CASTLE TRADING ANTI-MONEY LAUNDERING (AML) AND KNOW YOUR CUSTOMER (KYC) POLICY

1. INTRODUCTION

Tayside Fintech Solutions Ltd, trading as Castle Trading (“Castle Trading,” “we,” “us,” or “our”), a company incorporated in Scotland with company number SC809177 and registered office at 2/8 King James VI Business Centre, Friarton Road, Perth, Perthshire, Scotland, PH2 8DY, is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy (“Policy”) outlines our procedures to verify Trader identities, monitor transactions, and ensure compliance with the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”), the UK Sanctions Regime, and international standards such as Financial Action Task Force (FATF) recommendations.

Castle Trading provides virtual trading accounts for simulated trading in financial markets using virtual capital only, through our proprietary platform (the “Platform”). As an unregulated proprietary trading firm, we do not manage real funds or provide investment services but maintain robust AML/KYC measures to ensure the integrity of our Services and protect our Traders and business from financial crime risks.

2. PURPOSE AND SCOPE

This Policy aims to:

Verify Trader identities to prevent fraud, money laundering, and terrorist financing.

Screen Traders against restricted jurisdictions and sanctions lists, including the UK Sanctions List and OFAC.

Monitor transactions and trading activities for suspicious or cheating-like behavior.

Ensure compliance with UK AML regulations and industry-standard practices.

Protect Trader data in accordance with GDPR and the UK Data Protection Act 2018.

This Policy applies to all Traders accessing our Services via www.castle.trading (the “Website”) and is supplemented by our Privacy Policy and General Terms & Conditions.

3. DEFINITIONS

3.1 “KYC”: Know Your Customer procedures to verify Trader identities and assess risks.
3.2 “AML”: Anti-Money Laundering measures to prevent and detect financial crime.
3.3 “Restricted Jurisdictions”: Countries where Services are not offered, listed in Section 5.2.
3.4 “Sanctions Lists”: Lists of individuals, entities, or countries subject to sanctions, including the UK Sanctions List and OFAC.
3.5 “Suspicious Activity”: Transactions or behaviors indicating potential money laundering, terrorist financing, fraud, or cheating-like activities.
3.6 “Trader”: A natural person using Castle Trading’s Services.

4. KYC VERIFICATION PROCESS

4.1 Identity Verification:

KYC verification is required prior to the first payout of simulated profits from Castle Trading Accounts. Subsequent payouts do not require re-verification unless requested under Enhanced Due Diligence (EDD).

Required documents include:

One valid government-issued ID (e.g., passport, driver’s license, national ID).

Proof of address (e.g., utility bill, bank statement, dated within the last 3 months).

Verification is conducted at Castle Trading’s discretion, either in-house or through a third-party provider, ensuring secure and compliant processing.

4.2 Trader Responsibilities:

Traders must complete KYC verification promptly upon request before receiving their first payout.

All provided information must be accurate, complete, and up-to-date. Traders must notify Castle Trading immediately of any changes (e.g., address, ID).

False or fraudulent KYC attempts will result in immediate account termination, nullification of simulated profits, a ban from purchasing further accounts, and no refund.

4.3 Process:

Traders submit KYC documents via a secure portal on the Website or through a third-party provider.

Castle Trading reviews documents within a reasonable timeframe, notifying Traders of approval or additional requirements.

Accounts failing KYC verification are suspended, and payouts are withheld until compliance is achieved.

5. AML COMPLIANCE MEASURES

5.1 Customer Due Diligence (CDD):

Castle Trading conducts CDD at the payout stage to verify Trader identities and assess AML risks.

CDD includes screening against Sanctions Lists (e.g., UK Sanctions List, OFAC) and monitoring IP addresses to confirm Traders are not in Restricted Jurisdictions.

Ongoing CDD is performed periodically or when triggered by suspicious activity.

