Anti-Money Laundering (AML) Policy

Introduction

Ruby Markets is committed to maintaining the highest standards of conduct in all of our dealings and to complying fully with all applicable anti-money laundering (AML) and counter-terrorist financing (CTF) laws and regulations.

Know Your Customer (KYC)

We implement comprehensive KYC procedures to verify the identity of our clients. These procedures include:

• Collecting and verifying identity documents
• Confirming the source of funds
• Understanding the nature and purpose of client relationships
• Regular verification updates

Customer Due Diligence (CDD)

Ruby Markets conducts appropriate customer due diligence on all clients before establishing business relationships. This includes obtaining information about the beneficial owners and the nature and purpose of the business relationship.

Enhanced Due Diligence (EDD)

For high-risk clients and transactions, we conduct enhanced due diligence, which may include:

• Obtaining additional information about the source of wealth
• Conducting additional background checks
• Enhanced ongoing monitoring
• Periodic verification of information

Suspicious Activity Reporting

Ruby Markets has established procedures to identify and report suspicious activities. We monitor all transactions and account activities to detect any suspicious patterns and report these to the relevant financial authorities as required by law.

Sanctions Compliance

We maintain comprehensive sanctions screening procedures to ensure we do not knowingly conduct business with individuals or entities on government sanctions lists. All clients are screened against the following lists:

• UN Security Council Consolidated Sanctions List
• OFAC Specially Designated Nationals List
• EU Consolidated Sanctions List
• Other applicable national and international lists

Record Keeping

Ruby Markets maintains comprehensive records of all client transactions and activities. These records are kept in accordance with applicable regulations and are available for inspection by relevant authorities.

Training

All employees of Ruby Markets receive regular training on AML and CTF requirements to ensure compliance with applicable laws and regulations.