Anti-Money Laundering Policy

Money laundering is the processing of criminal proceeds to disguise their illegal origin.

CDO Markets has a comprehensive Anti-Money laundering policy, an outline of which is set out below.

Senior management of CDO Markets have a responsibility to ensure that the firm’s control processes and procedures are appropriate and effectively implemented to counter the risk of the firm being used to money laundering and financial crime. Senior management are fully involved in the processes and take ownership of the risk-based approach.

The firm’s Money Laundering Reporting Officer (MLRO) will provide an annual report to the directors on the operation and effectiveness of the firm’s systems and controls to combat money laundering and financial crime. When the report is received senior management will consider the findings and take any action that is required

Money Transfer Policy Overview:

CDO Markets will not, under any circumstances, accept funds from a remitter where the ordering party is not also the beneficiary i.e. No Third Party transfers are accepted, and funds are either returned as unapplied or a dependent on determination of the firm’s Compliance Officer.

Likewise CDO Markets will never disburse funds to a Third Party, and will always “return to sender” i.e. Client Account at CDO to Client account at correspondent bank where the original transfer was made.

Customer Due Diligence

Our firm’s obligations for conducting CDD as well as describing those situations and customers where either “Simplified Due Diligence” (“SDD”) can be applied or where “Enhanced Due Diligence” (“EDD”) must be used.

Core obligations on the firm are:

The prescribed CDD measures must be carried out for all customers not covered by exemptions; Systems must be in place for dealing with those who are unable to produce ‘standard evidence’ EDD must be applied in higher risk cases where the customer is not present and also in relation to Politically Exposed Persons (PEPs); Awareness that some persons/entities must not be dealt with and systems are in place for keeping information up to date. CDD measures that must be carried out involve :Identifying the investor and verifying their identity; Identifying the beneficial owner where relevant and verifying their identity; and obtaining information on the purpose and intended nature of the business relationship The firm monitors and adapts this process as required.