Anti-Money Laundering Policy

Artevotrade LLC ("the Firm," "we," "us," or "our") is committed to the highest standards of legal and ethical conduct. We maintain a zero-tolerance policy toward money laundering, terrorist financing, and any form of financial crime. This Anti-Money Laundering (AML) Policy sets out our commitment, procedures, and obligations for preventing and detecting financial crime in all our operations.

1. Policy Statement

Artevotrade LLC is committed to full compliance with all applicable anti-money laundering and counter-terrorist financing (AML/CTF) laws, regulations, and guidance in the jurisdictions in which we operate. These include, but are not limited to:

• The United States Bank Secrecy Act (BSA) and associated FinCEN regulations;
• The USA PATRIOT Act;
• The EU Anti-Money Laundering Directives (AMLD series);
• Applicable AML legislation in the jurisdictions where clients are located.

The Firm will not knowingly facilitate, enable, or benefit from any transaction involving the proceeds of criminal activity, and will take all reasonable steps to ensure that our services are not used for money laundering or terrorist financing purposes.

2. Client Due Diligence (CDD)

Prior to entering into any significant service engagement, Artevotrade LLC applies Client Due Diligence (CDD) procedures proportionate to the risk level of the engagement. These may include:

• Identity verification: Confirming the legal identity of the client organization through official registration documents, company certificates, or equivalent;
• Beneficial ownership identification: Identifying the ultimate beneficial owners where the client is a corporate entity;
• Purpose of engagement: Understanding the nature and purpose of the business relationship and the intended use of our services;
• Source of funds: For high-value or high-risk engagements, obtaining confirmation of the legitimate source of funds;
• PEP screening: Checking clients and their principals against Politically Exposed Persons (PEP) and sanctions lists.

Enhanced Due Diligence (EDD) is applied for clients assessed as higher risk, including those based in high-risk jurisdictions as identified by the Financial Action Task Force (FATF) or applicable regulatory authorities.

3. Risk Assessment

The Firm conducts a risk-based assessment of each client relationship prior to onboarding and on an ongoing basis. Risk factors considered include:

• Geographic risk: client's country of domicile and countries of operation;
• Sector risk: industry and nature of the client's business;
• Transaction risk: size, complexity, and structure of the proposed engagement;
• Client profile risk: whether the client or its principals appear on sanctions or PEP lists.

4. Suspicious Activity Reporting

All staff and collaborators of Artevotrade LLC are obligated to report any suspicion of money laundering or terrorist financing activity to the firm's designated compliance function without delay. Suspicious activity indicators may include:

• Requests for payment in cash or through unusual channels;
• Overpayment of invoices with requests for refund to a different account;
• Clients reluctant to provide identification or beneficial ownership information;
• Transactions that appear inconsistent with the client's known business profile;
• Unusual urgency or pressure around payment or contract execution;
• Client or related parties appearing on sanctions, PEP, or adverse media lists.

Where a suspicion is reported internally, the Firm will consider whether a Suspicious Activity Report (SAR) or equivalent report must be filed with the relevant financial intelligence unit (FIU) or law enforcement authority. The Firm will not tip off any client or third party about an AML report or investigation.

5. Sanctions Compliance

Artevotrade LLC will not engage in any transaction, service delivery, or business relationship with individuals, entities, or countries subject to applicable international sanctions, including those imposed by the United States Office of Foreign Assets Control (OFAC), the United Nations Security Council, the European Union, or the United Kingdom's Office of Financial Sanctions Implementation (OFSI).

6. Record Keeping

Artevotrade LLC maintains records of all CDD and EDD documentation, transaction records, and internal AML reports for a minimum of five (5) years from the end of the relevant business relationship or transaction, or as otherwise required by applicable law. Records are stored securely and are available to relevant authorities upon lawful request.

7. AML Training

All staff, contractors, and collaborators of Artevotrade LLC who are involved in client-facing activities or financial operations receive appropriate AML/CTF training. This training covers:

• Recognition of money laundering and terrorist financing indicators;
• Internal reporting procedures;
• Legal obligations and consequences of non-compliance;
• The firm's CDD and EDD procedures.

Training is reviewed and updated at least annually to reflect changes in applicable regulations and risk environments.

8. Policy Review

This AML Policy is reviewed at least annually by the firm's compliance function and updated to reflect changes in applicable law, regulatory guidance, and operational risk. Material changes to this policy will be communicated to all relevant personnel.

9. Contact

For AML compliance inquiries, please contact us via our contact form or at our registered address, marked: Attention: Compliance.