AML / CFT Policy

01Our commitment

BINGMEX Limited (the "Company", "BINGMEX", "we", "us") is committed to maintaining a strong compliance culture and to upholding the highest standards of integrity in the conduct of its business. We have adopted the policies and procedures set out in our internal Compliance & Anti-Money Laundering and Combatting Terrorist Financing Manual (the "Manual") in order to detect, prevent and combat money laundering ("ML"), terrorist financing ("TF") and the financing of proliferation ("PF") of weapons of mass destruction.

This public AML / CFT Policy summarises the key obligations BINGMEX undertakes towards its clients, counterparties and regulators. It is consistent with the Manual approved by our Board, but is not a substitute for it; the Manual remains the controlling internal document and binds every BINGMEX officer and employee.

02Legal & regulatory framework

Our AML / CFT programme is designed to comply with the laws of the Republic of Mauritius and with the international standards published by the Financial Action Task Force ("FATF"). The principal legal sources we operate under include:

FIAMLA

Financial Intelligence and Anti-Money Laundering Act 2002, as amended.

FIAML Regulations

Financial Intelligence and Anti-Money Laundering Regulations 2018.

FSA 2007

Financial Services Act 2007.

Securities Act

Securities Act 2005, under which BINGMEX is licensed (Section 29).

UNSA 2019

United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019.

POT Regulations

Prevention of Terrorism (Special Measures) Regulations 2003.

AML/CFT & PF Act

Anti-Money Laundering and Combatting the Financing of Terrorism and Proliferation (Miscellaneous Provisions) Act.

Data Protection

Data Protection Act 2017.

FATF

The Forty Recommendations of the Financial Action Task Force.

FSC Handbook

The FSC's AML / CFT Handbook (current version).

Failure to comply with the minimum requirements of the FIAMLA and the FIAML Regulations 2018 may be regarded by the FSC as conduct contrary to the best economic interests, or damaging to the reputation, of Mauritius and of fitness and propriety. We treat compliance as non-negotiable.

03Money laundering, terrorist financing & proliferation

Money laundering is the process by which criminals seek to conceal the true origin and ownership of the proceeds of criminal activity. It is conventionally described as occurring in three stages: placement (introducing illicit funds into the financial system), layering (moving funds through complex transactions or jurisdictions to disguise their source) and integration (re-introducing the funds into the legitimate economy).

Terrorist financing means the provision of financial support, in any form, to terrorism or to those who encourage, plan or engage in it. The source of the funds may itself be lawful — what makes the activity unlawful is the destination and intended use of the funds.

Proliferation financing means making available an asset, providing a financial service or conducting a financial transaction in circumstances where the person knows, or is reckless as to whether, the asset, service or transaction is intended to facilitate the proliferation of nuclear, chemical or biological weapons of mass destruction. This is addressed under FATF Recommendation 7 and the UNSA 2019.

BINGMEX takes its responsibility to prevent these offences seriously. The penalties under FIAMLA include fines of up to MUR 2 million and imprisonment of up to 10 years for individuals, with much higher penalties under UNSA 2019.

04Governance & appointed officers

Ultimate accountability for AML / CFT compliance rests with the Board of Directors of BINGMEX. The Board approves the AML / CFT programme and ensures that the policies, procedures, systems and controls are commensurate with the nature, size and complexity of our business.

In line with Regulations 22(1)(a) and 26(1) of the FIAML Regulations 2018, BINGMEX has appointed, and the FSC has approved, the following Controlled Functions under Section 24 of the Financial Services Act 2007:

MLRO

Money Laundering Reporting Officer — appointed at senior management level, FSC-approved

CO & DMLRO

Compliance Officer and Deputy Money Laundering Reporting Officer — appointed at senior management level, FSC-approved

The MLRO is the senior officer to whom internal disclosures of suspicion are made and who decides whether an external Suspicious Transaction Report ("STR") is filed with the Mauritius Financial Intelligence Unit ("FIU"). The Compliance Officer has day-to-day responsibility for ensuring continued compliance with the Manual and reports regularly to the Board. Both officers are independent of the front-office sales function. The identities of the appointed officers are recorded with the FSC and are available to clients on request to legal@bingmex.com.

