General

In order to ensure the compliance with international trade standards Altitude Trading Limited (hereinafter referred to as “we” or “ATL”) operate in accordance with the legislation on combating illicit money laundering and countering terrorism financing. To monitor the accordance with legal requirements and recommendations of FATF, ATL has Anti-Money Laundering and Know Your Customer (AML / KYC) procedures, for determining the policy of engagement with any person who intend to become our customer.

AML / KYC Rules

As our client you irrevocably agree with the following rules and undertake to observe them:

• You are obliged to follow ATL's AML and KYC requirements while you are our client. Upon the request of the ATL the additional documents and information should be provided by you. Filling of the respective KYC questionnaire may also be an obligatory requirement under Company's sole decision. You agree with such requirements of the Company and undertake to follow them;
• The withdrawal of any assets is carried out only to the account that belongs to you. The withdrawal of Assets to third parties is prohibited. Internal transfers between the Company's customers are also forbidden;
• The Company is obliged and has the right without obtaining prior consent to share with financial institutions and law enforcement agencies any information about you, as required by applicable law, and you give ATL consent to these actions. In order to comply with this paragraph, ATL holds a records about your transactions for the last seven years at least;
• You undertake to follow the legislation, including international ones, aiming to combat illicit trafficking, financial fraud, money laundering and legalisation of funds obtained by illegal means. You should use your best efforts to avoid direct or indirect participation in illegal financial activities and any illegal transactions using the ATL's Website and Services;
• You guarantee the legal origin, legal ownership and the right to use the assets transferred to your account. In case of the evidence of suspicious transactions in your account, cash replenishments from untrusted sources ATL reserves the right to conduct an internal investigation, to suspend or close all your positions, accounts, and to suspend operations on the accounts before the end of the official investigation. When making the decision ATL is guided by the provisions of the applicable law, FATF recommendations or by common practice;
• ATL has the right to request additional information about you if the method of withdrawal is different from the depositing method. The Company also reserves the right to suspend your account during the investigation if you refused to provide the additional information requested by ATL;
• In the course of investigation, ATL has the right to request additional copies of documents confirming your identity or identity of other individuals in corporate structure, as well as documents confirming place of living and lawful possession and legal origin of funds. ATL also has the right to demand the provision of original documents for review in case of any doubts from ATL's side;
• ATL does not provide Services to the persons and legal entities who are located at the jurisdictions that are “blacklisted” by FATF. Also ATL does not provide services to citizens and residents of U.S.A;
• ATL refuses to perform the operations that from ATL’s point of view are considered to be suspicious. The use of preventive measures (such as suspending or closing of a customer's account) is not the reason for civil liability of the Company for failure to fulfill obligations to you;
• ATL is not obliged to inform you or other persons about the measures taken to fulfil the AML/CFT legislation. Also ATL is not obliged to inform you or other persons about any suspicions, about the reasons for refusal of execution of your trading order, refusal to open the account, need for providing any documents, etc;
• This document is just a summary, which goal is to clarify ATL's rights and intention to contribute in worldwide AML initiative. However, each Company has its own internal AML&KYC procedures and rules, that may supplement rules specified in this summary. Nothing in this summary should be understood as an immutable rule that cannot be supplemented by a local AML policy;
• This Anti-Money Laundering and Know Your Customer policy is an integral part of any agreement concluded between you and ATL. Non-compliance with this policy can be a ground for termination of the agreement at the ATL's sole discretion.