Anti-Money Laundering
Anti-Money Laundering
Anti-Money Laundering
Anti-Money Laundering
Anti-Money Laundering
Introduction
Introduction
GatesFX LTD (“GatesFX,” “we,” “our,” or “us”) is firmly committed to the prevention of money laundering and the financing of terrorism.
This Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy establishes the framework through which GatesFX identifies, monitors, and mitigates risks related to financial crime.
Our policy is based on international standards set by the Financial Action Task Force (FATF) and the laws and regulations of St. Lucia, ensuring that GatesFX operates with the highest level of transparency and integrity.
GatesFX LTD (“GatesFX,” “we,” “our,” or “us”) is firmly committed to the prevention of money laundering and the financing of terrorism.
This Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy establishes the framework through which GatesFX identifies, monitors, and mitigates risks related to financial crime.
Our policy is based on international standards set by the Financial Action Task Force (FATF) and the laws and regulations of St. Lucia, ensuring that GatesFX operates with the highest level of transparency and integrity.
2. Purpose
2. Purpose
The purpose of this policy is to:
Prevent the use of GatesFX’s services for money laundering or terrorist financing.
Establish procedures for identifying and verifying clients.
Ensure effective monitoring of trading and payment activity.
Comply with local and international reporting obligations.
Safeguard the company’s reputation and protect clients’ interests.
The purpose of this policy is to:
Prevent the use of GatesFX’s services for money laundering or terrorist financing.
Establish procedures for identifying and verifying clients.
Ensure effective monitoring of trading and payment activity.
Comply with local and international reporting obligations.
Safeguard the company’s reputation and protect clients’ interests.
3. Scope
3. Scope
This policy applies to:
All clients, counterparties, and beneficial owners of accounts held with GatesFX.
All employees, contractors, and partners of GatesFX LTD.
All products, services, and transaction channels, including online deposits, withdrawals, and trading activities.
This policy applies to:
All clients, counterparties, and beneficial owners of accounts held with GatesFX.
All employees, contractors, and partners of GatesFX LTD.
All products, services, and transaction channels, including online deposits, withdrawals, and trading activities.
4. Key Definitions
4. Key Definitions
Money Laundering: The process of concealing the origins of illegally obtained funds by transferring them through legitimate businesses or financial systems.
Terrorist Financing: Providing or collecting funds intended to support terrorist acts or organizations.
Beneficial Owner: The natural person who ultimately owns or controls an account or transaction.
Suspicious Activity: Any transaction inconsistent with a client’s known profile or legitimate business purpose.
Money Laundering: The process of concealing the origins of illegally obtained funds by transferring them through legitimate businesses or financial systems.
Terrorist Financing: Providing or collecting funds intended to support terrorist acts or organizations.
Beneficial Owner: The natural person who ultimately owns or controls an account or transaction.
Suspicious Activity: Any transaction inconsistent with a client’s known profile or legitimate business purpose.
5. Customer Due Diligence (CDD)
5. Customer Due Diligence (CDD)
5.1 Standard Verification
Before establishing a trading relationship, GatesFX verifies each client’s:
Full legal name
Date of birth
Residential address
National identification number or passport details
Source of funds and wealth (where applicable)
Verification must be completed before deposits, withdrawals, or trading can occur.
5.2 Enhanced Due Diligence (EDD)
EDD is applied to:
High-risk clients or jurisdictions;
Politically Exposed Persons (PEPs);
Clients transacting large volumes or using complex structures.
EDD may include requesting additional documents, verifying source of wealth, or conducting senior-management approval.
5.3 Simplified Due Diligence
Applied only where the risk of money laundering is demonstrably low and permitted by law—never for trading accounts involving leverage or high-risk assets.
5.1 Standard Verification
Before establishing a trading relationship, GatesFX verifies each client’s:
Full legal name
Date of birth
Residential address
National identification number or passport details
Source of funds and wealth (where applicable)
Verification must be completed before deposits, withdrawals, or trading can occur.
5.2 Enhanced Due Diligence (EDD)
EDD is applied to:
High-risk clients or jurisdictions;
Politically Exposed Persons (PEPs);
Clients transacting large volumes or using complex structures.
EDD may include requesting additional documents, verifying source of wealth, or conducting senior-management approval.
5.3 Simplified Due Diligence
Applied only where the risk of money laundering is demonstrably low and permitted by law—never for trading accounts involving leverage or high-risk assets.
