Liquid Markets and related entities partner with Sumsub.com for our KYC requirements. The Company shall follow customer identification procedure for opening of accounts and monitoring transactions of a suspicious nature for the purpose of reporting it to appropriate authority. The policy is based on Anti Money Laundering (AML) standards.

Policies

1- Information collected from the customer for the purpose of opening of account shall be kept confidential and the Company shall not divulge any details thereof for cross selling or any other purposes. Information sought from the customer shall be relevant to the perceived risk, shall not be intrusive, and shall be in conformity with the guidelines issued by Liquid Markets from time to time. Any other information from the customer shall be sought separately with his/ her/ its consent and after opening the account.

2- The objective of the KYC policy is to prevent the Company from being used, intentionally or unintentionally, by criminal elements for money laundering activities. KYC procedures also enable the Company to know/ understand its customers and their financial dealings better, which in turn help the Company to manage its risks prudently. The Company has framed its KYC policy incorporating the following four key elements:

(i) Customer Acceptance Policy;

(ii) Customer Identification Procedures;

(iii) Monitoring of Transactions/ On-going Due Diligence; and

(iv) Risk Management.

3- For the purpose of the KYC policy:

a) “Beneficial Owner” refers to the natural person(s) who ultimately owns or controls a customer and/ or the natural person on whose behalf a transaction is being conducted. It also includes those persons who exercise ultimate effective control over a legal person or arrangement.

b) “Customer” means a person that engages in a financial transaction or activity with the Company and includes a person on whose behalf the person that engages in the transaction or activity is acting.

c) 'Customer Due Diligence (CDD)' means identifying and verifying the customer and the beneficial owner using 'Officially Valid Documents' as a 'proof of identity' and 'proof of address'.

h) 'Politically Exposed Persons (PEPs)' are:

(i) individuals who are or have been entrusted with prominent public functions domestically or by a foreign country, e.g., Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials;

(ii) international organization PEPs who are or have been entrusted with a prominent function by an international organization, refers to members of senior management or individuals who have been entrusted with equivalent functions, i.e., directors, deputy directors and members of the board or equivalent functions, and

(iii) family members related to PEP either directly (consanguinity) or through marriage or similar (civil) forms of partnership; and

(v) close associates are individuals who are closely connected to a PEP, either socially or professionally.

(j) “Principal Officer” means an officer designated by the Company.

4- Customer Acceptance Policy (CAP):

The criteria for acceptance of customers are as follows:

(i) No account shall be opened in anonymous or fictitious/ benami name(s)

(ii) No transaction or account based relationship will be undertaken without following the Customer Due Diligence (CDD) procedure.

a. The mandatory information to be sought for KYC purpose while opening an account and during the periodic updates as specified, should be obtained.

b. 'Optional'/additional information is obtained with the explicit consent of the customer after the account is opened.

c. CDD procedure is followed for all the joint account holders while opening a Joint Account.

(iii) Circumstances, in which a customer is permitted to act on behalf of another person/entity, should be clearly spelt out in conformity with the established law as there could be occasions when an account is operated by a mandate holder or where an account may be opened by an intermediary in the fiduciary capacity;

(iv) Parameters of risk assessment in terms of the customers’ identity, social/ financial status, nature of business activity, information about the clients’ business and their locations, etc. have been defined to enable categorization of customers into low, medium and high risk.

While considering customer’s identity, the ability to confirm identity documents through online or other services offered by issuing authorities or other entities may also be factored in documentation requirements and other information to be collected in respect of different categories of customers depending on perceived risk and keeping in mind the requirements of PML Act, 2002 and guidelines issued by Liquid Markets from time to time;

(v) The Company shall not open an account where it is unable to apply appropriate CDD measures, i.e., the Company is unable to verify the identity and /or obtain documents required as per the risk categorisation due to non-cooperation of the customer or non-reliability of the data/information furnished to the Company. It may, however, be necessary to have suitable built in safeguards to avoid harassment of the customer. For example, decision to close an account may be taken at a reasonably high level after giving due notice to the customer explaining the reasons for such a decision;

(vi) Before opening a new account necessary screening will be performed so as to ensure that the identity of the customer does not match with any person with known criminal background or with banned entities such as individual terrorists or terrorist organizations or whose name appears in the lists circulated by RBI/ SEBI/ NHB/ IRDA, United Nations Security Council (UNSC), OFAC, as per section 51A of the Unlawful Activities (Prevention) Act, 1967, watch list by Interpol, etc. These are done using the list/ information/ databases available on World-check, Watch-out Investors, website of OFAC, UNSCR (as mentioned below) or such other information sources/tools. The Company shall prepare a profile for each new customer based on risk categorization, as provided subsequently in this policy. The customer profile will be a confidential document and details contained therein shall not be divulged for cross selling or any other purposes.

(vii) For the purpose of risk categorisation, individuals (other than High Net Worth individuals) and entities whose identities and sources of wealth can be easily identified and transactions in whose accounts by and large conform to the known profile, may be categorised as low risk.

Illustrative examples of low risk customers could be salaried employees whose salary structures are well defined, people belonging to lower economic strata of the society whose accounts show small balances and low turnover, Government departments & Government owned companies, regulators and statutory bodies etc. In such cases, only the basic requirements of verifying the identity and location of the customer are to be met. Customers that are likely to pose a higher than average risk to the company shall be categorized as medium or high risk depending on customer’s background, nature and location of activity, country of origin, sources of funds and client profile etc. The Company shall apply enhanced due diligence measures based on the risk assessment, thereby requiring intensive ‘due diligence’ for higher risk customers, especially those for whom the sources of funds are not clear. Examples of customers requiring enhanced due diligence shall include (a) trusts, charities, NGOs and organizations receiving donations, (c) companies having close family shareholding or beneficial ownership, (d) firms with ‘sleeping partners’, (e) Politically Exposed Persons, (f) those with dubious reputation as per public information available, etc. The adoption of customer acceptance policy and its implementation should not become too restrictive and must not result in denial of financial facility to members of the general public, especially those, who are financially or socially disadvantaged.