05Risk-based approach

Our AML / CFT programme is built on a risk-based approach, in line with FATF Recommendation 1 and Section 17A of the FIAMLA. We maintain three layers of risk assessment:

• National Risk Assessment (NRA) — we read, understand and incorporate the conclusions of the National Money Laundering and Terrorism Financing Risk Assessment of Mauritius into our framework.
• Business Risk Assessment (BRA) — a Board-approved assessment of the inherent ML/TF risks faced by BINGMEX as a Full Service Investment Dealer, covering customer types, products, services, geographies, delivery channels and operational, reputational and legal risks.
• Client Risk Assessment (CRA) — performed prior to onboarding every client and reviewed periodically thereafter. Each client is rated Low, Medium or High risk based on customer profile, country of residence, products and services used, and screening results.

Review frequency is itself risk-based:

06Customer due diligence (CDD)

Pursuant to Section 17C of the FIAMLA and Regulation 3 of the FIAML Regulations 2018, BINGMEX must identify each customer and, where applicable, the underlying beneficial owner, and verify their identity using independent and reliable sources.

When CDD applies

BINGMEX performs CDD on a client:

• before establishing a business relationship;
• before carrying out an electronic transfer or occasional transaction;
• when there is suspicion of ML, TF or a serious offence, regardless of the level of transaction;
• when there is doubt about the veracity or adequacy of identification information previously obtained;
• periodically as part of our ongoing CDD routine.

Documents we collect from individual clients

For natural persons, BINGMEX collects, at minimum:

• Full name, date of birth, nationality, country of residence;
• Residential address (no PO boxes);
• Occupation or business activity;
• Nature and purpose of the proposed relationship and intended transactions;
• Source of funds and, where appropriate, source of wealth;
• Government-issued identification number.

The supporting documents we accept include:

Legal persons and arrangements

Where the client is a company, partnership, foundation, société, trust or other legal arrangement, BINGMEX collects identification data on the entity itself (legal status, registered office, principal place of business, official identification number, ownership and control structure) and applies the natural-person CDD requirements above to its directors, beneficial owners (typically those holding more than 20%), authorised signatories and underlying principals. We require corroborating documents such as the Certificate of Incorporation, Memorandum and Articles of Association, company registry search, latest audited financial statements and certificate of good standing.

Source of funds & source of wealth

Source of funds is the origin of the particular funds used to fund the relationship — for example, the bank account from which a deposit is wired. Source of wealth is the origin of the client's overall financial standing — the activities that have generated the client's net worth. We are required to establish source of wealth for every higher-risk client (including foreign Politically Exposed Persons), and for any other relationship where the product or service makes it appropriate.

Document certification & non-face-to-face onboarding

Where identification documents are not provided in original form, copies must be certified as true copies by an appropriate certifier — for example, an attorney, notary, accountant, director or company secretary of a regulated financial institution, member of the judiciary or senior civil servant. The certifier must sign and date the copy and identify themselves clearly.

BINGMEX recognises that its business is conducted predominantly on a non-face-to-face basis. We apply enhanced controls to non-face-to-face onboarding — including electronic verification, document tamper checks, and additional identity attestations where appropriate — in line with the FSC's expectations.

07Enhanced due diligence & PEPs

Regulation 12 of the FIAML Regulations 2018 requires reporting persons to apply Enhanced Due Diligence ("EDD") where ML / TF risks are identified to be higher. EDD applies, but is not limited to:

• Clients located in countries identified by the FATF as having strategic AML / CFT deficiencies, or by the FSC as non-equivalent;
• Clients located in or conducting business through jurisdictions with sanctions or embargoes in force, or with elevated levels of corruption, organised crime or weapon / drug production;
• Politically Exposed Persons (PEPs) — domestic, foreign or international-organisation — and their family members and close associates;
• Clients with unusually large or complex one-off transactions, or transaction volumes inconsistent with the expected profile;
• Clients with complex or opaque ownership structures;
• Clients in cash-intensive businesses, virtual-asset activity or untraceable / anonymous payment channels.

EDD measures applied by BINGMEX may include:

• Requesting additional information on the customer and updating it more frequently;
• Obtaining additional information on the intended nature of the relationship and on source of funds and source of wealth;
• Obtaining senior management or Board approval to commence or continue the relationship;
• Conducting close, more frequent monitoring of the relationship and of individual transactions, with lower monitoring thresholds.

Politically Exposed Persons (PEPs)

FIAML Regulations categorise PEPs as domestic, foreign and international-organisation. Family members and close associates of PEPs are treated as PEPs for due-diligence purposes. Where a positive PEP match is identified, the relationship is automatically classified as high-risk; senior management or Board approval is required to onboard the client; reasonable measures are taken to establish source of wealth and source of funds; and the relationship is subject to enhanced ongoing monitoring.

