Anti-money-laundering and counter-terrorist-financing policy
How TNFX Ltd meets its anti-money-laundering and counter-terrorist-financing obligations as a Securities Dealer licensed by the Financial Services Authority of Seychelles (licence SD133).
Who this applies to
TNFX Ltd (“TNFX”) is a Securities Dealer licensed by the Financial Services Authority of Seychelles under licence SD133, registered at CT House, Office 9A, Providence, Mahe, Seychelles. This policy applies to every client relationship and to every employee and introducing partner acting for TNFX.
TNFX does not accept residents of the United States or Canada. Applications declaring those countries of residence are refused at registration.
Customer due diligence
No client may fund a live trading account until they have been identified. Identification requires a government-issued photographic identity document, which is checked automatically for legibility, expiry and consistency with the details supplied, and a proof of address where one is required.
Where the documents supplied are unreadable, expired, or inconsistent with the application, the account is not verified and the file is returned for further documentation rather than approved on a best-guess basis.
Sanctions screening
Every applicant is screened against the consolidated sanctions lists published by the United States Office of Foreign Assets Control (the SDN list and its alternate-name list), the United Nations Security Council, and the European Union.
Screening takes place at onboarding, before a live trading account exists. A potential match does not result in refusal by an automated system and it does not result in automatic approval either: the application is placed on compliance hold for a person to assess.
Matching is deliberately tolerant of spelling and transliteration, because names rendered from Arabic, Persian, Kurdish and Russian script appear on sanctions lists in many forms. The system is tuned to refer too many cases rather than too few, and a reviewer clears the false positives. A missed name is a regulatory failure; an extra review is an administrative cost.
The sanctions lists are re-downloaded from the issuing authorities every day, so screening is performed against current data rather than a snapshot.
Where verification later supplies a date of birth or nationality that was not available at onboarding, the client is screened again against those additional identifiers.
Source and destination of funds
Withdrawals are returned by the method used to deposit. Where that is not possible, funds are released only to an account proven to belong to the client. A withdrawal may not be used to move value to a third party, and the destination of funds must be the same as their origin or an account demonstrated to be the client's own. This is set out in clauses 5 and 6 of the client agreement.
Where a withdrawal request is made on an account through which no trading has taken place, TNFX returns the funds to their source and may require further documentation before doing so, in order to satisfy its anti-money-laundering obligations.
Monitoring and account restriction
TNFX operates automated detection for trading and payment patterns associated with abuse. That detection raises a case for review. It cannot itself freeze, restrict or close an account: a restriction is always applied by a person who has reviewed the evidence, and every decision is appealable under clause 15 of the client agreement.
Record keeping and disclosure
TNFX retains identification documents, verification decisions and screening results for the period required by applicable law. As set out in clause 4 of the client agreement, TNFX may disclose information to organisations involved in fraud or money-laundering prevention, and may obtain information from and disclose information to other investment firms in connection with transactions you seek to open.
How personal data is handled more generally is set out in the privacy notice.
Scope of this page. This describes the controls TNFX operates in its client onboarding and payment systems. Matters held outside those systems — the appointed compliance officer, the firm’s written risk assessment, politically-exposed-person and adverse-media screening, suspicious-transaction reporting procedure, and staff training records — are maintained separately and are not reproduced here. For any of those, or to make a request under this policy, contact [email protected].
Related: Terms and Conditions · Withdrawal and refund policy · Privacy and data protection · How to make a complaint
Read alongside the TNFX Terms and Conditions, which is the controlling document.