5- Customer Identification Procedure (CIP)

Customer Identification Procedure to be carried out at different stages as under:

Commencement of an account-based relationship with the customer; When the Company has a doubt about the authenticity or adequacy of the customer identification data obtained by the Company. Customer identification means identifying the customer and verifying his/ her/ its identity by using reliable, independent source documents, data or information; and Carrying out a financial transaction.

a) The Company shall obtain sufficient information necessary to establish, to its satisfaction, the identity of each new customer, whether regular or occasional, and the purpose of the intended nature of business relationship. Being satisfied means that the Company should be able to satisfy the competent authorities that due diligence was observed based on the risk profile of the customer, in compliance with the extant guidelines in place. Besides risk perception, the nature of information/documents required would also depend on the type of customer (individual, corporate, etc.). For customers that are natural persons, the Company shall obtain sufficient identification data to verify the identity of the customer, his/ her address/ location, and also his/ her recent photograph. For customers that are legal persons or entities, the Company shall

(i) verify the legal status of the legal person/ entity through proper and relevant documents;

(ii) verify that any person purporting to act on behalf of the legal person/entity is so authorized and identify and verify the identity of that person; and

(iii) understand the ownership and control structure of the customer and determine who are the natural persons who ultimately control the legal person.

If the Company accepts such accounts in terms of the Customer Acceptance Policy, the Company shall take reasonable measures to identify the beneficial owner(s) and verify his/ her/ their identity in a manner so that it is satisfied that it knows who the beneficial owner(s) is/are.

Our list of the nature and type of documents/information that shall be relied upon for customer identification is;

passport or national ID number, and country of issuance;

date of birth;

residential or business address;

phone number;

email address;

sample signatures;

other financial information, such as the purpose for opening a trading account, source of funds, etc.

b) Introduction shall not be sought while opening accounts.

c) The Company shall not ask the customer to furnish an additional OVD, if the OVD submitted by the customer for KYC contains both proof of identity and proof of address. Further, the customer shall not be required to furnish separate proof of address for permanent and current addresses, if these are different. The Company shall obtain a declaration from the customer about her/ his local address on which all correspondence will be made by the Company, in the event the proof of address furnished by the customer is the address where the customer is currently residing.

The Company shall allot Unique Customer Identification Code (UCIC) to all their customers while entering into any new relationships.

6- Monitoring of Transactions/ On-going Due Diligence:

a) The Company shall pay special attention to all large and complex transactions including RTGS transactions, and those with unusual patterns, inconsistent with normal and expected activity of the customer, which have no apparent economic rationale or legitimate purpose.

b) The Company shall prescribe threshold limits for specific categories of accounts and pay particular attention to the transactions which exceed prescribed thresholds, based on income and / or net worth of the customer.

c) Currently, no cash transactions are done by the Company, since all disbursements and repayments are made through normal banking channels only. However, should it ever be necessary to operate cash, transactions that involve large amounts of cash inconsistent with the normal and expected activity of the customer should particularly attract the attention of the company. Very high account turnover inconsistent with the size of the balance maintained may indicate that funds are being 'washed' through the account.

d) High-risk accounts shall be subjected to intensify monitoring and enhanced due diligence. The Company shall set key indicators for such accounts, taking note of the background of the customer, such as the country of origin, sources of funds, the type of transactions involved and other risk factors. The Company shall put in place a system of periodical review of risk categorization of accounts, with such periodicity being at least once in 6 (six) months and the need for applying enhanced due diligence measures.

e) The records of transactions in the accounts shall be preserved and maintained as required in terms of section 12 of the PML Act, 2002. The Company shall report the transactions of suspicious nature and/ or any other type of transaction notified under section 12 of the PMLAct, 2002, to the appropriate law enforcement authority.

f) While currently, no cash transactions are undertaken, in the unforeseen event of such transactions taking place, the Company will maintain a proper record of all cash transactions (deposits and withdrawals) of $100 USD and above. The internal monitoring system shall have an inbuilt procedure for reporting of such transactions and those of suspicious nature to controlling/ head office on a fortnightly basis.

7- Risk Management:

a) Through this policy, the Board of Directors of the Company is ensuring the formal documentation of its KYC programme. The management will establish appropriate procedures to ensure its effective implementation.

b) The Company’s internal audit and compliance functions have an important role in evaluating and ensuring adherence to the KYC policies and procedures. As a general rule, the compliance function would provide an independent evaluation of the Company’s own policies and procedures, including legal and regulatory requirements. The audit machinery shall be staffed adequately with individuals who are well-versed in such policies and procedures. The Internal Auditors shall specifically check and verify the application of KYC procedures at the branches and comment on the lapses observed in this regard. The compliance in this regard shall be put up before the Audit Committee of the Board on quarterly intervals.

c) The Company shall have an ongoing employee training programme so that the members of the staff are adequately trained in KYC and AML procedures. Training requirements shall have different focuses for frontline staff, compliance staff and staff dealing with new customers. It is crucial that all those concerned fully understand the rationale behind the KYC policy and implement the same consistently.

8- Review of KYC for the Existing Accounts:

a) The Company shall also apply this policy to the existing customers on the basis of materiality and risk. Moreover, transactions in existing accounts shall be continuously monitored and any unusual pattern in the operation of the account shall trigger a review of the CDD measures.

b) The Company shall consider applying monetary limits to such accounts based on the nature and type of the account. All the existing accounts of companies, firms, trusts, charities, religious organizations and other institutions are subjected to minimum KYC standards which would establish the identity of the natural/legal person and those of the ‘beneficial owners’. Where the Company is unable to apply appropriate KYC measures due to non-furnishing of information and/ or non-cooperation by the customer, the Company shall consider closing the account or terminating the business relationship after issuing due notice to the customer explaining the reasons for taking such a decision. Such decisions shall be taken at a reasonably senior leve

c) The Company shall carry out periodic updation at least once in every 2 years for high risk customers, once in every 8 years for medium risk customers and once in every 10 years for low risk customers, subject to the following conditions:

– Fresh proofs of identity and address shall not be sought at the time of periodic updation, from low risk customers, when there is no change in status of their identities and addresses and a self-certification to that effect is obtained;

– certified copy of the proof of address forwarded by ‘low risk’ customers through mail/ post, etc. in case of change of address shall be acceptable;

– physical presence of low risk customer at the time of periodic updations shall not be insisted upon; and

– time limits prescribed above would apply from the date of opening of the account/ last verification of KYC.

