Aml Policy

Introduction and Scope

This Anti‑Money Laundering (AML) Policy governs all activities conducted by 6rt in relation to onboarding, customer due diligence, ongoing monitoring, and all financial interactions. It establishes the controls required to detect, deter, and report money laundering and the financing of terrorism, in full compliance with applicable laws and international standards. This Policy applies to all customers, prospective customers, employees, agents, payment service providers, and business partners engaged with 6rt. It is reviewed at least annually and updated as required by regulatory developments or changes in business operations.

Regulatory Framework and Risk‑Based Approach

6rt adopts a risk‑based framework to AML/Countering the Financing of Terrorism (CFT) compliance. The Company identifies and assesses money laundering and terrorist financing risks by customer type, jurisdiction, products and services, delivery channels, and transaction patterns. Controls are proportionate to the identified risk and are designed to prevent, detect, and report suspicious activity. 6rt cooperates with competent authorities, retains records as required, and shares information where legally permissible and necessary to fulfill regulatory obligations.

Customer Identification and Verification (KYC)

On initial engagement and at ongoing intervals, 6rt collects information to identify the Client and verify their true identity. Onboarding requires the Client to provide:

• Full legal name, date of birth, country of residence, mobile number, and email address; and
• For individuals: a government‑issued identity document (e.g., passport, national ID, driver’s license) and, where available, proof of address (utility bill or bank reference) not older than three months; and
• For legal entities: corporate documents, beneficial ownership information, and precise data on ultimate beneficial owners.

6rt may request additional information or documents to satisfy identity verification and to mitigate risk. Verification may involve scanning, photographic copies, and cross‑checking with screening tools for sanctions, negative media, and Politically Exposed Persons (PEPs). The Client shall promptly provide requested documents. Where verifications cannot be completed satisfactorily, 6rt may suspend or terminate the account and restrict related transactions.

Ongoing Monitoring and Customer Due Diligence

6rt maintains ongoing due diligence throughout the business relationship. Customer risk ratings are reviewed and updated if there are material changes in information, behavior, or volume of activity. High‑risk indicators (e.g., unusual transaction patterns, rapid changes in jurisdiction, or discrepancies between profile data and activity) trigger enhanced monitoring and investigated inquiries. Clients must notify 6rt of changes to personal or contact information promptly.

Payment Processing, Funds and Transfers

To minimize AML/CFT risks, 6rt does not accept or remit cash payments. All funds originate from the named payer and are performed through established payment channels that correspond to the Client’s registered details. Key requirements:

• Payments must be initiated by and attributable to the Client in 6rt records; third‑party deposits are not accepted.
• Withdrawals are processed to the same payment method and to the same account used for deposits, to the extent technically feasible; 6rt may require additional verification for withdrawals.
• Withdrawals shall be conducted in the same currency as the original deposit, unless a conversion is explicitly approved under policy terms.
• Recordkeeping of transactions is maintained for a minimum of five (5) years following the termination of the business relationship.

Where verification or source of funds is in question, 6rt may delay, suspend, or refuse transactions consistent with AML/CFT obligations and regulatory requirements.

Enhanced Due Diligence and High‑Risk Scenarios

Clients or circumstances presenting higher risk—such as high‑risk jurisdictions, unusually large or complex transactional activity, or involvement of PEPs—trigger enhanced due diligence (EDD). Controls may include:

• Requesting detailed source of funds and wealth information;
• Collecting additional identity documents and corporate ownership information;
• Instituting intensified ongoing monitoring and periodic reviews at defined intervals; and
• Requiring independent confirmation of information where appropriate.

6rt conducts country and geographic risk assessments and applies heightened scrutiny to customers connected to jurisdictions with elevated AML/CFT risk as identified by applicable regulators and international bodies.

Screening, Sanctions, PEPs, and Beneficial Ownership

On onboarding and at regular intervals, 6rt screens customer data against sanctions lists, PEP lists, and adverse media indicators. For corporate accounts, 6rt collects and maintains accurate information on beneficial ownership and control structures. Any positive match or risk indicator initiates further verification, enhanced monitoring, or potential account restriction in line with regulatory requirements.

Risk Assessment Methodology

6rt conducts a formal risk assessment to identify threats, vulnerabilities, and potential consequences of money laundering and terrorist financing. The assessment addresses:

• Threats posed by customers, products, services, and geographies;
• Vulnerabilities in the control environment and transaction channels;
• Potential consequences for the Firm, customers, and the financial system.

The objective is to prioritize mitigation actions based on risk significance, not to perform merely procedural compliance. The assessment is updated to reflect changes in products, technologies, and customer demographics.

Suspicious Activity Reporting and Escalation

All employees must report grounds for knowledge or suspicion of money laundering or related wrongdoing to the Money Laundering Reporting Officer (MLRO) immediately and no later than 24 hours after becoming aware. 6rt maintains strict confidentiality; disclosure (tipping off) to the customer or other parties is prohibited. The MLRO reviews reports and, where warranted, files a report with the appropriate authorities in accordance with statutory timelines and procedures. Escalation to senior management occurs for high‑risk or high‑severity concerns, with documentation retained for audit purposes.

Roles and Responsibilities

Senior management bears ultimate responsibility for AML/CFT compliance. The MLRO is a designated senior official responsible for receiving disclosures, coordinating internal investigations, and reporting to regulators as required. All employees receive training on AML/CFT obligations and the proper procedures for identifying, escalating, and reporting suspicious activity.

Training and Awareness

6rt provides ongoing AML training to all staff. Initial training covers customer due diligence, transaction monitoring, and reporting obligations; ongoing sessions address evolving threats, emerging typologies, and changes in regulatory expectations. Training records are maintained and reviewed at least annually.

Record Keeping and Data Management

6rt preserves information related to customer identity, verification, risk assessments, transaction records, SARs, internal communications, and training logs for a minimum of five (5) years following the end of the business relationship. Records are stored securely and are accessible to authorized personnel and regulatory authorities as required by law.

Governance, Audits and Compliance

AML governance rests with the Compliance Function and a designated risk committee. The MLRO and Compliance Officer participate in governance meetings and are empowered to obtain resources, initiate investigations, and suspend or close accounts as needed. Regular internal and, where required, external audits assess the effectiveness of controls, procedures, and training; findings drive remedial actions and policy updates.

Prohibited Practices and Penalties

Prohibited conduct includes tipping off, facilitating anonymous accounts, and enabling activities that obscure the source or destination of funds. Any attempt to bypass verification, misrepresent identity, or create duplicate accounts is grounds for immediate suspension or termination of the relationship, with potential withholding of winnings, forfeiture of bonuses, and recovery of misappropriated funds as permitted by law.