Know Your Customer (KYC) Policy

ArigoFX Ltd.
Effective Date: 3^rd June 2025

1. Introduction

ArigoFX Ltd. (“ArigoFX” or “the Company”) is committed to complying with all laws related to Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and financial crime prevention. This KYC Policy outlines how ArigoFX verifies customer identity and monitors activities in compliance with Saint Lucia laws and international standards like those from the Financial Action Task Force (FATF).

2. Purpose

• Prevent use of ArigoFX’s services for money laundering or terrorist financing.
• Establish a risk-based customer verification process.
• Monitor customer relationships and transactions continuously.
• Ensure regulatory compliance and cooperation with authorities.

3. Scope

This Policy applies to all clients of ArigoFX Ltd., including individuals, companies, partnerships, trusts, and other legal entities. It also applies to all employees and agents of the Company.

4. Customer Due Diligence (CDD)

4.1 Standard CDD

Before any business relationship or transaction, ArigoFX shall:

• Identify and verify the customer’s identity using independent sources.
• For individuals: collect full name, DOB, nationality, address, and valid government ID.
• For companies: collect registration documents, address, directors, signatories, and UBOs.

4.2 Enhanced Due Diligence (EDD)

EDD applies in high-risk cases such as:

• Politically Exposed Persons (PEPs) and their close contacts.
• Customers from FATF-listed or high-risk jurisdictions.
• Unusual transactions without clear purpose.

EDD may include:

• Verifying source of funds and wealth.
• Approval from senior management.
• Ongoing enhanced monitoring.

4.3 Simplified Due Diligence (SDD)

In low-risk situations, and where allowed by law, ArigoFX may apply simplified measures with approval from the Compliance Department.

5. Ongoing Monitoring and Reviews

We will monitor all customer relationships to ensure activity aligns with expected behavior. This includes:

• Regular reviews of customer information.
• Real-time transaction monitoring tools.
• Reporting suspicious activity to the MLRO.

6. Risk-Based Approach

Customers are classified as low, medium, or high risk based on:

• Type of customer and occupation.
• Geographic location.
• Services used.
• Delivery channels.

7. Record-Keeping

We retain KYC records, including identification and transaction data, for a minimum of five (5) years after the relationship ends or longer if legally required.

8. Data Protection and Confidentiality

All KYC data is protected under the Data Protection Act of Saint Lucia. It will only be shared with law enforcement or regulators if legally required.

9. Training and Awareness

Employees, especially those in compliance and client service roles, receive regular training to recognize red flags and follow proper KYC procedures.

10. Governance and Oversight

The Compliance Department, led by the MLRO, oversees this policy’s implementation. Management ensures sufficient resources, and internal audits review effectiveness regularly.

11. Policy Review

This Policy is reviewed at least once per year or more often as needed. All changes must be approved by the Board or designated committee.