Anti-Money Laundering (“AML”), Combating the Financing of Terrorism (“CFT”), and Sanctions Policy Statement

Node Digital Management Ltd (“Nodeam”) is committed to abide by and implement a comprehensive set of policies in accordance with sanctions-based, internationally recognised guidelines and local regulatory requirements wherever Nodeam and/or its other controlled entities will operate. This will be collectively known herein as Nodeam’s AML Programme.

Nodeam will account for all applicable guidelines, laws, regulations, and sanctions set forth by the Financial Action Task Force (“FATF”), the United Nations Security Council Resolution (“UNSCR”), the European Union (“EU”), the United States Office of Foreign Assets Control (“OFAC”), and the Republic of Seychelles.

Nodeam’s AML programme has been designed to identify and mitigate risks to Nodeam’s business activities. All staff from Nodeam will be expected to conduct themselves accordingly, if not to a higher standard.

AML/CFT Policy

The following sets out the base standards to be complied with.

The Board of Directors (“Board”) oversees and maintains the governance framework of Nodeam’s AML programme.

The Know Your Customer/Know Your Business (“KYC/KYB”) process and requirements are designed to identify and verify all customers and, where applicable, beneficial owners’ source of funds to the extent warranted by the risk of Money Laundering (“ML”) or Terrorist Financing (“TF”) as required by regulation.

Conduct risk assessments at the customer, product, and service levels.

Conduct enhanced due diligence for those customers presenting higher risk, utilising, but not limited to, face-to-face meetings, additional assurances, and shorter intervals for on-going monitoring and reporting.

To not onboard customers who are deemed Politically exposed (“PEP’).

Possess a combination of risk-based measures and systems for monitoring customer transactions and contacting customers for additional information as and when necessary to ensure compliance with applicable laws, regulations, and policies.

Install procedures to report unusual activities internally and to report suspicious activities to appropriate regulatory authorities in accordance with applicable laws.

Conduct mandatory AML/CFT and Sanctions training for all employees on a periodic basis.

The maintenance of appropriate records for the minimum prescribed periods.

Nodeam, in its sole discretion, may decide not to commence or continue with any customer/ business partner relationships, process transactions, provide products or services, or facilitate transactions even when expressly permitted by applicable AML/CFT and Sanctions regulations.

Prohibited Industries  

Nodeam will not serve prospects, customers, or partners engaged in the following (non-exhaustive) activities:

Fraud, gambling (online or otherwise), drugs (including legalised marijuana/cannabis), arms & munitions, adult content/pornography, religious cults, blacklisted trading platforms (all asset classes).

Sanctions Compliance

Nodeam is prohibited from transacting with individuals, companies, or countries that are on prescribed Sanctions lists. We will screen against the FATF, UNSCR EU, OFAC, and other sanctions watchlists in the jurisdiction(s) in which we operate. The list of sanctioned territories is listed in the Appendix following.

This policy statement supersedes any statement on the same matters previously made by Nodeam and should be viewed along with the Restricted Territories List and regarded as a whole.

This policy statement supersedes any statement on the same matters previously made by Nodeam and should be view along with the restricted territories list and be regarded as a whole.

Restricted Territories List

1. Nodeam will not offer its services and products to the following sanctioned territories:

I. Abkhazia
II. Afghanistan
III. Albania
IV. Angola
V. Belarus
VI. Burundi
VII. Central African Republic
VIII. Congo (DRC)
IX. Cuba
X. Crimea, Donetsk & Luhansk
XI. Ethiopia
XII. Guinea Bissau
XIII. Haiti
XIV. Iran
XV. Iraq
XVI. Ivory Coast (Cote D’Ivoire)
XVII. Lebanon
XVIII. Liberia
XIX. Libya
XX. Mali
XXI. Myanmar
XXII. Nagorno-Karabakh
XXIII. Nicaragua
XXIV. North Korea (DPKR)
XXV. Northern Cyprus
XXVI. Russia
XXVII. Sahrawi Arab Democratic Republic
XXVIII. Somalia
XXIX. Somaliland
XXX. South Ossetia
XXXI. South Sudan
XXXII. Syria
XXXIII. Syrian Arab Republic
XXXIV. Sudan
XXXV. Ukraine
XXXVI. Yemen
XXXVII. Venezuela
XXXVIII. Zimbabwe

2. Non-sanctioned territories that Nodeam is not offering services/products to:

I. USA & Outlying Territories
II. China (PRC) *
III. Hong Kong SAR *
IV. Japan *
V. Singapore *

*Denotes individuals of these territories may be on-boarded but subject to investor classification, and, or enhanced vetting procedures

3. Any sanctioned entities, individuals or activities defined in the body of Nodeam’s Anti-Money Laundering (AML) and Countering Financing of Terrorism (CFT) Policy Statement.

4. Territories that may trigger enhanced vetting procedures:

I. Armenia
II. Azerbaijan
III. Barbados
IV. Bosnia-Herzegovina
V. Burkina Faso
VI. Burundi
VII. Cambodia
VIII. Cayman Islands
IX. Croatia
X. Djibouti
XI. Eritrea
XII. Gaza Strip
XIII. Gibraltar
XIV. Guinea
XV. Jamaica
XVI. Jordan
XVII. Kosovo
XVIII. Montenegro
XIX. Morocco
XX. Mozambique
XXI. Nigeria
XXII. North Macedonia
XXIII. Pakistan
XXIV. Panama
XXV. Philippines
XXVI. Senegal
XXVII. Serbia
XXVIII. Slovenia
XXIX. Tanzania
XXX. Turkey
XXXI. Trinidad & Tobago
XXXII. Tunisia
XXXIII. Uganda
XXXIV. United Arab Emirates
XXXV. Vanuatu
XXXVI. Western Sahara

NB: The lists provided herein may be changed without prior notification.