Anti Money Laundering Policy

Sogor Capital Limited
Registration No.: 2025-00522
Registered Address: Ground Floor, The Sotheby Building, Rodney Bay, Gros-Islet, Lucia LC01 101
Jurisdiction: Saint Lucia
Business Activities: Online Currency Trading, Financial Services, Brokerage and Financial Services

1. Policy Statement

Sogor Capital Limited is committed to preventing money laundering, terrorist financing, and all other financial crimes. The company fully adheres to all applicable AML/CFT (Counter Financing of Terrorism) laws and regulations of Saint Lucia and international standards including those recommended by the Financial Action Task Force (FATF).

2. Purpose of This Policy

• To detect and prevent the use of our services for money laundering or terrorist financing.
• To establish robust internal controls and monitoring systems.
• To protect the integrity and reputation of Sogor Capital Limited.
• To ensure full compliance with all legal obligations.

3. Scope

This policy applies to:

• All employees, directors, agents, and affiliated entities.
• All services including currency trading, brokerage, and financial operations.
• All clients, partners, and third-party providers.

4. AML Compliance Officer

An AML Compliance Officer (MLRO – Money Laundering Reporting Officer) shall be appointed to:

• Oversee the AML program.
• Conduct training.
• File Suspicious Activity Reports (SARs).
• Serve as the point of contact with regulators.

5. Customer Due Diligence (CDD) & Know Your Customer (KYC)

Sogor Capital Limited performs full KYC before onboarding any customer. This includes:

• Verifying the customer's identity using reliable, independent documentation (e.g., passport, utility bills).
• Understanding the nature and purpose of the business relationship.
• Determining the source of funds.
• Ongoing monitoring of transactions.

Enhanced Due Diligence (EDD) will be applied in cases such as:

• High-risk customers
• Politically Exposed Persons (PEPs)
• Unusual or large transactions

6. Sanctions and Watchlist Screening

Clients will be screened against:

• United Nations Sanctions List
• OFAC (U.S.) Sanctions List
• EU and other relevant international sanctions lists
• PEP databases

7. Transaction Monitoring

• All customer transactions are monitored for unusual activity.
• Automated systems may be used to flag transactions.
• Manual reviews will be conducted in suspicious cases.
• Red flags include: structuring, rapid movement of large funds, or transactions inconsistent with customer profile.

8. Suspicious Activity Reporting (SAR)

If suspicious activity is identified:

• A report will be filed to the Financial Intelligence Authority (FIA) of Saint Lucia.
• The AML Officer will maintain a confidential record of all SARs.
• All employees are required to report any red flags to the AML Officer immediately.

9. Record Keeping

Records will be maintained for at least five (5) years, including:

• Customer identification documents
• Transaction records
• Internal reports and SARs

10. Employee Training

• Regular AML training will be provided to all employees.
• Training will cover customer identification, red flag detection, and reporting procedures.
• Refresher training will be conducted annually or as required.

11. Independent Audit

• An independent AML audit will be conducted at least once every two years.
• The results of the audit will be reviewed by senior management.

12. Non-Compliance and Penalties

• Disciplinary action will be taken against any employee who violates AML policy.
• Severe violations may result in termination and reporting to regulators.

13. Policy Review

This policy will be reviewed and updated annually or whenever required by law or business changes.

Approved by:
Director, Sogor Capital Limited
Date: 17-08-2025