9- Appointment of Principal Officer:

The Company has appointed a senior management officer designated as the Principal Officer. The Principal Officer shall be located at the head office of the Company and shall be responsible for monitoring and reporting of all transactions and sharing of information as required under the law. The Principal Officer will maintain close liaison with enforcement agencies, the Company and any other institution, which are involved in the fight against money laundering and combating financing of terrorism.

10- Record Management:

In order to maintain preserve and report the customer account information with reference to provisions of PML Act and Rules the Company shall

1) maintain all necessary records of transactions between the Company and the customer for at least 5 (five) years from the date of transaction;

2) preserve the records pertaining to the identification of the customers and their addresses obtained while opening the account and during the course of business relationship for at least5 (five) years after the business relationship is ended;

3) make available the identification records and transaction data to the competent authorities upon request;

4) introduce a system of maintaining proper record of transactions prescribed under Rule 3 of Prevention of Money Laundering (Maintenance of Records) Rules, 2005;

5) maintain all necessary information in respect of transactions prescribed under PML Rule 3 as to permit reconstruction of individual transaction, including the nature, amount and date of transaction and the parties to the transaction;

6) evolve a system for proper maintenance and preservation of account information in a manner that allows easy and quick retrieval of data whenever required or requested by the competent authorities; and

7) maintain records of identity and address of the customers and records in respect of transactions referred to in PML Rule 3 in hard or soft format.

The Company shall upload the KYC data pertaining to all new individual accounts opened on or after April 1, 2017 with CERSAI in terms of the provisions of the Prevention of Money Laundering (Maintenance of Records) Rules, 2005.

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Liquid Market PTY LLC AFFILIATE TERMS & CONDITIONS

Definitions

The Introducing Broker (IB) indicates existing and potential clients in the process of attaining

affiliation with the Company pursuant to the Terms and Conditions of this Agreement. The

Introducing Broker and the Company may be individually referred to as “Party” or

collectively referred to as “Parties”.

1.1. In this Agreement, the following terms shall have the meaning identified below:-

1.2 “Existing Client” refers to a client of the Company who has agreed to the Terms and

Conditions of the Client Agreement.

1.3 “Potential Client” refers to a potential client of the Company.

1.4 “Referral” refers to a trader that has been referred to the platform via IBs.

1.5 “Client Account” refers to the account allocated to a Client following registration with the

Company.

1.6 “Client Agreement” refers to the Terms of Use and Privacy Policy on the Company

Website.

1.7 “Company” refers to LIQUID MARKETS, a company incorporated in Saint Vincent

and the Grenadines.

1.8 “Company Services” means the exchange platform and the related customer support

provided by the Company.

1.9 “Company Website” means https://LIQUIDmarkets.com/

1.10 “Confidential Information” means any confidential information divulged from one Party

to the other Party pursuant to this Agreement and which encompasses, amongst others; ideas,

techniques, models, and data; computer software in source or object code and related

documentation, flowcharts and diagrams; marketing techniques and materials, marketing

plans, strategies, and development plans (including prospective trade names and trademarks);

client names, information and pricing policies; and financial information.

1.11 From the date of affiliation and account creation, the IB accepts the Terms and

Conditions of this Agreement.

1.12 “Introducing Broker/IB” refers to an individual or legal entity which introduces referrals

to the company and operates in the interests of the Company, on the basis of this Agreement.

1.13 “IB code” refers to the IB’s unique identification code.

1.14 “Privacy Policy” refers to the Company’s Privacy Policy as amended from time to time.

1.15 “Referral Commission” refers to the commission payable by the Company to the IB

within the context of this Agreement.

1.16 “Referral link” means the link to the Company Website containing the IB’s unique

identification number, which is to be used by the IB to introduce referrals to the broker

platform.

1.17 “Terms of Use” means the Company’s Terms of Use at

https://LIQUIDmarkets.com/terms-and-conditions as amended from time to time.

2. General Terms

2.1. In conformity with the Terms and Conditions of this Agreement, an Existing Client who

is a party to, and is in compliance with the Client Agreement with the Company and uses a

trading account to trade on the Company Website shall have the right to introduce a referral

to the Company on the basis of and under the conditions provided herein.

2.2. The Terms and Conditions of this Agreement become binding for each IB at the moment

the IB joins the LIQUID MARKETS Affiliate Program. This Agreement contains all the

Terms and Conditions that regulate the relationship between the Company and the IB.

2.3. To become an IB of the Company, an individual or a legal entity must:

Be an Existing Client of the Company; and

Comply with this Agreement and receive an IB Code and a Referral Link.

2.4. In addition to any documents and/or information provided to the Company as part of the

initial registration process as a Client, the Company reserves the right to request any

additional documents and/or information in order to verify the status of the IB as an

individual or legal entity.

2.5. From the Effective Date the IB may:

Carry out advertising campaigns in the interest of the Company;

Hold events directed towards the acquisition of new Referrals to the Company

(provided that the events do not violate the laws of the country in which they are held,

or of the country of residence of the IB);

Provide Referrals with information about the Company’s line of business and

company services available, the competitive advantages of the Company and other

terms and conditions;

 Communicate all necessary information about the Company to Referrals, including

the Company’s address and contact information, and general and special conditions

for the provision of company services;

Help new Referrals to get acquainted with the Company website, refer and clarify

documents and information posted on the Company Website (including but not

limited to the terms of this Agreement and the Client Agreement).

The IB acknowledges access to all data and trades conducted by Referrals that utilize

the IB’s unique Referral Link. To this effect, the IB endeavours to inform his/her

Referrals of this procedure.

3. Interaction of the Parties

3.1. The IB shall not, under any circumstance, construe this Agreement as the creation of a

partnership, joint venture, agency, or employer-employee relationship. The IB may only

operate and act in relation to third parties as an Existing Client of the Company, serving as an

IB and not in any other capacity.

3.2. The IB is not a representative of the Company and is not authorized by the Company to

provide any of the Company Services on the Company’s behalf and the IB must not do or say

anything to imply anything to the contrary to any Referral.

3.3. The IB shall be granted a non-exclusive, non-transferable, non-assignable, limited

royalty-free license to use the Company name, logo, trademarks (registered or not registered)

provided in the Client Account (the “Company Marks”), the Referral link, and/or advertising

materials provided by the Company in Client referrals. Nothing in this Agreement creates or

grants any proprietary right, title, or interest to any of the Company Marks and/or advertising

materials and the IB acknowledges any such rights to the Company Marks and advertising

materials shall remain the sole and absolute property of the Company.

