FundedBits Anti-Money Laundering (AML) Policy

1. Purpose & Commitment

FundedBits is fully committed to preventing money laundering, terrorist financing, and other illicit financial activities. This policy outlines our approach to detecting, preventing, and reporting suspicious activities, ensuring full compliance with applicable laws and regulations in every jurisdiction we operate in.

2. Scope

This AML Policy applies to:

• All FundedBits employees, contractors, consultants, and affiliated persons.
• All clients, counterparties, or customers interacting with FundedBits.

Every individual under the FundedBits umbrella must adhere to these guidelines, without exception.

3. Customer Due Diligence (CDD)

1. Customer Risk Assessment
   • Every new account is assigned a risk rating (low, medium, or high) based on factors like location, trading patterns, and background information.
   • Higher-risk accounts undergo Enhanced Due Diligence (EDD), which may include closer scrutiny of account activity and ongoing monitoring.

4. Ongoing Monitoring

• Transaction Reviews: FundedBits continuously monitors client accounts to identify unusual or high-risk activities (e.g., rapid large trades, frequent withdrawals, or transactions that don’t match typical trading behavior).
• Periodic Updates: We may request updated information from clients over time, especially if there are changes in account activity or other red flags.

5. Transaction Monitoring & Record-Keeping

1. Automated Monitoring
   
   • FundedBits uses automated software to flag suspicious trading patterns or money flows in real time.
   • Any flagged alerts are reviewed by our compliance team, who may escalate them if further investigation is needed.
2. Record Retention
   
   • All  documents, transaction histories, and correspondence are securely stored for at least 5 years (or longer, if required by local laws).
   • We maintain clear audit trails of all transactions to ensure transparency and facilitate regulatory inspections.

6. Suspicious Activity Reporting (SAR)

1. Identification of Suspicious Activities
   • Suspicious activities include, but are not limited to, unusually large transactions, sudden changes in trading patterns, or attempts to evade KYC requirements.
2. Internal Reporting
   • Employees must immediately report any potential red flags to the AML Compliance Officer.
   • The Compliance Officer investigates and decides if a Suspicious Activity Report (SAR) must be filed with the relevant authorities.
3. Confidentiality
   • All SARs are strictly confidential. FundedBits employees should never inform a client or third party that a SAR has been filed (“tipping off” is prohibited by law).

7. Employee Training & Awareness

• FundedBits provides mandatory AML training to all relevant personnel upon hiring and on a regular schedule thereafter.
• Training covers the legal framework, identifying suspicious behavior, reporting procedures, and updates on new regulations or emerging risks.
• Employees are accountable for staying current with all AML procedures and must certify completion of training modules annually.

8. Compliance Officer & Governance

• AML Compliance Officer: A designated individual oversees the AML program, updates policies, conducts risk assessments, and serves as the primary contact for authorities.
• Senior Management Oversight: Management fully supports the AML policy, ensuring that adequate resources and authority are provided for its effective implementation.
• Independent Audit: FundedBits may conduct periodic audits of its AML system to verify compliance, identify gaps, and implement necessary improvements.

9. Non-Compliance & Disciplinary Measures

• Any employee or contractor found violating AML policies, whether through negligence or willful misconduct, will face disciplinary action up to and including termination of employment or contract.
• FundedBits reserves the right to close or freeze accounts that breach AML rules, pending further investigation.

10. Policy Review & Updates

• This AML Policy is reviewed at least annually (or more frequently if regulatory changes occur).
• Any changes or enhancements are communicated promptly to all employees and relevant stakeholders.

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Conclusion

At FundedBits, we leave zero room for error when it comes to AML compliance. Our robust policies and procedures help safeguard our clients, our firm, and the broader financial ecosystem. By diligently adhering to these guidelines, we maintain our commitment to integrity, transparency, and the highest ethical standards in prop trading.

Approved by: FundedBits Management & Compliance Team
Effective Date: 01/01/2025

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