Legal

Anti Money Laundering Policy

Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Document Reference: NC-AML-POL-2026-V2.4
Operating Entity: Novixa Capital Limited
Effective Date: September 1, 2026
Target Scope: All Global Trading Accounts, Deposits, and Withdrawals
Policy Owner: Global Compliance & Risk Management Department
Approval Status: Board Approved & Active

Executive Commitment & Statutory Framework

Novixa Capital Limited is committed to the highest standards of compliance against money laundering (AML) and counter-terrorist financing (CTF). The objective of the Company's Policy against Money Laundering and Terrorism Financing is to actively prevent the risks of these matters across all foreign exchange (Forex) and contract for difference (CFD) brokerage activities.

To help international statutory bodies and governments combat the financing of terrorism and money laundering activities, financial compliance laws require all authorized financial institutions to obtain, verify, and record information that identifies each person or entity opening a trading account. Novixa Capital Limited operates under a strict legal obligation to monitor client activities and report any suspicious client activity relevant to money laundering to appropriate authorities.

Definition & Sequential Stages of Money Laundering

Money Laundering is the process of converting funds or assets received from illegal activities (such as fraud, corruption, organized crime, or terrorism) into other funds or investments that appear legitimate to hide or distort the actual source of funds. The money laundering process can be divided into three sequential stages:

Placement

Funds originating from criminal conduct are converted into financial instruments or deposited into bank accounts and trading accounts. To avoid detection and suspicion, money launderers frequently deposit small amounts over time across multiple channels (a practice commonly referred to as 'smurfing').

Layering

Funds are transferred, converted, or routed through multiple accounts and financial instruments to obscure their original source and interrupt audit trails. In forex trading, this may involve complex trading across currency pairs or rapid inter-account transfers.

Integration

Laundered funds are reintroduced into the economy as apparently legitimate capital through investments, asset acquisitions, or legitimate commercial withdrawals.

Critical Controls

Critical Operating Restrictions

Zero Physical Cash Acceptance

To prevent money laundering, Novixa Capital Limited does NOT accept or pay out physical cash, cash equivalents, third-party cheques, or anonymous money transfers under any circumstances.

Strict Return-to-Source (RTS) Rule

All client withdrawals must be processed directly back to the originating bank account, credit/debit card, or verified wallet from which the initial funds were deposited.

Unilateral Right to Suspend

The company reserves the absolute right to freeze or suspend any financial operation or trading account that appears illegal, fraudulent, or connected to money laundering.

Implementation Framework & Procedures

Novixa Capital Limited ensures that all registered clients are verified real and legal persons or corporate entities. The company performs mandatory due diligence in accordance with applicable statutory regulations. The AML policy is implemented through three core operational pillars:

Know Your Customer (KYC) Policy

Rigorous identity verification and due diligence procedures prior to account activation.

Transaction & Trade Monitoring

Real-time automated and manual surveillance of customer funding and trading activity.

Comprehensive Record Maintenance

Secure archiving of client identity documentation and complete transactional audit trails.

Monitoring Client Activity & Suspicious Red Flags

Novixa Capital Limited continuously monitors ongoing client financial activity to detect, investigate, and prevent suspicious transactions. Suspicious activity includes any transaction or trading behavior that is inconsistent with a client's normal trading pattern, declared financial profile, or apparent commercial purpose.

Key Indicators of Suspicious Activity (Red Flags)

High Deposit Volume with Minimal Trading

A client deposits significant capital and immediately requests a withdrawal without engaging in meaningful market trading.

Third-Party Funding Attempts

Attempts to fund a trading account from a bank account or credit card belonging to an unrelated third party.

Structured Payments (Smurfing)

Multiple incoming deposits submitted just below regulatory identification or reporting thresholds within a short timeframe.

High-Risk Jurisdictional Connections

Transfers originating from or directed toward non-cooperative or high-risk jurisdictions as flagged by international authorities.

Record Maintenance & Audit Standards

To support law enforcement investigations and maintain complete audit capability, Novixa Capital Limited securely stores the records below. Retention standard: all records are maintained in encrypted archives for at least seven (7) years following the formal closure of the trading account or termination of the business relationship.

All individual and corporate client identification records and supporting documentation.

Complete transactional ledgers, trade histories, deposit/withdrawal records, and banking receipts.

Internal AML review notes, risk assessments, and communication logs.

Mandatory Enforcement & Regulatory Reporting Actions

In any case of suspected money laundering or terrorist financing, Novixa Capital Limited acts decisively in full accordance with applicable law and reports details to relevant statutory financial intelligence units (FIUs). The company may execute the following enforcement actions without prior client notification:

Immediate suspension or cancellation of pending trading orders and withdrawal requests.

Freezing or permanent closure of trading accounts involved in suspicious activity.

Termination of the business relationship and blocking of associated access credentials.

Filing of formal Suspicious Activity Reports (SARs) with regulatory authorities.

Last updated September 1, 2026