Where a person ceases to be entrusted with a prominent public function, BINGMEX continues to apply risk-sensitive measures for at least 12 months thereafter and only declassifies the PEP relationship after careful consideration and Board approval.

08Simplified due diligence (SDD)

Where ML / TF risks have been determined to be low, BINGMEX may, with Board approval, apply Simplified Due Diligence. SDD does not eliminate the obligation to identify and verify the customer; it permits a reduction in the depth or frequency of certain measures. Categories where SDD may apply include corporations listed on a recognised stock exchange, governmental bodies and entities in equivalent jurisdictions performing public functions. SDD is never applied where there is suspicion of ML or TF, or any other indicator of elevated risk.

09Ongoing & transaction monitoring

Pursuant to Regulation 3(1)(e) of the FIAML Regulations 2018, BINGMEX conducts ongoing monitoring of every business relationship throughout its lifecycle. This involves two strands:

1. Transaction monitoring — applying scrutiny to transactions undertaken throughout the course of the relationship, including, where necessary, the source of funds, to ensure that activity remains consistent with our knowledge of the customer, the customer's business and the customer's risk profile.
2. Customer file refresh — ensuring the documents, data and information collected under the CDD process are kept up to date and relevant by reviewing existing records, particularly for higher-risk categories of customer.

Our monitoring combines real-time and post-event reviews. Real-time monitoring is used to reduce exposure to ML, TF and predicate offences as instructions are received. Post-event monitoring (typically monthly) examines patterns of activity over the preceding period.

For high-risk relationships, complete reviews include re-confirmation of address, re-confirmation of source of funds and source of wealth, screening against Refinitiv World-Check, NameScan, sanctions lists and adverse-media searches, and a complete review of the transaction profile.

Examples of red flags

The following non-exhaustive indicators may prompt enhanced scrutiny or an internal disclosure:

• Unusually large deposits or withdrawals, or transactions inconsistent with our understanding of the customer;
• Funds originating from or destined for high-risk locations or unrelated third parties;
• Transactions occurring after a period of dormancy;
• Patterns of activity with no apparent economic or lawful purpose;
• Customers unwilling to provide CDD documentation, source of funds or beneficial-ownership detail;
• Multiple accounts under the same client without commercial justification;
• Extreme urgency, where the client is not concerned by transfer fees or repayment costs.

10Sanctions screening

BINGMEX screens prospective and existing clients, beneficial owners and counterparties against, at minimum:

• The United Nations Security Council Consolidated List;
• The list maintained by the National Sanctions Secretariat ("NSSEC") of Mauritius under UNSA 2019;
• Designations made by the FSC and other relevant supervisory authorities;
• Commercial sanctions and PEP databases such as Refinitiv World-Check and NameScan.

Screening is performed at onboarding, when a relationship's CDD is refreshed, before each cross-border wire transfer, and whenever the underlying lists are updated. Where a positive match is identified, BINGMEX will:

1. Freeze the relevant funds or assets without delay;
2. Make an internal disclosure to the MLRO;
3. Report to the NSSEC and to the FSC, in line with Section 23 of UNSA 2019;
4. File a Suspicious Transaction Report with the Financial Intelligence Unit.

11Suspicious transaction reporting (STR)

A "suspicious transaction" is one that gives rise to a reasonable suspicion that it may involve the laundering of money or the proceeds of any crime; or funds linked to terrorism, proliferation or proscribed organisations; or that has no apparent economic or lawful purpose; or that is unusually complex; or that gives rise to suspicion for any other reason (Section 2 of the FIAMLA).

Every BINGMEX officer and employee has a personal statutory duty to report any suspicion to the MLRO using the Internal Disclosure Form within 24 hours of the suspicion arising. The MLRO assesses the disclosure and, where a reasonable suspicion is confirmed, files an external Suspicious Transaction Report with the Financial Intelligence Unit via the goAML platform (mrugoaml.fiumauritius.org) within five working days of becoming aware of the transaction. The MLRO maintains separate registers of internal and external disclosures.

Failure to file a required STR is an offence under Section 19 of the FIAML Act and may render an individual liable to a fine of up to MUR 5 million and imprisonment of up to 10 years. We treat the obligation to report as personal and absolute.

