Anti-Money Laundering (AML) Policy

Last updated: 9 October 2026

This policy explains how Atlas Prime works to prevent its services from being used for money laundering or terrorist financing, and what that means for you as a client.

“Atlas Prime” is a trade name. Client accounts are opened and held with Atlas Prime Ltd, a company incorporated in Saint Lucia under registration number 2024-00754, with its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia.

In this policy, “we”, “us” and “our” mean Atlas Prime Ltd. “You” and “your” mean a client or a person applying to become a client.

Other companies also use the Atlas Prime name. They are named at the foot of our website at atlasprimefx.com. Your account is with Atlas Prime Ltd and not with any of those companies.

We are committed to preventing the use of our services for money laundering or terrorist financing, and to complying with the anti-money laundering (AML) and counter-terrorist financing (CTF) laws that apply to us. We require our management and employees to comply with those laws and with this policy.

1. Purpose and Scope

This policy sets out the principles and procedures we apply to detect, prevent and report attempts to launder money or finance terrorism through our services.

It applies to all clients, employees, introducing brokers, partners and third parties that interact with us.

It is one of four documents you are asked to accept when you register in your client cabinet. The others are our Terms of Use, our Privacy Policy and our High-Risk Investment Warning.

2. Money Laundering and Terrorist Financing

Money laundering is the process by which the proceeds of crime are converted into assets that appear to have a legitimate origin.

Terrorist financing is the provision or collection of funds with the intention that they be used to carry out acts of terrorism.

Both are criminal offences under the laws of the countries in which we operate. Financial services, including trading accounts, can be misused for these purposes. The checks and controls described in this policy are designed to prevent that.

3. Customer Due Diligence (KYC)

Customer Due Diligence, also known as “Know Your Customer” or KYC, is the set of checks we carry out to confirm who our clients are and to understand where their funds come from. We carry out Customer Due Diligence on every client before opening an account and permitting deposits, trading or withdrawals.

What We Check

Customer Due Diligence includes, at a minimum:

• Identity. We verify your identity using a valid government-issued photo identity document. This means a passport, a national identity card or a driving licence.
• Residential address. We verify your residential address using a recent utility bill, bank statement or equivalent document, typically issued within the last six months.
• Source of funds and source of wealth. We collect information on your source of funds and, where relevant, your source of wealth. Your source of funds is where the money you deposit comes from. Your source of wealth is how you came to have your wealth as a whole.
• Sanctions and politically exposed persons. We screen clients against applicable international sanctions lists and politically exposed person (PEP) databases. Broadly, a politically exposed person is someone who holds, or has held, a prominent public position. Close family members and close associates of such a person may be treated in the same way.

We reserve the right to request additional documents at any time, and to refuse, suspend or close an account where satisfactory information is not provided.

What to Expect in Practice

For you as a client, the checks described above mean the following:

• You complete verification in your client cabinet.
• Under our Terms of Use, the information you give us must be accurate, current and complete, and you must keep it up to date.
• To help avoid delay, provide clear and complete copies of valid documents, and check that the name on them matches the name you registered with.
• We may ask you for documents or information more than once, including after your account has been opened.
• You cannot deposit or trade until verification is complete. The opening of your account may be delayed while our checks are completed.
• If we carry out further checks later, the processing of a transaction may be delayed. Until those checks are completed, you may be unable to trade or withdraw.
• The law may limit what we are allowed to tell you. Where it does, we may be unable to explain why a check is being carried out, or why an account or a transaction has been delayed, refused, suspended, frozen, reversed or closed.
• The documents and information you give us contain personal data. Our Privacy Policy explains how it is collected, used and protected.

4. Enhanced Due Diligence

We apply Enhanced Due Diligence where a client, a transaction or a jurisdiction presents a higher risk. This includes cases involving:

• politically exposed persons;
• clients from high-risk jurisdictions; or
• unusually large or complex transactions.

Enhanced Due Diligence may include additional verification, approval by senior management and closer ongoing monitoring.

If Enhanced Due Diligence applies to you, we may ask you for more information or documents, and our checks may take longer. Enhanced Due Diligence is applied on the basis of risk. It does not by itself mean that we suspect you of wrongdoing.

5. Ongoing Monitoring

We monitor client activity on an ongoing basis. We do this to identify transactions that are unusual, that are inconsistent with a client’s profile, or that have no apparent economic or lawful purpose.

If we identify a transaction of this kind, we may ask you for information or documents that explain it.

6. Deposits and Withdrawals in Your Own Name

Deposits and withdrawals are expected to be made through accounts held in your own name.

Third-party funding is not permitted. This means that your account must not be funded from a bank account, card or other payment method that belongs to another person or business.

We may ask you for evidence that a payment method is held in your name.

7. Sanctions and Restricted Jurisdictions

We do not provide services to individuals or entities that are subject to applicable international sanctions.

We also do not provide services to residents of jurisdictions where the provision of our services is prohibited or restricted. We do not offer services to residents of certain jurisdictions, including but not limited to the United States of America, Canada, Australia, Singapore, New Zealand, North Korea, Myanmar, Cuba, and other restricted regions. This is not a complete list. If you are not sure whether we can provide services where you live, please ask us before you apply (see section 12).

It is your responsibility to make sure that your use of our services complies with the laws and regulations of your country of residence.

8. Suspicious Activity: Reporting and Restrictions

Our employees are required to report any knowledge or suspicion of money laundering or terrorist financing to our compliance function.

Where we are required to do so, we will report suspicious activity to the relevant authorities.

We may delay, refuse or reverse a transaction, and we may freeze an account, where we have reasonable grounds to suspect that it is connected with financial crime.

While a transaction is delayed or an account is frozen, you may be unable to deposit, withdraw or trade. Where the law does not allow us to, we will not tell you whether a report has been made or explain the reason for the action we have taken.

9. Record Keeping

We keep client identification records, account files and transaction records for the period required by applicable law. This is generally at least five years after the end of our business relationship with you. Where you hold an account, we keep these records for a minimum of five years from the date your account is closed.

Communications that are relevant to a trade or a dispute are kept where the law requires it, or while a dispute, regulatory inquiry or legal proceeding is pending.

Because we are required to keep these records, we cannot delete them before the retention period ends, even if you ask us to close or delete your account. Our Account Deletion Policy explains what is deleted on request and which records must be kept. Our Privacy Policy explains how your personal data is collected, used and protected.

10. Training and Responsibility

We provide AML and CTF awareness training to relevant staff.

Overall responsibility for AML and CTF compliance rests with our management.

11. Changes to this Policy

We keep this policy under regular review to reflect changes in law, regulation and best practice. When we change it, the updated version will be posted on this page with a revised “Last updated” date and will take effect when it is posted. We may also tell you about important changes by email or through your client cabinet. Please check this page from time to time.

12. Contact Us

If you have a question about this policy, or about a check or a request we have made, please contact us at support@atlasprimefx.com.

If you want to make a complaint, our Terms of Use explain how to do so.