Anti-Money Laundering (AML) Policy

1. INTRODUCTION
2. VENTRATRADE AML POLICY
3. ACCOUNT OPENING PROCEDURES – KNOW YOUR CUSTOMER POLICY (“KYC”)
4. BANK ACCOUNT REQUIREMENTS
5. FUNDS WITHDRAWAL PROCEDURE
6. COMPLIANCE FOOTNOTE

ANTI-MONEY LAUNDERING POLICY INTRODUCTION

VentraTrade.com is operated by Luxon LTD, incorporated in St. Lucia under registered number No.2025-00541 by the registrar of International Business Companies, with its registered office at Fortgate Offshore Investment and Legal Services Ltd., Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia.

VentraTrade complies with relevant acts and regulations, including:

• Financial Intelligence Centre Act, 2001 (Act No. 38 of 2001)

• Protection of Constitutional Democracy against Terrorist and Related Activities Act, 2004

• Financial Intelligence Centre Amendment Acts (2008 & 2017)

• Financial Sector Regulation Act, 2017

• Financing Control Regulations under Money Laundering and Terrorist Financing Control Regulations

VentraTrade also operates in line with FATF Recommendations to combat money laundering, terrorist financing, and related threats.

VENTRATRADE AML POLICY

VentraTrade is devoted to preventing money laundering and identifying suspicious transactions. Key measures include:

• Verifying client identity and residence

• Understanding the client’s business nature

• Checking the purpose of the business relationship and source of funds

• Monitoring and reporting suspicious transactions

• Keeping records for at least 5 years after termination of the business relationship

• Reporting suspicious activities to authorities depending on client location

Additionally, VentraTrade:

• Collects, verifies, and updates personal identification information at least annually

• Tracks suspicious transactions and non-standard trading conditions

• Does not accept third-party or cash deposits

• Matches deposits to the account name on file

• Monitors funding from bank accounts outside the client’s home country

• Reserves the right to refuse transactions linked to money laundering or criminal activity

• All client funds are held in separate, segregated accounts for deposits and withdrawals

ACCOUNT OPENING PROCEDURES – KNOW YOUR CUSTOMER (KYC)

Account Opening Requirements:

• Clients must have permanent residence outside the European Economic Area (EEA) and be over 18 years old

• Complete the account opening application with personal and economic information

• Complete the appropriateness test

• Provide identification documents (Proof of Identity and Proof of Residence)

Timeframe:

• Clients have 1 month from application submission to provide required documents. Failure to do so results in application decline, and any deposits will be refunded via the original method.

Identification Documents – Proof of Identity:

• Valid Passport

• National Identity Card

• Government-issued ID (e.g., Driver’s License)

• Residence Permit

Must be in client’s name with visible photo; updated upon expiration.

Proof of Residence:

• Utility or phone bill

• Bank statement

• Governmental document (tax bill or residence certificate)

Must be recent (not older than 6 months), show name, permanent address, and date of issue; updated at least annually.

VentraTrade may request additional documents when necessary.

BANK ACCOUNT REQUIREMENTS

VentraTrade account holders must have a valid bank or credit card account in their name. Statements must match the name and address provided in the account application.

FUNDS WITHDRAWAL PROCEDURE

Withdrawal follows strict principles to ensure funds are sent back to the original source:

1. Complete a signed withdrawal request with correct account information

2. Submit the form to the VentraTrade Finance Department, which will:

   • Confirm account balance

   • Verify documents and account approval

   • Check for holds or withdrawal restrictions

   • Ensure funds are withdrawn via the original deposit method

   • Review deposit history for suspicious activity

   • Verify bank account details

If no issues are found, funds are released. Suspicious activity triggers review by VentraTrade AMLCO and Management, who decide whether to notify regulatory bodies.

Note: Accounts must be verified for withdrawals to be processed.

COMPLIANCE FOOTNOTE

• AML compliance procedures above summarize VentraTrade Compliance Team guidelines

• Full Compliance Policy is available to qualified institutions, regulators, and counterparties

• VentraTrade reserves final authority regarding document validity

Clients should assume that all information provided may be available to:

1. Competent regulatory authorities in the company’s incorporation country

2. The country of origin of funds transmitted

3. The destination country of withdrawn/refunded funds

VentraTrade will not engage in business if funds come from criminal activities or illegal account transactions.

The Company may review or amend its AML Policy at any time. This policy is informative and not contractually binding.

Compliance Contact:

• Email: compliance@ventratrade.com

• Address: Compliance Department, Luxon LTD, Fortgate Offshore Investment and Legal Services Ltd., Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia

• Website: www.ventratrade.com

• Email: info@ventratrade.com