6. Liveliness and Identity Verification
6. Liveliness and Identity Verification
As part of our digital KYC process, clients may be required to complete a liveliness check, submitting a short video or selfie to confirm that:
The person submitting documents matches the provided ID; and
The verification is conducted in real time by a live individual.
This measure prevents identity theft and the use of forged documentation.
As part of our digital KYC process, clients may be required to complete a liveliness check, submitting a short video or selfie to confirm that:
The person submitting documents matches the provided ID; and
The verification is conducted in real time by a live individual.
This measure prevents identity theft and the use of forged documentation.
7. Ongoing Monitoring of Transactions
7. Ongoing Monitoring of Transactions
GatesFX maintains automated and manual monitoring systems to identify suspicious patterns, including:
Unusual deposit or withdrawal frequencies;
Transactions inconsistent with a client’s profile;
Rapid movement of funds between unrelated accounts;
Activity involving sanctioned countries, currencies, or entities.
Transactions flagged by the monitoring system are reviewed by the Compliance Department, and escalated when necessary.
GatesFX maintains automated and manual monitoring systems to identify suspicious patterns, including:
Unusual deposit or withdrawal frequencies;
Transactions inconsistent with a client’s profile;
Rapid movement of funds between unrelated accounts;
Activity involving sanctioned countries, currencies, or entities.
Transactions flagged by the monitoring system are reviewed by the Compliance Department, and escalated when necessary.
8. Sanctions Screening
8. Sanctions Screening
All clients and counterparties are screened against recognized global sanctions lists, including:
UN Security Council Sanctions List
OFAC (Specially Designated Nationals)
EU and UK Sanctions Lists
Accounts linked to sanctioned individuals or entities are frozen pending investigation and may be reported to authorities.
All clients and counterparties are screened against recognized global sanctions lists, including:
UN Security Council Sanctions List
OFAC (Specially Designated Nationals)
EU and UK Sanctions Lists
Accounts linked to sanctioned individuals or entities are frozen pending investigation and may be reported to authorities.
9. Reporting of Suspicious Activities
9. Reporting of Suspicious Activities
If suspicious activity is identified:
The Compliance Officer will review and document the case.
A Suspicious Activity Report (SAR) may be filed with the Financial Intelligence Authority of St. Lucia (FIA) or other competent bodies.
Clients will not be notified of any SAR filing (“tipping off” is strictly prohibited).
Failure to comply with reporting obligations is a criminal offense under applicable laws.
If suspicious activity is identified:
The Compliance Officer will review and document the case.
A Suspicious Activity Report (SAR) may be filed with the Financial Intelligence Authority of St. Lucia (FIA) or other competent bodies.
Clients will not be notified of any SAR filing (“tipping off” is strictly prohibited).
Failure to comply with reporting obligations is a criminal offense under applicable laws.
10. Record Keeping
10. Record Keeping
GatesFX retains all KYC, transaction, and communication records for a minimum of five (5) years after the relationship ends.
Records are stored securely, encrypted, and accessible only to authorized compliance personnel and regulators upon request.
GatesFX retains all KYC, transaction, and communication records for a minimum of five (5) years after the relationship ends.
Records are stored securely, encrypted, and accessible only to authorized compliance personnel and regulators upon request.
11. Employee Training and Awareness
11. Employee Training and Awareness
All GatesFX employees receive mandatory AML/CTF training, including:
Recognizing red flags and suspicious behavior;
Handling and reporting procedures;
Confidentiality and data-protection obligations.
Refresher training is conducted annually to ensure continuous compliance awareness.
All GatesFX employees receive mandatory AML/CTF training, including:
Recognizing red flags and suspicious behavior;
Handling and reporting procedures;
Confidentiality and data-protection obligations.
Refresher training is conducted annually to ensure continuous compliance awareness.
12. Risk-Based Approach
12. Risk-Based Approach
GatesFX employs a risk-based approach to AML compliance by:
Assessing client, geographic, and transactional risk factors;
Assigning internal risk scores;
Adjusting CDD intensity and monitoring frequency accordingly.
This ensures resources are focused where risk is highest while maintaining regulatory balance.
GatesFX employs a risk-based approach to AML compliance by:
Assessing client, geographic, and transactional risk factors;
Assigning internal risk scores;
Adjusting CDD intensity and monitoring frequency accordingly.
This ensures resources are focused where risk is highest while maintaining regulatory balance.