3.4. The Company shall not under any circumstances whatsoever be responsible for:

Any actions carried out by the IB that is in violation of the provisions of this

Agreement and/or the Client Agreement;

Any actions of the IB beyond the authority granted by the Company pursuant to this

Agreement;

Any complaint lodged against the IВ acting in his capacity as an IB.

3.5. The Parties are obligated to comply with the provisions set out in this Agreement and/or

the Client Agreement.

4. Obligations of the Introducing Broker

4.1. It shall be the IB’s responsibility to promote the Company and/or the Company Services

in compliance with all the applicable laws of his (if the IB is an individual) or its (if the IB is

a company) country of residence and/or incorporation (as the case may be) where the

introduction of the Referral are taking place. The Company in no way accepts any

responsibility for any violation of such laws committed by the IB.

4.2. The IB shall promptly notify the Company in writing of any assertion of any material

claim against the IB by any Client(s) and/or Referred Client(s), or of any suit and/or

proceedings by any Client(s), Referrals and/or regulatory agency against the IB.

4.3. The IB is obligated to put forth maximum effort in introducing Referrals to the

Company.

4.4. If the Referral is deemed to be introduced by the IB, the IB Code will automatically be

placed in all following trading accounts opened by the Referral. A Referral cannot be

transferred to another IB. In the event that the IB terminates its/his Client Account with the

Company for whatever reason, the IB code will be removed in the trading account opened by

the Referral. For the avoidance of doubt, in such an event, the Referral will not be able to be

referred by any other IB or transferred to any other IB.

4.5. The Company reserves the right to independently register a Referral as having been

referred by the IB if the Referral writes to the Company with a request to attach the Referral’s

Client Account to a particular IB within one 30 (thirty) business days after registration. The

request may be made to the Company in the following ways:

4.5.1. By email at support@liquidmarkets.com

4.5.2. The instant messaging function available on the Client Account; or

4.5.3. The chatbot function is available on the Company Website.

The Referral shall be required to explain why registration was not affected via the use of the

Referral Link of the IB.

4.6. The IB must stop using any advertising material provided by the Company and/or the

Company Marks immediately upon written request of the Company. In the event that IB does

not comply with this written request within fourteen (14) days of receiving the same, the

Company shall have the right to terminate this Agreement unilaterally.

4.7. The IB may not make use of any dishonest advertising methods for the purpose of

promoting themselves on the internet. In particular, it is forbidden to:

4.7.1. Use methods of website promotion that violate the rules of internet search engines,

knowingly manipulate the results of internet searches and use other methods of promotion

that misinform or mislead search engines or search engine users;

4.7.2. Knowingly mislead website visitors by improperly redirecting them to other websites

or internet resources;

4.7.3. Use advertising material containing false information, pornographic content, or

material that serves to ignite ethnic conflict or racial discrimination;

4.7.4. Send mass mailings of any kind whether of a commercial, political, or any other nature

which the recipients have not expressed a desire to receive;

4.7.5. Use advertising material containing false information about the Company and/or the

Company Services offered or knowingly conceal risks from Referrals relating to the same;

4.7.6. Use any materials which may damage the positive image of the Company;

4.7.7. Use any other dishonest advertising methods.

4.8. The IB shall not:

Register and/or use any Company Marks or domain names containing a part of or the

term LIQUID MARKETS or any other variation of this phrase in writing; and

Register an organization and/or use in the name of an existing Company a part of or

the term LIQUID MARKETS, or any other variation of this phrase in writing.

4.9. The IB is strictly forbidden from advertising in contextual advertising systems such as

Yandex, Direct, Begun, and Google AdWords using keywords containing “LIQUID

MARKETS”; and advertising in banner networks, internet catalogues, etc.

4.10. The IB is obligated to inform the Company of any facts or circumstances of which it

has become aware regarding any of its Referrals that could lead to adverse consequences

(risks) for the Company.

4.11. Should Existing Clients or Referrals lodge complaints regarding the activity of the IB,

the IB shall be obligated to independently address all such complaints at the IB’s sole

expense.

5. Rights and Obligations of the Company

5.1. The Company is obligated to pay the Referral Commission to the IB in the amount and

under the conditions stipulated in this Agreement.

5.2. The Company shall be responsible for the execution of Client orders and calculations of

the Referral Commission due to the IB. Should the IB wish to check the calculations, the IB

may request statements from their Referrals, on the basis of which an appeal may be made

concerning the Company’s calculations. The Company does not provide statements on

Referral transactions.

5.3. The Company has the right to monitor the activities of the IB regarding the functions and

duties of the IB under this Agreement. In the event that the IB is found to be in contravention

of any such functions and/or duties, the Company shall be entitled to send the IB email

warnings regarding the contravening conduct. This is without prejudice to any other rights the

Company may have against the IB under this Agreement.

5.4. The Company has the right to request and receive information from the IB on the latter’s

fulfilment of the provisions contained in this Agreement.

6. Limitation of the IB’s Authority

6.1. The IB is not entitled to do the following without prior written consent of the Company:

Assume any responsibility on behalf of the Company or place the Company under any

obligations;

Publish any material (articles, letters) or assist in the writing of material (articles,

letters) concerning the Company in any newspapers, magazines, or other periodicals

or on internet resources (such as blogs, social networking websites, forums, etc.)

which may damage the positive image of the Company; or

Give any guarantees and/or make any promises, make any claims in relation to any

payments under any contracts and/or agreements concluded by the Company.

6.2. The IB entering into relations with the Company is obligated to inform interested parties

and referrals of its IB status and authority. Since the IB is an intermediary, it is the Company

that carries out all actions and measures necessary to conclude the Client Agreement with the

Client through the Company Website.

6.3. The IB is not entitled, in its own name and/or on behalf of a Referral, to register a

Referral with the Company and/or accept the Client Agreement on behalf of the Client using

the IB’s personal login username and password. The IB is obligated to inform the Referral of

the need to protect the security and confidentiality of a Client’s account and login information

(login username and password) to the Company’s Website. The Client shall be responsible

for ensuring that such information is not given out to third parties.

