AML POLICY
Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy
FPT100
Power Of Smart Money Ltd
Version: 2.0
Effective Date: 10 May 2026
Jurisdiction: United Kingdom
Document Classification: Internal Compliance & Operational Policy
1. PURPOSE
This Anti-Money Laundering (“AML”) and Know Your Customer (“KYC”) Policy establishes the framework adopted by FPT100 and Power Of Smart Money Ltd (“the Company”) to prevent, detect, and report any activities related to:
Money Laundering
Terrorist Financing
Fraud
Financial Crime
Identity Theft
Unlawful Source of Funds
Sanctions Violations
The Company is committed to conducting business in a lawful, ethical, and transparent manner while maintaining robust compliance procedures aligned with UK regulatory expectations and international best practices.
2. SCOPE
This policy applies to:
Directors
Employees
Contractors
Affiliates
Sales Representatives
Business Development Partners
Clients
Copy Trading Participants
Academy Students
Signal Subscribers
Strategic Partners
This policy covers all products and services operated under:
FPT100
Power Of Smart Money Ltd
Associated educational, trading, affiliate, investment, networking, or partnership activities
3. REGULATORY FRAMEWORK
This policy is guided by principles contained within:
The Proceeds of Crime Act 2002 (POCA)
The Money Laundering Regulations 2017 (as amended)
Terrorism Act 2000
Fraud Act 2006
UK GDPR & Data Protection Act 2018
OFAC, UK Sanctions List, and international sanctions frameworks where applicable
4. RISK-BASED APPROACH
The Company adopts a risk-based approach to AML compliance.
Higher-risk activities may require enhanced scrutiny, including:
Large deposits or transfers
Third-party payments
Unusual trading activity
Rapid movement of funds
High-risk jurisdictions
Politically Exposed Persons (PEPs)
Anonymous or unverifiable clients
Crypto-related transactions
Clients attempting to bypass compliance procedures
The Company reserves the right to reject, suspend, or terminate any relationship deemed high-risk.
5. CUSTOMER IDENTIFICATION (KYC)
Before onboarding clients into selected services, the Company may request:
Individuals
Full legal name
Date of birth
Residential address
Government-issued photo ID
Proof of address
Contact details
Businesses
Certificate of Incorporation
Director details
Shareholder information
Registered address
Nature of business
Source of funds information
Verification may be conducted manually or through third-party verification systems.
6. SOURCE OF FUNDS & SOURCE OF WEALTH
The Company may request reasonable evidence showing the legitimate origin of funds used within its ecosystem.
Examples include:
Employment income
Business income
Investment profits
Savings
Inheritance
Asset sales
The Company may decline funds where:
The source cannot be reasonably verified
The activity appears suspicious
Documentation is inconsistent
The client refuses cooperation
7. PROHIBITED ACTIVITIES
The following activities are strictly prohibited:
Money laundering
Fraudulent transactions
Chargeback abuse
Use of stolen identities
Sanctions evasion
Terrorist financing
Market manipulation
Use of hacked or compromised payment methods
Use of mule accounts
Illegal investment solicitation
False representation of returns or guarantees
Any violation may result in:
Immediate account suspension
Service termination
Internal investigation
Reporting to authorities where legally required
8. TRANSACTION MONITORING
The Company reserves the right to monitor activity across its platforms and services to identify suspicious behaviour patterns.
Monitoring indicators may include:
Unusual payment sizes
Repeated failed payments
Multiple accounts linked to one individual
Inconsistent identity information
Suspicious affiliate behaviour
Rapid withdrawals after deposits
Abnormal account activity
The Company may request additional verification at any stage of the relationship.
9. SANCTIONS SCREENING
The Company reserves the right to screen clients, affiliates, and counterparties against applicable sanctions lists including:
UK Sanctions List
OFAC Sanctions List
International watchlists
The Company may refuse service to sanctioned individuals, entities, or jurisdictions.
10. RECORD KEEPING
Compliance records may be retained for up to 5 years or longer where legally required.
Records may include:
Identification documents
Transaction history
Communications
Compliance reviews
Internal reports
Risk assessments
All information is handled in accordance with applicable data protection laws.
11. REPORTING SUSPICIOUS ACTIVITY
Where suspicious activity is identified, the Company reserves the right to:
Escalate internally
Freeze or restrict activity
Request additional information
Submit Suspicious Activity Reports (SARs) to relevant authorities where required by law
Employees and representatives must immediately report suspicious behaviour to management.
12. STAFF TRAINING & RESPONSIBILITIES
Relevant personnel may receive periodic AML/KYC awareness training covering:
Fraud indicators
Suspicious transaction detection
Customer verification
Data protection
Compliance obligations
All representatives are expected to:
Act ethically
Follow compliance procedures
Escalate concerns promptly
Maintain confidentiality
13. THIRD-PARTY PAYMENT POLICY
The Company generally discourages or restricts third-party payments unless:
Proper verification has been completed
Satisfactory explanations are provided
Management approval is obtained
Payments may only be accepted from accounts held in the client’s own name unless otherwise approved.
14. CRYPTOCURRENCY POLICY
Where cryptocurrency transactions are accepted:
Additional verification procedures may apply
Blockchain tracing tools may be used where necessary
High-risk wallets or transactions may be rejected
Privacy-enhancing or anonymous transaction methods may be restricted
The Company reserves the right to refuse crypto transactions at its discretion.
15. DATA PROTECTION & CONFIDENTIALITY
All client information collected for AML/KYC purposes shall be:
Stored securely
Accessed only by authorised personnel
Processed lawfully
Protected under applicable UK data protection laws
The Company will not knowingly sell confidential client data.
16. LIMITATION OF SERVICES
FPT100 and Power Of Smart Money Ltd are educational, networking, strategic partnership, trading, and business development brands.
Nothing within the Company’s materials should automatically be interpreted as:
Guaranteed returns
Regulated financial advice
Investment guarantees
Banking services
Custody services unless expressly stated
Participation in trading-related activities carries risk.
17. INTERNAL COMPLIANCE AUTHORITY
Management reserves the right to:
Refuse onboarding
Request additional documentation
Suspend accounts
Decline transactions
Terminate relationships
Amend compliance requirements at any time
Where necessary to protect the integrity of the business ecosystem.
18. POLICY REVIEW
This policy may be reviewed and updated periodically to:
Reflect regulatory changes
Improve internal controls
Address emerging risks
Enhance operational effectiveness
The latest version supersedes prior versions.
19. CONTACT
Compliance Department
Business & Compliance Enquiries
Email: compliance@powerofsmartmoney.com
DISCLAIMER
Trading, copy trading, educational services, and financial market participation carry risk. Past performance does not guarantee future results. Clients are responsible for understanding the risks associated with financial markets and speculative activities.