ENZO FX (https://enzofx.com) is operated by Enzo FX Global Markets Limited Liability Company, a limited liability company registered in República de Costa Rica with company registration number 4062001308689, with a registered address at San Jose-San Jose Mata Redonda, Neighborhood Las Vegas, Blue Building Diagonal to La Salle Highschool, follows the laws of República de Costa Rica.

The objective of the AML Policy: We seek to offer the highest security to all of our users and customers on ENZO FX; for that, three-step account verification is done to ensure the identity of our customers. The reason behind this is to prove that the details of the person registered are correct and the deposit methods used are not stolen or being used by someone else, which is to create the general framework for the fight against money laundering. We also take into the accord that depending on the nationality and origin, the way of payment, and withdrawal, different safety measures must be taken.

ENZO FX also puts reasonable measures in place to control and limit ML risk, including dedicating the appropriate means.

ENZO FX is committed to high standards of anti-money laundering (AML) according to the AML framework of República de Costa Rica:

● Law No. 7786: Law Against Illicit Enrichment;
● Law No. 8204: Narcotics, Psychotropic Substances, Unauthorized Use Drugs, Related Activities, Money Laundering, and Financing of Terrorism;
● Law No. 8488: Strengthening of the AML and ATF System;
● Financial Institutions Law and Relevant Regulations.

Definition of money laundering

Money Laundering is understood as:
● The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity or from taking part in such activity, to conceal or disguise the illegal origin of the property, or helping any person who is involved in the commission of such an activity to evade the legal consequences of that people or companies action;
● The concealment or disguise of the true nature, source, location, disposition, movement, and rights concerning, or ownership of, property, knowing that such property is derived from criminal activity or an act of participation in such activity;
● The acquisition, possession, or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from assisting in such activity;
● Participation in, association to commit, attempts to commit and to aid, to abet, facilitate, and counseling the commission of any of the actions referred to in points before.

Money laundering shall be regarded as such even when the activities which generated the property to be laundered were carried out in the territory of a third country.

Organization of the AML for ENZO FX LLC

Following the AML legislation, ENZO FX LLC has appointed the “highest level” for the prevention of ML: The entire management of ENZO FX LLC is in charge.

Furthermore, an AMLCO (Anti Money Laundering Compliance Officer) and internal compliance team are in charge of the enforcement of the AML policy and procedures within ENZO FX digital platform (https://enzofx.com), a software system and company’s organizational structure that facilitates the monitoring and regulation of financial activities to prevent money laundering.

The AMLCO is placed under the direct responsibility of the general management.

AML policy changes and implementation requirements

Each significant change of ENZO FX LLC AML policy is subject to approval by the general management of ENZO FX LLC and the Anti-money laundering compliance officer.

Three step Verification

Step 1 verification:
Every user and customer must complete step one verification for registration on the ENZO FX website (https://enzofx.com), both deposit and withdrawal transactions. Regarding the choice of payment, the amount of payment, the amount of deposit, the option of deposit or withdrawal, and the nationality of the user/customer, step one verification must be completed as the initial step. Step one verification is an application form that the user/customer themselves need to fill out. The required information includes first name, second name, date of birth, country of usual residence, gender, and full address.

Step 2 verification:
Step two verification must be done by every user who deposits over 2000$ (two thousand Dollars) or withdraws over 2000$ (two thousand dollars). Until step two verification is done, the withdrawal or deposit will be on hold. Step to validation will lead the user or customer to a subpage where he must send in his ID. The user/customer must take a picture of his ID. Only an official ID may be used for ID verification; depending on the country, the variety of accepted IDs may be different. There will also be an electronic check if the filled-in Data from the step one verification is correct. The electronic check will check via available databases to ensure the given information matches with the filled form and the name from the ID. These databases could include various types of records, such as official government records, identification databases, or the other relevant databases that are publicly accessible and store information about individuals’ identities and documents. If the electronic test fails or is not possible, the user/customer is required to send in confirmation of his current residence. A certificate of registration by the government or a similar document is required.

Step 3 verification:
Step three verification must be done by every user who deposits over 5000$ (five thousand Dollars) or withdrawals over 5000$ (five thousand Dollars). Until step three verification is done, the withdrawal or deposit will be on hold. For step 3, a user/customer will be asked for a source of wealth.