6.4. During the period of validity of the Client Account, all actions performed using the

Client Account shall be considered to be carried out personally by the Existing Client. The

Company shall not be held responsible for the unauthorized use of the Client Account

information by third parties.

6.5. Under no circumstances does the IB have the right to:

Receive payments from, or make payments to Clients and/or Referrals. All financial

dealings with Clients and/or Referrals will be performed by the Company; or

Directly or indirectly give Clients and/or Referrals any amount of the IB’s Referral

Commission; or

Serve as an IB on behalf of any third parties.

6.6. Should the IB breach the Terms and Conditions of this Agreement, the Company

reserves the right to close the IB’s Client Account and exclude logins by the Referral(s) until

the IB has rectified such breach, provided that the breach is capable of remedy.

6.7. The IB itself cannot act as a Referral of an IB. Should any data of the IB coincide with

data associated with any Referred Client (such as email, IP addresses, etc.), the Referral shall

be removed from the IB’s Referred list and the Referral Commission based on this Referral

will not be paid.

Compensation of the IB

7.1 All affiliate commissions upon request for all affiliates generating cumulative

commissions reaching equivalent to USD10 (ten) or more. Should the commissions

accumulate to less than the $10 (ten) threshold, commissions will remain unpaid until the $10

(ten) threshold is met.

7.2 Our 4-tier commission structure works so that:

Tier 1 Affiliate receives 25% of the commission

Tier 2 Affiliate receives 15% of the commission

Tier 3 Affiliate receives 10% of the commission

Tier 4 Affiliate receives 10% of the commission

When a Trader signs up using an affiliate’s unique Referral link, he/she /they will receive

equivalent $2 (two) per traded lot PLUS equivalent $0.5 (fifty cents) per traded lot for their

referrals’ users. In case when the referral/s will not refer, the affiliate will earn the full default

commission amount in the amount of equivalent to $3 (three).

7.3 Commissions generated from those residing in restricted countries are void.

7.4 Affiliates are prohibited from creating an alternative account via their affiliate link and

any commission generated from trades made under their personal trading account will be

void.

7.5 Only one IB account per IB may be created.

8. Representations and Warranties

8.1. The IB hereby represents and warrants that from the Effective Date:

If it is a company, it is duly incorporated and validly exists under the laws of the

jurisdiction in which it was incorporated. It has the requisite corporate power and

authority to execute, deliver and perform the provisions of this Agreement and the

transactions contemplated hereby;

If it is a company, it has taken, fulfilled, and done all necessary actions, conditions,

and things, including all necessary corporate actions, (i) to lawfully enter into,

exercise its rights, carry out and comply with its obligations pursuant to the provisions

of this Agreement and the transactions contemplated hereby; and (ii) to ensure that

those obligations are legally binding and enforceable.

Its entry into, exercise of its rights and/or performance of or compliance with its

obligations under this Agreement and the transactions contemplated hereby do not

and will not violate, conflict, or exceed any power or restriction granted or imposed

by (i) any law, regulation, authorization, directive or order (whether or not having the

force of law) to which it is subject, (ii) its constitutive documents or (iii) any

agreement to which it is a party or which is binding on it and its assets; and

That it will use its best endeavours to introduce Referrals to the Company and the

Company Services through the Referral Link as may be necessary and ensure that the

objective of the Agreement is met.

9. Contract Term

9.1. This Agreement shall enter into force from the Effective Date and shall remain valid as

long as:

The IB has a valid Client Account with the Company and has observed all the rights

and obligations under the Client Agreement; and

This Agreement has not been terminated pursuant to Clauses 11.1 or 11.2.

9.2. In the event that the IB ceases to have a Client Account with the Company for whatever

reason, this Agreement shall be terminated immediately. If the IB ceases to have a Client

Account with the Company:

Due to a breach by the IB of the Client Agreement, any Referral Commission due to

the IB shall be up to the date of the occurrence of the breach; or

Not due to a breach by the IB of the Client Agreement, any Referral Commission due

to the IB shall be up to the date of the written notice of termination of the Client

Agreement by either Party.

10. Force Majeure

10.1. Neither Party hereof shall be held liable for the complete or partial failure to fulfil its

obligations should this failure result from a force majeure event or circumstance (including

but not limited to fire, earthquake, and other natural disasters, war, or other military

operations, blockades, government regulations and other extraordinary and unavoidable

circumstances beyond either Party’s control).

10.2. The Party for whom it becomes impossible to fulfil its obligations is obligated to inform

the other Party through written notification of the onset, estimated duration, and cessation of

the above-mentioned circumstances within five (5) business days from the moment of their

onset and cessation.

10.3. The facts set out in the notification should be confirmed by a competent authority or

organization of the respective country. The delay or absence of notification by the Party

concerned deprives said party of the right to cite any of the above-mentioned circumstances

as grounds for release from responsibility for the failure to fulfil its obligations.

10.4. Should the inability to either completely or partially fulfil obligations last more than

three (3) months, the Agreement will automatically be terminated.

11. Termination

11.1. In the event that the IB breaches any clauses in this Agreement, and this breach is not

rectified within fourteen (14) days from the date of the breach, this may amount to a material

breach of this Agreement, which shall lead to the immediate termination of this Agreement

and the cancellation of any Referral Commission due to the IB from the date the breach

occurred.

11.2. This Agreement may be terminated at any time as follows:

by either Party forthwith upon written notice to the other Party in the event, the other

Party should become insolvent or make an assignment for the benefit of its creditors

or file for or be placed in judicial management, receivership, bankruptcy, liquidation,

or winding uptake any other action which would indicate insolvency on its part; or

by either Party at any time without cause upon thirty (30) days prior written notice to

each other.

For the avoidance of doubt, if termination of this Agreement is effected pursuant to Clauses

10, 11.2.1, and 11.2.2, the cancellation of any Referral Commission due to the IB shall be

from the date of the written notice served by the relevant Party.

11.3. On termination of this Agreement, the IB shall:

immediately cease the use and/or dissemination of the Referral Link to any Clients;

immediately cease the use of the Company Marks;

immediately cease the use of any advertising material provided by the Company; and

immediately cease providing information to Clients about the Company and/or the

Company Services.