5.2 Restricted Jurisdictions:

Services are not offered to individuals residing in or nationals of: Burundi, Central African Republic, Cuba, Congo Republic, Crimea, Democratic Republic of Congo, Eritrea, Guinea, Guinea-Bissau, Iraq, Iran, Laos, Liberia, Libya, Myanmar, North Korea, Papua New Guinea, South Sudan, Sudan, Somalia, Syria, Vanuatu, Venezuela, Yemen.

IP monitoring and KYC checks ensure compliance with this restriction, with non-compliant accounts closed immediately.

5.3 Sanctions Screening:

Traders are screened against the UK Sanctions List, OFAC, and other relevant international sanctions lists at onboarding and before payouts, facilitated by third-party KYC providers or in-house systems.

Accounts linked to sanctioned individuals or entities are terminated, and any funds (e.g., registration fees) are returned to the original payment method, subject to legal requirements.

5.4 Payment Monitoring:

Payments for account access (via Paytiko for cards, Coinbase/Blockbee for cryptocurrencies) are monitored to ensure the cardholder or crypto wallet owner matches the Trader’s verified name.

Mismatches result in account closure and return of funds to the original payment method, with no access to Services or payouts.

Castle Trading’s systems flag transactions exhibiting money laundering-like behavior, though the risk is considered low due to small account sizes (up to $5,000 virtual capital).

5.5 Trading Activity Monitoring:

All trading activities are monitored for Forbidden Trading Practices and cheating-like behavior, as defined on the Website’s “Rules” page.

Suspicious trading patterns (e.g., attempts to exploit system inefficiencies, unusual volumes) trigger review by the compliance team, potentially leading to EDD or account termination.

Cheating-like activities result in immediate account bans, nullification of profits, and a ban from purchasing further accounts, with no refund.

6. ENHANCED DUE DILIGENCE (EDD)

6.1 Triggers for EDD:

Special cases identified on a case-by-case basis, including but not limited to:

Discrepancies in KYC information or payment details.

Suspicious trading patterns or payout requests.

Traders flagged by sanctions or high-risk jurisdiction screenings.

Internal risk assessments indicating potential AML concerns.

6.2 EDD Measures:

Request for additional documents, such as a secondary government-issued ID or updated proof of address.

Source of funds verification (e.g., bank statements, payment source details).

Direct communication (e.g., email or video call) to clarify Trader identity or activities.

6.3 Non-Compliance:

Failure to comply with EDD requests results in account suspension, withholding of payouts, or termination without refund.

7. SUSPICIOUS ACTIVITY REPORTING

7.1 Identification:

Castle Trading’s systems and compliance team monitor for Suspicious Activity, including:

Attempts to bypass KYC/AML checks or provide false information.

Payments from unverified or mismatched sources.

Trading patterns suggesting money laundering, fraud, or cheating.

The low risk due to small account sizes is acknowledged, but vigilance is maintained, especially at the payout stage.

7.2 Reporting:

Suspicious Activity is reviewed by executive staff acting as the Money Laundering Reporting Officer (MLRO).

If warranted, a Suspicious Activity Report (SAR) is filed with the UK National Crime Agency (NCA) in accordance with MLR 2017.

Traders may be contacted for clarification during investigations, with non-cooperation leading to account termination.

7.3 Consequences:

Accounts linked to confirmed Suspicious Activity are banned, with simulated profits nullified, no refunds issued, and a ban from purchasing further accounts.

Relevant authorities are notified as required by law.

8. RECORD-KEEPING

8.1 Castle Trading retains all KYC/AML records, including verification documents, transaction details, and monitoring logs, for a minimum of 5 years from the date of account closure or transaction, as required by MLR 2017.
8.2 Records are stored in an encrypted internal database, accessible only to authorized personnel, ensuring compliance with GDPR and the UK Data Protection Act 2018.
8.3 Records are securely disposed of after the retention period, unless required for ongoing investigations or legal obligations.

9. DATA PROTECTION

9.1 Compliance with GDPR:

Personal data collected for KYC/AML purposes (e.g., ID, address, payment details) is processed in accordance with Castle Trading’s Privacy Policy, GDPR, and the UK Data Protection Act 2018.