Customer identification and verification (KYC)

The formal identification of customers on entry into commercial relations is a vital element, both for the regulations relating to money laundering and for the KYC policy of the Company.

This identification relies on the following fundamental principles:
● A copy of your passport, ID card or driving license. Also, a second picture with the face of the user/customer is required. The user/customer may blur out every information besides the date of birth, nationality, gender, first name, second name, and picture to secure their privacy.
● Please note that all four corners of the ID have to be visible in the same image, and all details have to be readable besides the names above. We might ask for all the details if necessary.
● A designated personnel of ENZO FX or a third-party designated service personnel may do additional checks if necessary, based on the situation.

Proof of Address
● Proof of address will be done via different electronic checks, which use accessible databases. If an electronic test fails, the user/customer has the option to make a manual proof.
● A recent utility bill was sent to your registered address, issued within the last three months, or an official document made by the government that proves your state of residence.
● To make the approval process as speedy as possible, please make sure the document is sent with a clear resolution where all four corners of the document are visible and all text is readable. For example, an electricity bill, water bill, bank statement, or any governmental post addressed to you.
● A designated personnel of ENZO FX or a third-party designated service personnel may do additional checks if necessary, based on the situation.

Source of funds
If a trader deposits over 5000$ (five thousand Dollars), there is a process of understanding the source of wealth (SOW)

Examples of SOW are:
● Ownership of business
● Employment
● Inheritance
● Investment
● Family

The origin and legitimacy of that wealth must be clearly understood. If this is not possible, a designated personnel of ENZO FX or a third-party designated service personnel may ask for an additional document or proof.

The account will be frozen if the same user deposits either this amount in one go or multiple transactions that amount to this. An email will be sent to them manually to go through the above and information on the website itself.

ENZO FX LLC also asks for a bank wire/credit card to further ensure the Identity of the user/customer. It also gives additional information about the financial situation of the user/customer.

The basic document for step one

The primary document will be accessible via the setting page on ENZO FX. Every user has to fill out the following information:
● First name
● Second name
● Nationality
● Gender
● Date of Birth
● Full address
The document will be saved and created by an AI; an employee may do additional checks if necessary based on the situation.

Risk management

To deal with the different risks and different states of wealth in other regions on the earth ENZO FX LLC will categorize every nation into three distinct regions of risk.

Region one: Low risk
For every nation from region one, the three-step verification is done as described earlier.

Region two: Medium risk
For every nation from region two, the three-step verification will be done at lower deposit, withdrawal, and tip amounts. Step one will be done as usual. Step two will be done after depositing 1000$ (one thousand Dollars) and withdrawing 1000$ (one thousand Dollars). Step three will be done after depositing 2500$ (two thousand five hundred Dollars) and withdrawing 2500$ (two thousand five hundred Dollars).

Region three: High risk
Regions of high risk will be banned. High-risk countries are identified based on international regulations, Costa Rican laws and our internal policies such as Terms & Conditions. High-risk regions will be regularly updated to keep up with the changing environment of a fast-changing world.

Additional measurements

In addition, an internal accountant team that the AML compliance officer oversees will look for any unusual behavior and report it right away to a designated personnel of ENZO FX LLC.

According to a risk-based few and broad experience, the human employees will recheck all checks that were done before by the software systems or other employees and may redo or do additional reviews according to the situation.

In addition, an accounting team supported by modern, electronic, analytic systems will look for unusual behavior like depositing and withdrawing without longer trading sessions, attempts to use a different bank account for Deposit and Withdraw, nationality changes, currency changes, behavior and activity changes, as well as checks, if an account is used by its original owner.

Also, a user has to use the same method for Withdrawal as he used for Deposit for the amount of the Initial Deposit to prevent any Money Laundering.

Enterprise-wide risk assessment

As part of its risk-based approach, ENZO FX LLC has conducted an AML “Enterprise-wide risk assessment” (EWRA) to identify and understand risks specific to ENZO FX LLC and its business lines. The AML risk policy is determined after identifying and documenting the risks inherent to its business lines, such as the services the website offers. The Users to whom services are offered, transactions performed by these Users, delivery channels used by the bank, the geographic locations of the bank’s operations, customers and commerce, and other qualitative and emerging risks.