13. Third-Party Payments and Transfers
13. Third-Party Payments and Transfers
GatesFX does not accept or process third-party deposits or withdrawals.
All funds must originate from and be returned to an account in the client’s own name.
Payments made from unverified or unrelated sources will be rejected and refunded.
GatesFX does not accept or process third-party deposits or withdrawals.
All funds must originate from and be returned to an account in the client’s own name.
Payments made from unverified or unrelated sources will be rejected and refunded.
14. Non-Compliance Consequences
14. Non-Compliance Consequences
Failure by a client to provide required information or cooperate with AML checks may result in:
Account suspension or closure;
Freezing of funds pending verification;
Reporting to competent authorities.
GatesFX reserves the right to terminate any business relationship immediately if AML obligations are not met.
Failure by a client to provide required information or cooperate with AML checks may result in:
Account suspension or closure;
Freezing of funds pending verification;
Reporting to competent authorities.
GatesFX reserves the right to terminate any business relationship immediately if AML obligations are not met.
15. Policy Updates
15. Policy Updates
GatesFX LTD reserves the right to amend or update this policy at any time to reflect operational, legal, or regulatory changes. Any updates will be published on the official GatesFX website and shall take effect immediately upon publication. Continued use of our services constitutes acceptance of any changes.
GatesFX LTD reserves the right to amend or update this policy at any time to reflect operational, legal, or regulatory changes. Any updates will be published on the official GatesFX website and shall take effect immediately upon publication. Continued use of our services constitutes acceptance of any changes.
Disclaimer
This AML & CTF Policy should be read in conjunction with the KYC Verification Policy, Anti-Fraud Policy, Deposit Policy, and Withdrawal Policy.
By opening an account or using GatesFX services, clients acknowledge and agree to the procedures and obligations outlined in this document.
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GatesFX is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services.
Registration number: 00396 IBC 2024
Copyright 2025. GatesFX LTD.
All rights reserved.
Registration Address:
Ground floor, The Sotheby Building,
Rodney Village, Rodney Bay,
Gros Islet, St. Lucia
AML Policy
Risk Disclosure
Privacy Policy
Refund Policy
Opening an Account
GatesFX LTD, is an Authorized Financial Services Provider (“FSP”) licensed and regulated by the Financial Sector Conduct Authority (“FSCA”) in South Africa (FSP No. 46087).
GatesFX LTD is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services and provides access to trading services in accordance with applicable laws and regulations.
Client accounts are onboarded through GatesFX LTD, a company incorporated in Saint Lucia (Reg. No. 00396 ICB 2024). By opening an account with GatesFX LTD, you confirm that you are at least eighteen (18) years of age (or the legal age in your jurisdiction), that you are acting of your own free will without solicitation from GatesFX, and that you will ensure compliance with all applicable local laws and regulations.
!
Risk Warning: Trading Forex and CFDs carries a high level of risk to your capital and you should only trade with funds you can afford to lose. Trading Forex and CFDs may not be suitable for all investors, so please ensure that you fully understand the risks involved and seek independent advice if necessary. Please read and ensure you fully understand our Risk Disclosure.
Restricted Countries: GatesFX LTD does not provide services for residents of certain countries, including Israel, New Zealand, Iran, and North Korea (Democratic Peoples's Republic of Korea), or any country where such distribution or use would be contrary of local law or regulation. Furthermore, GatesFX LTD does not solicit citizens of the Untied States of America. Please check with your local jurisdiction to determine if you are permitted to open an account with GatesFX LTD.
It is your responsibility to determine whether you are permitted to open an account with GatesFX.
Disclaimer: The information provided herein reflects personal opinions and ideas and does not constitute a recommendation to purchase financial services or guarantee the performance or outcomes of future transactions. This material is not intended to be interpreted as financial advice. While every effort has been made to ensure the accuracy, validity and completeness of the information, no guarantees are provided and no liability is accepted for any losses incurred as a result of investments made based on this material. Nothing contained on this site should be considered or construed as professional advice from GatesFX LTD, its affiliates, directors, officer, or employees.
GatesFX is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services.
Registration number: 00396 IBC 2024
Copyright 2025. GatesFX LTD.
All rights reserved.