11.4. The termination of this Agreement is without prejudice to any clause which by

operation of law survives or is specifically stated to survive the termination of this

Agreement. For the avoidance of doubt, Clauses 9 (Contract Term), 11 (Termination), 12

(Indemnification and Limitation of Liability), 13 (Confidentiality), and 15 (Governing Law

and Jurisdiction) shall survive the termination of this Agreement.

12. Indemnification and Limitation of Liability

12.1. The IB shall defend, indemnify and hold harmless the Company, and its respective

affiliates, directors, officers, employees, agents, and representatives from and against all

claims, demands, losses, damages, and costs and expenses (including legal costs and

expenses) or liabilities of whatever nature or kind of the Company or third parties arising out

of or in connection with a breach by the IB of any of its obligations or warranties under this

Agreement.

12.2. Under no circumstances shall the Company be liable to the IB for indirect, incidental,

consequential, special, or exemplary damages (even if such party has been advised of the

possibility of such damages), arising from any aspect of the relationship provided herein.

13. Confidentiality

13.1. Each Party undertakes that it shall not at any time disclose to any person any

Confidential Information which is disclosed by the other Party as part of this Agreement

except where necessary to its employees, officers, representatives or advisors for the purposes

of carrying out their respective obligations under this Agreement.

13.2. No Party shall use the other Party’s confidential information for any purpose other than

for the purposes set out in this Agreement.

13.3. The confidentiality obligations contained in this clause shall be for the duration of this

Agreement, and shall continue for a period of three (3) years from the date of termination of

this Agreement.

14. Miscellaneous

14.1. The granting by any party of any time or indulgence in respect of any breach of any

provision of this Agreement by the other shall not be deemed a waiver of such breach and the

waiver by any party of any breach of any provision of this Agreement by the other shall not

prevent the subsequent enforcement of that provision and shall not be deemed as a waiver of

any subsequent breach.

14.2. Save as expressly provided herein, this Agreement shall operate to the entire exclusion

of any other agreement or understanding of any kind pertaining to the subject matter of this

Agreement between the parties preceding the Effective Date.

14.3. All rights, remedies, and powers conferred upon the parties pursuant to this Agreement

are in addition to such other rights, remedies, or powers now or subsequently conferred upon

them by law or otherwise.

14.4. Neither Party shall assign this Agreement or any rights under this Agreement without

the prior written consent of the other Party, which shall not be unreasonably withheld. This

Agreement shall be for the benefit of and be binding on the Parties and their successors in

title or permitted assigns.

14.5. Should any term of this Agreement be considered void or voidable under any applicable

law, then such terms shall be severed or amended in such a manner as to render the remainder

of this Agreement valid or enforceable unless the whole commercial object is thereby

frustrated.

14.6. Where this Agreement is issued in a language other than English, the English language

version shall take precedence in the event of any conflict.

14.7. The IB agrees to allow the Company to use the IB’s contact information, for example,

address, email, and other information specified in the Client registration form to send the IB

letters and proposals.

14.8. In the interest of complete clarity, the IB shall always and under all circumstances,

without exception, act solely on its own behalf, and not in the name of the Company.

15. Governing law

15.1. This Agreement is governed by the law of the Saint Vincent and the Grenadines and

will be subject to the exclusive jurisdiction of the Saint Vincent and the Grenadines Courts.

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This is a legal contract between Liquid Markets Pty Ltd, (hereinafter referred to as “Company”) its successors and assigns, and the party (or parties) executing this document.

The PAMM account Terms, jointly with the Terms & Condition and Risk Disclaimer include all the provisions and conditions provided to the Client by the Company for the use of PAMM accounts. Reading and understanding all of the above documents is a mandatory requirement in order to access the PAMM service. By registering as a Manager or an Investor, the Client acknowledges and confirms that he has read and understood all documents in relation to the PAMM service.

The PAMM Account service is intended to connect Investors’ Investment Accounts to the account of the Manager (hereinafter, “Manager”) for purposes of further transactions of the Manager on the financial markets in the interests of the Investors. The PAMM Account unites Investors’ Investment Accounts into a single trading account.

The Manager is an agent of the Investor in relation to the Investment Account.

All transactions performed by the Manager on the PAMM Accounts are subject to this Terms and Conditions, Risk Disclosure and General Terms and conditions.

The Liquid Markets Pty Ltd PAMM Account service is not an asset management tool for Investors. This service provides the opportunity to follow the trading strategies of the Manager, who may manage his/her own personal capital through a specific PAMM Account, and/or with the Investor's own capital. The investor, voluntarily, at their own risk, selects the Manager. All decisions of acceptance or rejection of the Manager’s offered terms are a personal matter of each potential investor and are received without any recommendation or solicitation by the Company.

The Company has no right to disclose any personal information about the Managers. Manager PAMM Account is a personal account of the Company's Client and therefore its owner's details cannot be disclosed to third parties. Based on this, any claims and/or requests that may be brought against the Company on behalf of investors against Managers will be rejected.

An Investor accepting the Manager terms confirms that he/she understands and accepts the nature of inherent risks and implications of Trading in financial markets.

The Company therefore states to the investor that it does not and will not guarantee the recurrence of rates of return that have been made by the Manager in the past.

All trading on the PAMM Accounts can only be performed by the Manager on the basis of such terms. The Company will reject all claims of the Investor(s) that the Manager failed to comply with their recommendations.

All transfers of funds between the Investor’s personal accounts and PAMM trading accounts are carried out only on the basis of requests from Investors. The Manager cannot influence the decision making for the inflow or outflow of Investor funds.

The Investor has no right to bring a claim against the Company's trading operations conducted in the PAMM Account. Only the Manager, according to procedures set by the Company, may submit a claim to Company.

The Company reserves the right to terminate the provision of the PAMM service to any manager at any time upon its sole discretion. The company may reject any request of Managers or Investors to provide the motives or reasons for such a decision. Such a decision, in relation to any Manager, cannot be used by Clients as a fact which can harm the Company’s, its employee’s or owner’s reputation.

PAMM Accounts

PAMM accounts are designed to allow the application of strategies as set by the Manager, who manages capital in trading in the Forex and Financial markets, in relation to the Investor's capital. The Manager performs trades on PAMM Accounts, which may consist of his funds as a Manager and the Investor's capital. 

