknowledge that you must ensure compliance with the terms and conditions described in this AML Policy and accord your consent to not using the Services and the Online Platforms in any manner that results in committing/attempting to commit any criminal offenses. You also agree and consent to any changes made to this Privacy Policy in due course and without notice.

You must ensure that any personal information and/or Identification Documents submitted by you belong to you.

You must file a fresh proof of address within six months of making any changes to the address mentioned as per the ‘proof of address’ submitted by you

Purpose of this Policy
To mitigate its risks relating to money laundering and other illegal activities, the Company intends to put in place this policy which has the following elements:
Customer Acceptance Terms;
Risk Management Procedure;
Customer Verification Procedure;
Transaction Monitoring Terms
Customer Acceptance Terms
The Company may either at the time of opening the User Account, while undertaking any transactions, during Periodic Updates, or for any other reason, ensure your compliance with the following:
Require that you undergo a verification process during the activation process of your User Account by submitting your Identification Documents and such other details, as mandated under Clause 8 (Customer Verification Procedure) of this AML Policy.
Require you to furnish such other details as may be deemed necessary by the Company to verify your identity, if the Company has reason to believe that you are a person or entity enlisted in the Sanctions Lists.
Require you to submit such additional information and/or data as may be directed by a competent enforcement authority.
Require you to certify that your Linked Bank Account is held only with a scheduled commercial bank compliant with all Know Your Customer (KYC) procedures mandated.
The Company may, in its sole discretion, refuse to open any new accounts, terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Online Platforms if it is unable to ensure compliance with any of the aforementioned conditions, either due to non-cooperation by the User or due to the details provided by the User being found enlisted on any Sanctions Lists or unreliable or unverifiable to the Company’s satisfaction.
Risk Management Procedure

The Company may categorize its Users including you into low, medium, or high-risk categories, after undertaking an appropriate risk assessment of each User based on the following factors (including without limitation)
Sufficiency and adequacy of identification information submitted under Clause 8 (Customer Verification Procedure)
It’s social and/or financial status
Nature of User’s business/vocational activities
Guidance notes circulated by various governmental and intergovernmental organizations. You acknowledge that to maintain the integrity of the Risk Management Procedure, the Company will keep your risk categorization and any data related thereto confidential. You will not be entitled to seek disclosure of your risk categorization. However, the Company may disclose the User’s risk categorization data to the competent enforcement authority if it finds that a particular User has executed or is likely to execute any Suspicious Transaction.
Customer Verification Procedure
The Company, during activation of User Accounts or while undertaking any transactions or for any other reason, may require for verification of any User’s identity, following details:
In Case of Individuals – one copy of any Identification Document containing their identity and address details; one recent photograph; any other documents about the business/financial status of such individual as may be prescribed by the Company from time to time.
In the Case of Companies – one copy of each of the national official/governmental company search extract equivalent; Certificate of Incorporation; Memorandum and Articles of Association; Board resolution authorizing to transaction on the Online Platform; Identification Documents containing identification and address details of the individual authorized to transact along with a copy of such authorization document.
In the case of a Partnership Firm/Limited Liability Partnership – one copy of each of the national official/governmental company search extract equivalent; Registration/Incorporation Certificate; partnership deed; Identification Documents containing identification and address details of the individual authorized to transact along with a copy of such authorization document. Users must ensure that all copies of the aforementioned Identification Documents are duly certified.
For verification of any User’s identity, the Company may rely on appropriate and licensed third-party service providers to authenticate the Identification Documents and other incidental details provided by the User.
If the Company finds any User information obtained under the procedure described under this Clause to be inadequate, insufficient, or enlisted on the Sanctions Lists, the Company may in its discretion either refuse or terminate (as the case may be) the registration of such User Account or require verification of such User’s Identification Documents again.
Identity Verification

We will ask for your name, mailing address, and other information, and documents that will allow us to identify you in line with the KYC/AML & CTF Policy. Al Wiser Algo has implemented a fully compliant and advanced User onboarding and AML Screening system (“KYC System”) through its Third Party Partner and in correlation with the requirements of the Digital Asset Exchanges. To conduct the Identity verification, we may insist you complete the following KYC process;