Registration Address:
Ground floor, The Sotheby Building,
Rodney Village, Rodney Bay,
Gros Islet, St. Lucia
AML Policy
Risk Disclosure
Privacy Policy
Refund Policy
Opening an Account
GatesFX LTD, is an Authorized Financial Services Provider (“FSP”) licensed and regulated by the Financial Sector Conduct Authority (“FSCA”) in South Africa (FSP No. 46087).
GatesFX LTD is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services and provides access to trading services in accordance with applicable laws and regulations.
Client accounts are onboarded through GatesFX LTD, a company incorporated in Saint Lucia (Reg. No. 00396 ICB 2024). By opening an account with GatesFX LTD, you confirm that you are at least eighteen (18) years of age (or the legal age in your jurisdiction), that you are acting of your own free will without solicitation from GatesFX, and that you will ensure compliance with all applicable local laws and regulations.
!
Risk Warning: Trading Forex and CFDs carries a high level of risk to your capital and you should only trade with funds you can afford to lose. Trading Forex and CFDs may not be suitable for all investors, so please ensure that you fully understand the risks involved and seek independent advice if necessary. Please read and ensure you fully understand our Risk Disclosure.
Restricted Countries: GatesFX LTD does not provide services for residents of certain countries, including Israel, New Zealand, Iran, and North Korea (Democratic Peoples's Republic of Korea), or any country where such distribution or use would be contrary of local law or regulation. Furthermore, GatesFX LTD does not solicit citizens of the Untied States of America. Please check with your local jurisdiction to determine if you are permitted to open an account with GatesFX LTD.
It is your responsibility to determine whether you are permitted to open an account with GatesFX.
Disclaimer: The information provided herein reflects personal opinions and ideas and does not constitute a recommendation to purchase financial services or guarantee the performance or outcomes of future transactions. This material is not intended to be interpreted as financial advice. While every effort has been made to ensure the accuracy, validity and completeness of the information, no guarantees are provided and no liability is accepted for any losses incurred as a result of investments made based on this material. Nothing contained on this site should be considered or construed as professional advice from GatesFX LTD, its affiliates, directors, officer, or employees.
GatesFX is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services.
Registration number: 00396 IBC 2024
Copyright 2025. GatesFX LTD.
All rights reserved.
Registration Address:
Ground floor, The Sotheby Building,
Rodney Village, Rodney Bay,
Gros Islet, St. Lucia
AML Policy
Risk Disclosure
Privacy Policy
Refund Policy
Opening an Account
GatesFX LTD, is an Authorized Financial Services Provider (“FSP”) licensed and regulated by the Financial Sector Conduct Authority (“FSCA”) in South Africa (FSP No. 46087).
GatesFX LTD is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services and provides access to trading services in accordance with applicable laws and regulations.
Client accounts are onboarded through GatesFX LTD, a company incorporated in Saint Lucia (Reg. No. 00396 ICB 2024). By opening an account with GatesFX LTD, you confirm that you are at least eighteen (18) years of age (or the legal age in your jurisdiction), that you are acting of your own free will without solicitation from GatesFX, and that you will ensure compliance with all applicable local laws and regulations.
!
Risk Warning: Trading Forex and CFDs carries a high level of risk to your capital and you should only trade with funds you can afford to lose. Trading Forex and CFDs may not be suitable for all investors, so please ensure that you fully understand the risks involved and seek independent advice if necessary. Please read and ensure you fully understand our Risk Disclosure.
Restricted Countries: GatesFX LTD does not provide services for residents of certain countries, including Israel, New Zealand, Iran, and North Korea (Democratic Peoples's Republic of Korea), or any country where such distribution or use would be contrary of local law or regulation. Furthermore, GatesFX LTD does not solicit citizens of the Untied States of America. Please check with your local jurisdiction to determine if you are permitted to open an account with GatesFX LTD.
It is your responsibility to determine whether you are permitted to open an account with GatesFX.
Disclaimer: The information provided herein reflects personal opinions and ideas and does not constitute a recommendation to purchase financial services or guarantee the performance or outcomes of future transactions. This material is not intended to be interpreted as financial advice. While every effort has been made to ensure the accuracy, validity and completeness of the information, no guarantees are provided and no liability is accepted for any losses incurred as a result of investments made based on this material. Nothing contained on this site should be considered or construed as professional advice from GatesFX LTD, its affiliates, directors, officer, or employees.
GatesFX is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services.
