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Anti‑Money Laundering (AML) Policy

Introduction

The DemoPips program and all related services are operated by Wintrado Acad Ltd, a company incorporated and registered under the laws of Cyprus with company registration number HE 451363 and registered office at 62 Athalassas Ave, Strovolos, Nicosia, Cyprus, 2012. “DemoPips” is a brand name of Wintrado Acad Ltd. All references to “the Company,” “we,” “us,” or “our” in this Policy refer to Wintrado Acad Ltd operating under the DemoPips brand.

This Anti‑Money Laundering (AML) Policy is established to ensure that DemoPips complies with all applicable laws and regulations related to anti‑money laundering (AML), counter‑terrorism financing (CTF), and sanctions. This policy outlines the company’s commitment to preventing illicit fund‑related activities and sets guidelines for employees, contractors, and other relevant parties to follow.

Policy Objective

The primary objective of this AML Policy is to detect, prevent, and report any suspicious activities related to money laundering, terrorism financing, or any other illicit fund‑related activities. DemoPips is dedicated to maintaining the integrity of its operations and ensuring its services are not misused for unlawful purposes.

AML Compliance Officer

DemoPips shall designate an AML Compliance Officer responsible for overseeing the implementation and effectiveness of this AML Policy. The AML Compliance Officer will have the authority to take necessary actions and report directly to senior management and the Board of Directors.

Customer Due Diligence (CDD)

1. Know Your Customer (KYC): The firm shall conduct thorough customer due diligence during onboarding and periodically review existing clients. This includes obtaining and verifying customer identification information, understanding the customer’s source of funds, and assessing the risk associated with each client.
2. Enhanced Due Diligence (EDD): For high‑risk clients, politically exposed persons (PEPs), and clients from high‑risk jurisdictions, additional enhanced due diligence measures shall be applied.

Reporting Suspicious Activities

1. Internal Reporting: All employees and relevant parties are required to promptly report any suspicious activities or transactions to the AML Compliance Officer. This includes unusual patterns, large or frequent cash movements, or any behavior that raises AML concerns.
2. Whistleblower Protection: DemoPips shall ensure that individuals reporting suspicious activities are protected from any retaliation or adverse actions.

Record Keeping

The firm shall maintain accurate and up‑to‑date records of customer identification, transaction details, and all related documents in compliance with Cyprus and EU AML regulations. These records shall be kept for a minimum period as required by law.

Training

All employees and relevant parties involved in our operations shall receive regular AML training. This training will educate them about the importance of AML compliance, how to identify suspicious activities, and the company’s procedures for reporting such activities.

Sanctions Compliance

DemoPips shall adhere to international, EU and UN sanctions programs. This includes monitoring and screening transactions and clients against relevant sanctions lists to ensure compliance.

Risk Assessment and Review

The AML Compliance Officer shall conduct periodic risk assessments and reviews of the AML Policy’s effectiveness. Any necessary updates or improvements shall be made based on the findings of these assessments.

Non‑Compliance

Non‑compliance with this AML Policy or any AML‑related laws and regulations may lead to disciplinary actions, including termination of employment or business relationships, as well as potential legal consequences.

Document Requirements for Account Opening

DemoPips must verify the identity of individuals before allocating company resources. Accepted forms of identity verification include:

  • Photo ID: Passport or government‑issued ID (driver’s license).
  • Proof of Address: Lease agreement, mortgage statement, utility bill, bank statement, government‑issued tax document, etc. (must be current and not older than three months).

If required, documents must be translated into English.

Notice

DemoPips does not receive cash payments, distribute cash, or accept third‑party funds. Any suspicion of unlawful activity may result in transaction refusal and reporting to the relevant authorities without notifying the account holder.

General AML & KYC Policy Rules

  • Clients must comply with AML and KYC requirements, including providing additional documents if requested.
  • Resource withdrawals are only permitted to accounts owned by the client.
  • DemoPips reserves the right to conduct investigations, block accounts, or refuse transactions deemed suspicious.
  • The company does not provide services to clients from FATF‑listed jurisdictions or U.S. residents.
  • DemoPips is not obligated to inform clients about AML‑related actions taken.

Policy Review and Updates

This AML Policy shall be reviewed and updated regularly to reflect changes in regulations and best practices and to ensure ongoing compliance with Cyprus and EU laws and regulations.

By adhering to this Anti‑Money Laundering Policy, DemoPips aims to contribute to a safe and transparent environment. All employees and relevant parties are expected to understand and comply with this policy to prevent and detect any potential money laundering or illicit activities within the company’s operations.