Account Creation & Registration
Sanction & PEP Screening
Document Verification
Identity Verification
Liveness check and Face Match
Known Face Search
Email verification
“KYC/AML Policy” shall mean the policies and procedures implemented by Al Wiser Algo to detect and prevent money laundering, terrorist financing, and corruption.
In providing Us with the above-mentioned information, you represent and warrant to confirm that the information is accurate and authentic. Further, you agree to keep Us updated if any of the information you provide changes. If there are any grounds for believing that any of the information you provided is incorrect, false, outdated or incomplete, we reserve the right to send you a letter of demand for corrections, suspend, freeze or terminate all/part of our Services we provide you. If we are unable to reach you with the contact information you provided, you shall be fully liable for any loss or expense caused to Us during your use of our Services.
By accepting these Terms of Service, you authorize Us to make inquiries, whether directly or through Third Party Partners, that we may consider necessary to verify your identity or to protect you and/or Us against fraud or any other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. Further, you expressly acknowledge and agree that your personal information may be disclosed to credit reference and fraud prevention or financial crime institutions or authorities and these institutions or authorities may respond to our inquiries in full.
Require You to furnish such other details as may be deemed necessary by Us to verify Your identity.
Require You to submit such additional information and/or data as may be directed by a competent enforcement authority.
We may, in its sole discretion, refuse to open any new accounts, suspend or terminate existing User Accounts after giving due notice, or refuse to process any transactions on the Platform if it is unable to ensure compliance with any of the aforementioned conditions, either due to non-cooperation by the User or due to the details provided by the User being unreliable or unverifiable to Our satisfaction.
We may limit the functionality of the Platform for Users who have not submitted full verification to us. These limitations may be applied to services on the Platform.
When you create a User Account, a User Identification Number (UID) is assigned by Us to identify you on the Platform. You can find your UID on your Account Dashboard on the website.

You may create a User Account only if you are at least 18 years old before you create an account.
You shall be solely and exclusively responsible for maintaining the confidentiality and security of your login credentials for accessing your account including your username and password. Each User Account UID is unique to each User Account. You will take all possible care to prevent unauthorized disclosure to, and access by, any person of your login credentials. In any event, we are not liable or responsible for any unauthorized access to your User Account. You will immediately notify us of any unauthorized use of your User Account or any other breach of this User Agreement, the other Agreements, or security known to you.
We shall be entitled to presume that any person who logs in with your login credentials is you. You will therefore be responsible for any actions taken using your login credentials.
We may cancel or suspend User Accounts that have been inactive for a long time, exhibit suspicious behavior are doing market manipulation, or are doing other prohibited activities.
Subject to your compliance with these Agreements and the applicable law, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to use and access the Platform. We may deploy technologies or processes to enforce the above grant of rights.
You are also responsible for ensuring that all persons who access the Platform through You/ Your internet connection or network are aware of these Agreements and other applicable terms and conditions and that they comply with them.
No Investment Services. Al Wiser Algo does not provide asset management, portfolio management, personalized investment recommendations, or advisory services to Users within the scope of the Services. Any information provided by Al Wiser Algo to the Users should not be considered advice of any kind. The user passes his investment decision himself and bears all the responsibility.
Transaction Monitoring Terms
All transactions executed and/or attempted to be executed on the Online Platforms are regularly monitored by the Company, both manually and through the use of software-based algorithms, in order to promptly identify and highlight certain kinds of transactions including without limitation.
The Company may, from time to time, undertake a necessary investigation in order to identify and examine transactions inconsistent with any User’s risk profile (determined in accordance with Clause 7 (Risk Management Procedure) above), sophistication, and expected usage pattern.
The extent of monitoring shall depend on various factors including upon each User’s risk profile.
The Company reserves the right to terminate the User Account, restrict and/or prevent access to Online Platforms, or report to the appropriate enforcement authorities the activities of any User in respect of transactions identified under Clause 9 (Transaction Monitoring Terms).
Maintenance Of Records

The Company will maintain and preserve the following information and/or data:
Records of all transactions executed on the Online Platforms, for at least 10 (10) years from the date of each transaction.
Records of all transactions identified under Clause 9 (Transaction Monitoring Terms) above for at least 12 (Twelve) years, including but not limited to the information about the nature, value, and parties to such transactions, and their date of remittance.
Identification records of Users (including but not limited to the Identification Documents submitted under Clause 8 (Customer Verification Procedure) above), during the subsistence of and for at least 10 years from the date of termination of such User Account.
Compliance, Disclosure, And Notices
The Company may share, from time to time, information regarding transactions identified under Clause 9 (Transaction Monitoring Terms), identification information of such Users, or any other information mandated under the applicable law, with the appropriate enforcement authorities.
To improve the integrity and transparency of transactions on Online Platforms, you are encouraged to report any information you are privy to or become privy to in the future regarding any Suspicious Transactions or transactions you have found or have reason to believe are dubious, to our Compliance Officers by writing to them at support@AlWiserAlgo.com.
To ensure compliance with this AML Policy and/or the applicable laws, the Company may be required to send you notices from time to time. All such notices will be sent to such address as provided by you under Clause 8 (Customer Verification Procedure) of this AML Policy. Where you are required to share any information according to the procedures contained in this AML Policy, such communication may be made by you electronically by sending an email to support@AlWiserAlgo.com.