The Manager has the right to:

Carry out trading transactions on PAMM Accounts on the instruments offered by the Company.

Establish the Manager terms.

The Manager has no right or shall not be allowed to request the deposit or withdrawal of funds to or from the Investor’s Accounts.

All PAMM Account calculations, deposit and withdrawal of funds, crediting and debiting of success fees and penalties if applicable are performed by the Company.

Manager Account

A Client by creating the PAMM Manager Account unconditionally accepts the terms and conditions set thereof. The Manager will receive an email with the login details after successful registration.

Unless otherwise specified by the Manager, the newly added PAMM Account may be added to Public PAMM Account Rankings on the official website of the Company.

The Company allows the Manager to use the PAMM services without publication of a Manager Offer in the public PAMM Account Rankings.

The Company reserves the right to limit the number of Manager Accounts and/or remove, suspend or terminate any account upon its sole discretion.

The Company reserves the right to take any precautionary measures as deemed necessary in order to protect the best interests of the PAMM service without prior notice to the Client. In particular, the Company has the right to proceed with the following actions, the list is not exhaustive:

Modify the PAMM Manager Account leverage;

Modify the PAMM Manager Account Stop Out Level;

Modify the PAMM Strategy Settings;

Request a PAMM Manager Account to cease operations.

Manager’s Proposal

Manager’s Proposal is a proposal to use strategies, used by Managers to perform trading transactions on behalf of any Client of the Company. Each proposal consists of a set of parameters used by the Company for the calculation of the remuneration of the Manager, as well as a set of conditions for the formation and operation of Managed accounts. Acceptance or rejection of any term of Proposal regarding the investment in any PAMM account is an entirely voluntary decision of the Client.

The Manager cannot influence the process of funds withdrawal from the Investor's account, which is carried out by the Company upon the request of the Investor.

Investor Account

Registration of any Client as an Investor is performed by the Company at the time of his/her acceptance of the Manager’s Offer. By accepting the Manager's offer the Client confirms that he or she:

Read and understood all of the provisions of these Terms.

Has all the power and authority to abide by these Terms and understands the significance of his/her own actions.

Ensures that the management of the Investor funds cannot entail any violation of the rights of the Investor or any third party.

Manager's Proposal is considered as accepted when an Investor submits a request to deposit funds to the specific Manager Account. An Investor cannot cancel a request to deposit funds once it has been submitted. In case an Investor wants to cancel his investment underfunded Manager account, the withdrawal of all the funds deposited will need to be submitted and an Investor will be required to cover any Penalty Fees applicable.

Client is permitted to register one Investor Account. The Company reserves the right to limit the number of Manager Accounts and/or remove, suspend or terminate any account upon its sole discretion.

Investor Account Participation

The Investor Account Participation is used to determine which part of the achieved profit and loss in the PAMM Manager account will be distributed to each Investor Account.

Calculation of the Investor Account Participation is produced during each PAMM Manager Account Balance Operation and is proportional to the invested funds.

Rollover

Rollover is a recurrent procedure for PAMM Accounts. The duration of rollover is depending on the amount and composition of the PAMM Accounts.

Each rollover includes:

Opening of New Investments;

Processing of Pending Investment Deposits;

Processing of Pending Investment Withdrawals;

Processing of Profit Share if applicable;

Deposits

Deposits into PAMM Manager Accounts are processed during next rollover after Manager’s approval.

Pending deposits cannot be cancelled.

Withdrawals

Withdrawals on PAMM Manager Accounts are processed during next rollover after Manager’s approval.

Calculation of the positions obtained profit and loss and the payment for overnight positions carrying is calculated for each managed account based on the Investor Account Participation proportionally.

PAMM and Managed Account’s Calculations

The Company calculates the Investor’s balance according to the following formula:

a. Investors’ Balance = Deposit - Withdrawals + realized Profit/Loss – Profit share,

b. Deposit = Amount deposited

c. Withdrawals = Amount withdrawn,

c. Profit/Loss = the value of the realized Profit/Loss, including commission and swap fees, achieved with the PAMM account during the preceding and following rollover interval.

Manager’s Obligations

The Manager taking into account all of the risks of trading engages in activities aimed at increasing the Managers Capital and Investor Funds.

The Manager Confirms that:

He/She self regulates every requirement of Foreign Exchange, tax and other legal implications in the jurisdiction a resident of which he/she is.

All the personal data and Client identifications documents that were provided to the Company during the Client and the PAMM account registration is accurate.

All documents that regulate trading and non-trading operations as well as these terms were carefully read and understood.

All of the risks and implication of trading on the financial markets are defined and understood.

The Manager agrees that he/she would be obliged to autonomously settle all possible claims or complaints against him/her by Investors or from the governing authorities, and under no circumstances would the Company or any of its owners or any of its representatives be involved in such a legal matter.

The Manager shall continuously monitor and manage the PAMM account.

The Manager agrees to keep access passwords to the trading platform secure and confidential, and do not have the right to disclose these passwords to third parties. All actions related to the fulfillment of these Terms and Conditions and/or usage of login and password are considered executed by the holder of said information. The Company does not bear responsibility for the unauthorized use of registration data by third parties.

Manager agrees that he has no right to:

Affiliate himself with the Company publicly or otherwise, in contracts and agreements either verbally or in writing.

Use the Company trademark or its logo in any documents or offer.

Make statements, calculations or obligations on behalf of the Company on any public means of communications (such as forums, journal articles etc).

Manager agrees that if the results of his activities the Company will be presented with any claims or demands, he is obliged to settle all financial claims at his own expense (including all balances in his trading accounts with the Company).

Investor’s Obligations

Investor confirms that:

He/she self regulates every, but not limited to, requirement of Foreign Exchange, tax and civil law of the jurisdiction a resident of where he/she is residing.

All the personal data and Client identifications documents that were provided to the Company during the Client and the PAMM account registration is accurate.

The Company has a right to share with the PAMM Manager PAMM Investor’s full name for identification purposes. All other confidential information will be shared based on PAMM Investor’s request.

All documents that regulate trading and non-trading operations as well as these terms, were carefully read and understood.

All of the risks and implications of Trading in the Financial Markets are defined and understood.

Investor agrees that all claims and complaints by third parties that may arise as a result of his/her activities will be resolved independently by him/her and at own expense.

