AML & KYC Policy

This Anti-Money-Laundering (AML) and Know Your Customer (KYC) Policy summarises the measures OstinFx Ltd. takes to detect, prevent and deter money laundering, terrorist financing, sanctions evasion and other financial crime. It applies to all clients and to everyone acting on our behalf.

1. Our commitment

We are committed to conducting our business responsibly and to maintaining controls designed to prevent our Services from being used for financial crime. We seek to apply standards consistent with recognised international best practice, including a risk-based approach to customer due diligence and ongoing monitoring, and we cooperate with competent authorities as required by applicable law.

2. Customer due diligence (CDD and EDD)

Before establishing a business relationship, and on an ongoing basis thereafter, we apply customer due-diligence measures proportionate to the risk presented by each client. Where a client, product, transaction or jurisdiction presents a higher risk — for example politically exposed persons or higher-risk geographies — we apply enhanced due diligence (EDD), which may include additional verification, senior-management approval and closer scrutiny of the relationship.

• identifying the client and verifying their identity;
• identifying and verifying any beneficial owner where a client is not a natural person;
• understanding the purpose and intended nature of the business relationship;
• assessing and, where appropriate, obtaining information on the client’s risk profile.

3. Identity verification

We require every client to provide valid identification and to complete our verification process before trading or withdrawing funds. This typically includes a government-issued photographic identity document, proof of current residential address and, where relevant, confirmation that documents belong to the account holder. We may use third-party verification services and may request updated documentation at any time.

4. Source of funds

To ensure that funds used in connection with the Services are legitimate, we may require information and supporting evidence about the source of a client’s funds and, where appropriate, source of wealth. Deposits must originate from an account in the client’s own name; third-party funding is not accepted. We may decline, delay or return transactions that we are unable to verify.

5. Ongoing monitoring

We monitor accounts and transactions on a risk-sensitive basis throughout the business relationship to identify activity that is unusual, inconsistent with our knowledge of the client, or otherwise indicative of financial crime. We keep client information up to date and may request additional documentation to maintain an accurate risk profile.

6. Sanctions and PEP screening

We screen clients and, where relevant, connected parties against applicable sanctions lists and against lists of politically exposed persons (PEPs) and their close associates. We do not provide Services to sanctioned individuals or entities, and relationships involving PEPs are subject to enhanced due diligence and, where required, senior-management approval.

7. Record keeping

We retain records of client identification, verification documents, risk assessments, transactions and relevant correspondence for the minimum periods required by applicable law, and generally for a period after the end of the business relationship. These records enable us to demonstrate compliance and to assist competent authorities where lawfully required.

8. Reporting suspicious activity

Where we identify activity that we know or suspect may be connected with money laundering, terrorist financing or other financial crime, we take appropriate action, which may include internal escalation, requesting further information, restricting activity and reporting to the relevant authorities. Where permitted or required by law, we may do so without notifying the client, and we may be prohibited from disclosing that a report has been made.

9. Prohibited jurisdictions and persons

We do not offer Services to persons in jurisdictions where doing so would be unlawful or would require authorisation we do not hold, nor to sanctioned persons or entities. We may refuse to open, or may close, any account where we determine that continuing the relationship would be inconsistent with this Policy or applicable law. It is your responsibility to ensure that your use of the Services is lawful in your jurisdiction.

10. Responsibility and training

Responsibility for our AML framework rests with senior management, supported by staff responsible for compliance. Relevant personnel receive training appropriate to their role so they can recognise and respond to financial-crime risks, and our controls are reviewed periodically and updated to reflect changes in our business and the regulatory environment.

11. Contact

Questions about this AML & KYC Policy, or compliance-related requests, may be directed to our compliance team at compliance@ostinfx.com, or by post to OstinFx Ltd., Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia.

Last updated: 13 July 2026