Data is collected only to the extent necessary for AML/KYC compliance, fraud prevention, and Service provision (data minimization principle).

Traders provide explicit consent for data processing during registration, with the right to withdraw consent subject to legal obligations.

9.2 Security Measures:

Data is encrypted during transmission and storage, with access restricted to trained personnel via secure authentication.

Third-party KYC providers (if used) are vetted for GDPR compliance, with data processing agreements in place.

Regular security audits and vulnerability assessments are conducted to protect data integrity.

9.3 Trader Rights:

Traders have the right to access, rectify, or request deletion of their personal data, subject to AML record-keeping obligations.

Requests can be made via support@castle.trading, with responses provided within 30 days, per GDPR requirements.

9.4 Data Transfers:

Data may be transferred outside the UK/EEA (e.g., to third-party KYC providers) with appropriate safeguards, such as Standard Contractual Clauses, to ensure GDPR compliance.

10. TRADER OBLIGATIONS

10.1 Traders shall:
   - Complete KYC verification promptly upon request before the first payout, providing accurate and valid documents.
   - Ensure payment methods (card or crypto) match the verified Trader name.
   - Refrain from using the Platform for illicit purposes, including money laundering, terrorist financing, fraud, or cheating.
   - Report any suspicious activity observed on the Platform to support@castle.trading.
10.2 Violations, including false KYC attempts, mismatched payment details, or cheating-like activities, result in immediate account termination, nullification of simulated profits, a ban from purchasing further accounts, and no refund.

11. TRAINING AND COMPLIANCE

11.1 Castle Trading provides annual AML/KYC training to all executive staff, who collectively handle MLRO duties, ensuring awareness of legal obligations, emerging risks, and Platform-specific concerns.
11.2 The executive team oversees Policy implementation, monitors compliance, and updates procedures to reflect regulatory changes or operational needs.
11.3 Regular reviews of third-party providers (e.g., Paytiko, Coinbase, Blockbee) ensure alignment with AML/KYC standards.

12. INDUSTRY-STANDARD PRACTICES

12.1 Risk-Based Approach:

Castle Trading adopts a risk-based approach, prioritizing AML/KYC efforts based on Trader profiles, payment methods, and trading activities, with low risk acknowledged due to small account sizes (up to $5,000 virtual capital).

Higher scrutiny is applied to payouts, crypto transactions, and special cases requiring EDD.

12.2 Third-Party Integration:

Third-party payment providers (Paytiko, Coinbase, Blockbee) and potential KYC vendors are required to comply with UK AML regulations and provide screening against Sanctions Lists.

Castle Trading verifies provider compliance through contractual agreements and periodic audits.

12.3 Continuous Monitoring:

Automated systems monitor IP addresses, payment details, and trading patterns in real-time to detect anomalies or restricted jurisdiction access.

Manual reviews by executive staff ensure thorough investigation of flagged activities.

12.4 Regulatory Alignment:

Despite being unregulated, Castle Trading aligns with MLR 2017 for payment processing and FATF recommendations for global best practices, including sanctions screening and suspicious activity reporting.

Policies are benchmarked against industry standards for proprietary trading firms, ensuring robust controls without overstepping unregulated status.

13. POLICY UPDATES

13.1 Castle Trading may update this Policy at its discretion to reflect legal, regulatory, or operational changes. Updates are effective upon posting on the Website or notification to Traders.
13.2 Continued use of the Services constitutes acceptance of the updated Policy.

14. CONTACT AND COMPLAINTS

14.1 For AML/KYC inquiries or to report suspicious activity, contact support@castle.trading.
14.2 Complaints about AML/KYC processes can be filed at support@castle.trading and will be resolved within 30 calendar days, as outlined in our Terms & Conditions.

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15. GOVERNING LAW

15.1 This Policy is governed by the law of Scotland. Any disputes are subject to the exclusive jurisdiction of Scottish courts.

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