The identification of AML risk categories is based on ENZO FX LLC’s understanding of regulatory requirements, regulatory expectations, and industry guidance. Additional safety measures are taken to take care of the other risks the World Wide Web brings with it. The EWRA is yearly reassessed.

Ongoing transaction monitoring

AML-Compliance team and accounting team of ENZO FX ensures that “ongoing transaction monitoring” is conducted to detect transactions that are unusual or suspicious compared to the customer profile.

This transaction monitoring is conducted on three levels:

1) The first Line of Control:
ENZO FX LLC works solely with trusted Payment Service Providers who all have effective AML policies in place to prevent the large majority of suspicious deposits onto ENZO FX LLC from taking place without proper execution of KYC procedures onto the potential customer.

2) The second Line of Control:
ENZO FX LLC makes its network aware so that any contact with the customer, trader or authorized representative must give rise to the exercise of due diligence on transactions on the account concerned. In particular, these include:
● Requests for the execution of financial transactions on the account;
● Requests concerning means of payment or services on the account.
Also, the three-step verification with adjusted risk management should provide all necessary information about all customers of ENZO FX LLC at all times.

Also, all transactions must be overseen by the accounting team of ENZO FX, overseen by the AML compliance officer, whom the general manager oversees.

The specific transactions submitted to the customer support manager, possibly through their Compliance Manager, must also be subject to due diligence.

Determination of the unusual nature of one or more transactions essentially depends on a subjective assessment concerning the knowledge of the customer (KYC), their financial behavior, and the transaction counterparty.

These checks will be done by the accounting team of ENZO FX with the help of modern software systems for additional security.

The transactions observed on customer accounts for which it is difficult to gain a proper understanding of the lawful activities and origin of funds must, therefore, rapidly be considered atypical (as they are not directly justifiable).

Any ENZO FX LLC staff member must inform the AML department of any atypical transactions that they observe and cannot attribute to a lawful activity or source of income known to the customer.

3) The third Line of Control:
As the last line of defense against AML ENZO FX LLC will do manual checks on all suspicious and higher-risk users to entirely prevent money laundering. If fraud or Money Laundering is found, the authorities will be informed.

Reporting of Suspicious transactions on ENZO FX LLC

In its internal procedures, ENZO FX LLC describes in precise terms the attention of its staff members, when it is necessary to report and how to proceed with such reporting.
Reports of atypical transactions are analyzed within the AML team following the precise methodology fully described in the internal procedures.

Depending on the result of this examination and based on the information gathered, the AML team:
● will decide whether it is necessary or not to send a report to the organ of corresponding supervision and control, which will immediately forward it to the Financial Intelligence Unit (FIU) of the Costa Rican Institute on Drugs;
● will decide whether or not it is necessary to terminate the business relations with the customer.

Procedures

The AML rules, including minimum KYC standards, will be translated into operational guidance or procedures that are available on the website of ENZO FX LLC.

Record keeping

Records of data obtained for identification must be kept for at least five years after the business relationship has ended.

Records of all transaction data must be kept for at least five years following the carrying-out of the transactions or the end of the business relationship.

These data will be safe and encrypted, stored offline and online.

Training

ENZO FX LLC human employees will make manual controls on a risk-based approval for which they get special training.
The training and awareness program is reflected by its usage:
● A mandatory AML training program following the latest regulatory evolutions for all in touch with finances
● Academic AML learning sessions for all new employees
The content of this training program has to be established by the kind of business the trainees are working for and the posts they hold. These sessions are given by an AML specialist working in the ENZO FX LLC AML team.

Auditing

Internal audit regularly establishes missions and reports about AML activities.

Data Security

All data given by any user/customer will be kept secure and will not be sold or provided to anyone else. Only if forced by law or to prevent money laundering data may be shared with the AML authority of the affected state.
Contact us

If you have any questions about our AML and KYC Policy, please get in touch with us by email: support@enzofx.com

If you have any complaints about our AML and KYC Policy or the checks done on your Account and your Person, please get in touch with us by email: support@enzofx.com