Registration number: 00396 IBC 2024
Copyright 2014-2025. GatesFX LTD. All rights reserved. Registration Address: Ground floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros Islet, St. Lucia
AML Policy
Risk Disclosure
Privacy Policy
Refund Policy
Opening an Account
GatesFX LTD, is an Authorized Financial Services Provider (“FSP”) licensed and regulated by the Financial Sector Conduct Authority (“FSCA”) in South Africa (FSP No. 46087).
GatesFX LTD is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services and provides access to trading services in accordance with applicable laws and regulations.
Client accounts are onboarded through GatesFX LTD, a company incorporated in Saint Lucia (Reg. No. 00396 ICB 2024). By opening an account with GatesFX LTD, you confirm that you are at least eighteen (18) years of age (or the legal age in your jurisdiction), that you are acting of your own free will without solicitation from GatesFX, and that you will ensure compliance with all applicable local laws and regulations.
!
Risk Warning: Trading Forex and CFDs carries a high level of risk to your capital and you should only trade with funds you can afford to lose. Trading Forex and CFDs may not be suitable for all investors, so please ensure that you fully understand the risks involved and seek independent advice if necessary. Please read and ensure you fully understand our Risk Disclosure.
Restricted Countries: GatesFX LTD does not provide services for residents of certain countries, including Israel, New Zealand, Iran, and North Korea (Democratic Peoples's Republic of Korea), or any country where such distribution or use would be contrary of local law or regulation. Furthermore, GatesFX LTD does not solicit citizens of the Untied States of America. Please check with your local jurisdiction to determine if you are permitted to open an account with GatesFX LTD.
It is your responsibility to determine whether you are permitted to open an account with GatesFX.
Disclaimer: The information provided herein reflects personal opinions and ideas and does not constitute a recommendation to purchase financial services or guarantee the performance or outcomes of future transactions. This material is not intended to be interpreted as financial advice. While every effort has been made to ensure the accuracy, validity and completeness of the information, no guarantees are provided and no liability is accepted for any losses incurred as a result of investments made based on this material. Nothing contained on this site should be considered or construed as professional advice from GatesFX LTD, its affiliates, directors, officer, or employees.
GatesFX is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services. Registration number: 00396 IBC 2024
Copyright 2025. GatesFX LTD. All rights reserved. Registration Address: Ground floor, La Place Creole Building, Rodney Village, Rodney Bay, Gros Islet, St. Lucia
AML Policy
Risk Disclosure
Privacy Policy
Refund Policy
Opening an Account
GatesFX LTD, is an Authorized Financial Services Provider (“FSP”) licensed and regulated by the Financial Sector Conduct Authority (“FSCA”) in South Africa (FSP No. 46087).
GatesFX LTD is an international broker regulated by the International Financial Centre of St. Lucia, ensuring transparency and compliance with international standards of the company's services and provides access to trading services in accordance with applicable laws and regulations.
Client accounts are onboarded through GatesFX LTD, a company incorporated in Saint Lucia (Reg. No. 00396 ICB 2024). By opening an account with GatesFX LTD, you confirm that you are at least eighteen (18) years of age (or the legal age in your jurisdiction), that you are acting of your own free will without solicitation from GatesFX, and that you will ensure compliance with all applicable local laws and regulations.
!
Risk Warning: Trading Forex and CFDs carries a high level of risk to your capital and you should only trade with funds you can afford to lose. Trading Forex and CFDs may not be suitable for all investors, so please ensure that you fully understand the risks involved and seek independent advice if necessary. Please read and ensure you fully understand our Risk Disclosure.
Restricted Countries: GatesFX LTD does not provide services for residents of certain countries, including Israel, New Zealand, Iran, and North Korea (Democratic Peoples's Republic of Korea), or any country where such distribution or use would be contrary of local law or regulation. Furthermore, GatesFX LTD does not solicit citizens of the Untied States of America. Please check with your local jurisdiction to determine if you are permitted to open an account with GatesFX LTD.
It is your responsibility to determine whether you are permitted to open an account with GatesFX.
Disclaimer: The information provided herein reflects personal opinions and ideas and does not constitute a recommendation to purchase financial services or guarantee the performance or outcomes of future transactions. This material is not intended to be interpreted as financial advice. While every effort has been made to ensure the accuracy, validity and completeness of the information, no guarantees are provided and no liability is accepted for any losses incurred as a result of investments made based on this material. Nothing contained on this site should be considered or construed as professional advice from GatesFX LTD, its affiliates, directors, officer, or employees.
**Take your first trade in
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**Take your first trade in
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