12Tipping-off prohibition

Section 16(1) of the FIAMLA prohibits any person involved in the reporting of a suspicious transaction from informing the customer or any unauthorised third party that the transaction has been reported, or that information has been supplied to the FIU. Once an internal STR has been made, it is an offence for any BINGMEX employee to warn or inform the owner of the funds. We train every employee on the boundary between legitimate enquiries (which are part of CDD) and tipping-off.

13Record keeping

BINGMEX maintains the records required by the FSC AML / CFT Handbook, including:

• Customer due diligence information — identification data, account files, business correspondence and the results of any analysis or assessment undertaken;
• Transaction records — the name and address of the customer, currency and amount, source and destination of funds, supporting agreements, nature and date of each transaction;
• Internal disclosures and copies of external Suspicious Transaction Reports filed with the FIU, including any accompanying documentation and the basis for any decision not to file an external report;
• Training records — dates, content, mode of delivery and the names of officers and employees who attended.

All such records are retained for at least seven (7) years from the end of the business relationship, the completion of the transaction or the date the report was made, whichever is the latest. Records are stored securely, with electronic copies retrievable on demand by the FSC, FIU or other competent authority.

Tampering with records is an offence under Section 19 of the FIAMLA and is punishable by fines of up to MUR 10 million and imprisonment of up to 5 years. BINGMEX has zero tolerance for the falsification, concealment or destruction of compliance records.

14Training & independent audit

Every BINGMEX officer and employee is required to complete AML / CFT training before commencing client-facing work, and to undergo refresher training at least annually. Training is tailored to role — new joiners, front-office sales, back-office accounting, managerial and approved-officer staff each receive a curriculum proportionate to their responsibilities. Training content covers BINGMEX-specific risks, the legal framework, identification of red flags, escalation procedures and the consequences (civil, criminal and disciplinary) of non-compliance. A training register is maintained.

In line with Regulation 22(1)(d) of the FIAML Regulations 2018, BINGMEX maintains an independent audit function to test the effectiveness of its AML / CFT programme. The audit is conducted by a person independent of the development and operation of the programme and may be performed by an in-house auditor or an external service provider with the requisite competence. The Board reviews the audit findings and is responsible for ensuring that any deficiencies are remediated within agreed timelines.

15Restricted jurisdictions

BINGMEX does not onboard clients from jurisdictions where the offering of our services would not be permissible under local law or where the FATF or FSC has identified strategic AML / CFT deficiencies. Restricted jurisdictions include, without limitation:

• Countries and territories subject to comprehensive financial sanctions imposed by the United Nations Security Council;
• Countries identified on the FATF "high-risk and other monitored jurisdictions" lists, where appropriate to the level of risk;
• The Democratic People's Republic of Korea, Iran and any other jurisdiction designated under UNSA 2019;
• Countries where the proposed activity would breach Mauritian law or the conditions of our FSC licence.

The restricted-jurisdictions list is reviewed regularly and may change without notice. Prospective clients should contact our onboarding desk if they are unsure whether they can be accepted.

16Contact our compliance team

If you have a query about a specific transaction, an onboarding decision, our AML / CFT framework or wish to raise a compliance concern (including whistle-blower disclosures), please contact us through the channels below. All correspondence is routed to our Compliance Officer and, where relevant, escalated to our MLRO.

Legal & Compliance

legal@bingmex.com — AML, KYC, sanctions, whistle-blower disclosures

Client Services

support@bingmex.com — onboarding, account and trading queries

Business & Partnerships

business@bingmex.com — institutional, IB and white-label

Registered Office

BINGMEX Limited
3rd Floor, Standard Chartered Tower, Bank Street, Cybercity, Ebene, Republic of Mauritius

Suspicious-transaction reports made to the Mauritius Financial Intelligence Unit are handled in strict confidence in accordance with Section 16 of the FIAMLA, which protects persons who report in good faith from civil and criminal liability.

17Updates to this policy

BINGMEX reviews this AML / CFT Policy at periodic intervals of no longer than 12 months, and additionally whenever there is a material change to the legal or regulatory framework, to BINGMEX's business activities or to the underlying internal Manual approved by our Board. The version published on this website will always be the current public summary.

Specific reservations, exceptions or higher-risk policies may apply to individual clients, products or transactions in addition to the matters described above. The Manual remains the controlling internal document; in case of any inconsistency between this public Policy and the Manual, the Manual prevails internally.