Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy

1. Purpose

Investment Funds Direct ("Investment Funds Direct", "the Company", "we", "our", or "us") is committed to maintaining the highest standards of integrity, transparency, and regulatory compliance. This Anti-Money Laundering ("AML") and Know Your Customer ("KYC") Policy outlines the measures adopted by the Company to prevent its services from being used for money laundering, terrorist financing, fraud, sanctions evasion, or any other form of financial crime.

This Policy applies to all clients, prospective clients, beneficial owners, authorized representatives, business partners, and any individual or entity seeking to establish or maintain a business relationship with the Company.

Investment Funds Direct reserves the right to refuse services, suspend trading activity, delay transactions, or terminate business relationships where necessary to comply with applicable laws, regulations, or internal compliance procedures.

2. Regulatory Commitment

Investment Funds Direct is committed to implementing reasonable policies and procedures designed to detect, prevent, and report suspicious financial activity.

The Company maintains internal controls intended to:

• Prevent money laundering.
• Prevent terrorist financing.
• Detect fraudulent activity.
• Identify suspicious transactions.
• Protect the integrity of the financial system.
• Comply with applicable legal and regulatory obligations.

All employees are expected to understand and comply with this Policy and cooperate with internal compliance procedures.

3. Customer Identification (Know Your Customer)

Before providing trading services, Investment Funds Direct requires clients to complete an identity verification process.

Clients may be requested to provide information including:

• Full legal name.
• Date of birth.
• Residential address.
• Nationality.
• Contact details.
• Occupation.
• Source of funds.
• Source of wealth where appropriate.

The Company may request supporting documentation, including:

• Government-issued photo identification.
• Passport.
• National identity card.
• Driver's license where accepted.
• Recent utility bill.
• Bank statement.
• Government correspondence.
• Tax documentation where appropriate.

Investment Funds Direct reserves the right to request additional documentation whenever necessary to verify identity or comply with legal obligations.

Failure to provide satisfactory documentation may result in account restrictions, delayed processing, suspension of services, or account closure.

4. Customer Due Diligence

Investment Funds Direct performs customer due diligence ("CDD") before establishing a business relationship and may continue such reviews throughout the duration of the client's account.

CDD may include:

• Identity verification.
• Address verification.
• Sanctions screening.
• Politically Exposed Person (PEP) screening.
• Adverse media screening.
• Verification of beneficial ownership.
• Risk assessment.
• Ongoing monitoring.

Additional Enhanced Due Diligence ("EDD") measures may be applied where higher-risk circumstances are identified.

5. Ongoing Monitoring

Client accounts are subject to ongoing monitoring throughout the business relationship.

Investment Funds Direct may review:

• Trading activity.
• Deposit patterns.
• Withdrawal requests.
• Account behaviour.
• Changes in client information.
• Transaction frequency.
• Geographic risk indicators.
• Device or login anomalies.

Where unusual or inconsistent activity is identified, additional verification or information may be requested before transactions are processed.

6. Source of Funds and Source of Wealth

Investment Funds Direct may request information regarding the origin of funds deposited into a trading account.

Clients may be asked to provide documentation demonstrating the legitimate source of funds or source of wealth, including but not limited to:

• Employment income.
• Business income.
• Investment returns.
• Property sales.
• Inheritance.
• Savings.
• Dividend income.
• Pension income.

The Company reserves the right to reject deposits where the source of funds cannot be satisfactorily established.

7. Politically Exposed Persons

Investment Funds Direct applies additional scrutiny where a client, beneficial owner, or authorized representative is identified as a Politically Exposed Person ("PEP"), a family member of a PEP, or a close associate of a PEP.

Additional verification measures may include:

• Enhanced identity verification.
• Senior management approval.
• Source of wealth verification.
• Enhanced transaction monitoring.
• Periodic account reviews.

PEP status does not automatically prevent a client from opening an account but may require additional compliance procedures.

8. Sanctions Compliance

Investment Funds Direct is committed to complying with applicable sanctions laws and may screen clients against recognized sanctions lists.

The Company reserves the right to refuse services, suspend transactions, freeze accounts where legally required, or terminate business relationships involving sanctioned persons, entities, or jurisdictions.

Clients are responsible for ensuring that they are legally permitted to use the Company's services within their jurisdiction.

9. Suspicious Activity

Investment Funds Direct monitors account activity for indicators of suspicious or potentially unlawful behaviour.

Examples may include:

• Unusual deposit or withdrawal patterns.
• Transactions lacking an apparent economic purpose.
• Use of false or misleading information.
• Attempts to avoid verification procedures.
• Third-party funding without satisfactory explanation.
• Structuring transactions to avoid reporting thresholds.
• Multiple accounts used inconsistently with legitimate trading.
• Activity inconsistent with the client's known financial profile.

Where suspicious activity is identified, the Company may conduct additional investigations and take appropriate action in accordance with applicable laws.

The Company may be prohibited by law from notifying a client that a report has been submitted to a competent authority.

10. Third-Party Payments

As a general principle, deposits and withdrawals should originate from and be returned to accounts held in the client's own name.

Investment Funds Direct may decline or delay transactions involving third parties where additional verification is required or where such transactions present an elevated compliance risk.

11. Record Retention

Investment Funds Direct maintains records relating to customer identification, account information, transaction history, and compliance activities for the period required under applicable legal and regulatory obligations.

Records are maintained securely and protected against unauthorized access, alteration, or disclosure.

12. Employee Responsibilities

Employees receive appropriate guidance regarding the Company's AML and KYC obligations and are expected to:

• Follow internal compliance procedures.
• Protect confidential information.
• Escalate suspicious activity.
• Cooperate with compliance investigations.
• Complete required compliance training.

Failure by employees to comply with internal AML procedures may result in disciplinary action.

13. Confidentiality

Information collected for AML and KYC purposes is handled confidentially and used only for legitimate business, legal, or regulatory purposes.

Personal information is processed in accordance with the Company's Privacy Policy and applicable data protection laws.

Information may be disclosed to competent authorities where required by law or regulatory obligation.

14. Refusal, Suspension, and Account Closure

Investment Funds Direct reserves the right to refuse account applications, decline transactions, suspend trading activity, restrict account functionality, delay withdrawals, or terminate business relationships where:

• Identity cannot be verified.
• Required documentation is not provided.
• Suspicious activity is identified.
• False information has been supplied.
• Applicable laws or regulations require such action.
• Continued provision of services would expose the Company to unacceptable legal, regulatory, or financial risk.

Such actions may be taken without prior notice where permitted or required by law.

15. Policy Updates

Investment Funds Direct may amend this AML and KYC Policy periodically to reflect changes in applicable legislation, regulatory expectations, industry standards, or internal compliance procedures.

The latest version will be made available through the Company's official website or client portal.

16. Contact Information

Questions relating to this AML and KYC Policy may be directed to Investment Funds Direct using the contact information published on the Company's official website.

Clients are encouraged to cooperate fully with any compliance requests and to notify the Company promptly of changes to their personal information or circumstances that may affect their account.

17. Acceptance

By applying for an account, submitting identification documents, depositing funds, or using the services provided by Investment Funds Direct, the client acknowledges that they have read, understood, and agreed to comply with this AML and KYC Policy.

The client further acknowledges that Investment Funds Direct may request additional information or documentation at any time as part of its ongoing compliance obligations and that failure to cooperate may result in restrictions, suspension, or termination of the business relationship.