Investor acknowledges that the Manager may be compensated by the Company based on traded volume as well as based on the management fee and/or performance fee.

Effective Duration and Amendments

These Terms and Conditions come into force for Company Clients the moment they are accepted in Liquid Markets Pty Ltd and cease to be in effect the moment the Client account is terminated.

The Client acknowledges that the Company has a right to introduce amendments to the provisions of these Terms and Conditions at any time.

Risks

The Manager and Investor accept responsibility for possible financial losses such as direct losses that may exceed the investment(s) total amount or lost profit resulting from the following risks:

the risk that the Manager does not possess the necessary qualification or knowledge required to manage Investors’ funds;

the risk that the Manager may not observe Investors’ interests or may carry out fraudulent operations in relation to Investors’ funds;

the risk that the Manager may lose control over the PAMM Account;

the risk that third parties may gain access to management of the PAMM Account;

the risk that complaints may be submitted by the Manager to the Company in an untimely fashion concerning the completion of operations on the Investor’s Investment Account;

the risk of unforeseen delays in transfers between accounts or the untimely execution of deposit/withdrawal requests or the closing/liquidation of a PAMM Account; the risk of a PAMM Account’s liquidation.

The PAMM Account Manager and their Investors are financially liable for any losses incurred on a PAMM Account. Their liability is proportionate to their share in the PAMM Account. Under no circumstances does the Company bear responsibility for the consequences of such risks.

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1- Introduction

a. As a company, we are committed to carrying on business in accordance with the highest ethical standards. This includes complying with all applicable laws and regulations aimed at combating money laundering and terrorist financing. This Policy has been developed by Liquid Markets to reduce the risk of money laundering and terrorist financing associated with its business and the sale of its products. This Policy explains our individual responsibility in complying with anti-money laundering and counter- terrorist financing laws ("AML Laws") around the world and ensuring that any third parties that we engage to act on our behalf, do the same.

b. The management of Liquid Markets is committed to complying with all laws. Any employee who violates the rules in this Policy or who permits anyone to violate those rules may be subject to appropriate disciplinary action, up to and including dismissal, and may be subject to personal civil or criminal fines.

c. If you have any questions about this Policy you should contact the Ethics and Compliance or the Legal Department.

2- Policy Statement on AML

a. It is Liquid Markets’s policy to comply with all applicable AML Laws in our operations worldwide. To this end, Liquid Markets will only conduct business with customers who are involved in legitimate business activity and whose funds are derived from legitimate sources.

b. This Policy is intended to help employees, contractors, and other third parties acting on the company’s behalf to understand where breaches of AML Laws might arise and to support them in making the right decisions in line with our corporate position as stated in this Policy.

3- Board Endorsement

a. The Board of Liquid Markets will not criticize management for any loss of business resulting from adherence to this Policy. No employee or contractor will suffer as a consequence of bringing to the attention of the Board or senior management, in good faith, a known or suspected breach of this Policy nor will any employee or contractors suffer any adverse employment or contract decision for abiding by this Policy.

4- Who is subject to this Policy?

a. This Policy applies to Liquid Markets operations globally, including all legal entities worldwide owned or controlled by Liquid Markets (including all group companies), and to all directors, officers, employees, contractors, and other third parties acting on behalf of the foregoing.

5- What's the risk?

a. Violations of AML Laws may lead to severe civil and/or criminal penalties against companies and individuals, including significant monetary fines, imprisonment, extradition, blacklisting, revocation of licenses, and disqualification of directors.

b. In addition, violations of AML Laws can lead to damaging practical consequences, including harm to reputation and commercial relationships, restrictions in the way we can do business, and extensive time and cost in conducting internal investigations and/or defending against government investigations and enforcement actions.

6- What do we mean by Money Laundering and Terrorist Financing?

a. Money laundering means exchanging money or assets that were obtained criminally for money or other assets that are ‘clean’. The clean money or assets don’t have an obvious link with any criminal activity. Money laundering also includes money that’s used to fund terrorism; however it’s obtained.

b. The following types of activities are considered to be “money laundering” and are prohibited under this Policy:

i. the conversion or transfer of property (including money), knowing or suspecting that such property is derived from criminal or certain specified unlawful activity ("criminal property"), for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;

ii. conducting a financial transaction which involves criminal property;

iii. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, ownership or control of criminal property;

iv. the acquisition, possession or use of criminal property;

v. promoting the carrying on of unlawful activity; and

vi. participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions mentioned in the foregoing points.

c. The broad definition of money laundering means that anybody (including any Liquid Markets employee) could be in violation of the law if he/she becomes aware of, or suspects, the existence of criminal property within the business and becomes involved in or continues to be involved in a matter which relates to that property being linked to the business without reporting his/her concerns.

d. Property can be criminal property where it derives from any criminal conduct, whether the underlying criminal conduct has taken place in the country where you are situated or overseas.

e. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

7- Red Flags

a. Where any suspicions arise that criminal conduct may have taken place involving a customer, colleague or third party, you should consider whether there is a risk that money laundering or terrorist financing has occurred or may occur.

b. Some examples of red flags to be reported include:

i. A customer provides insufficient, false or suspicious information or is reluctant to provide complete information

ii. Methods or volumes of payment that are not consistent with the payment policy or that are not customarily used in the course of business, e.g., payments with money orders, traveler’s checks, and/or multiple instruments, and payments from unrelated third parties

iii. Receipts of multiple negotiable instruments to pay a single invoice

iv. Requests by a customer or partner to pay in cash

v. Early repayments of a loan, especially if payment is from an unrelated third party or involves another unacceptable form of payment

vi. Orders or purchases that are inconsistent with the customer’s trade or business

vii. Payments to or from third parties that have no apparent or logical connection with the customer or transaction

viii. Payment to or from countries considered high risk for money laundering or terrorist financing

ix. Payments to or from countries considered to be tax havens or offshore jurisdictions

x. Payments from countries unrelated to the transaction or not logical for the customer

xi. A customer’s business formation documents are from a tax haven, or a country that poses a high risk for money laundering, terrorism or terrorist financing, or a country that is not logical for the customer

xii. Overpayments followed by directions to refund a payment, especially if requested to send the payment to a third party

xiii. Any customer for whom you cannot determine the true beneficial owner

xiv. Structuring transactions to avoid government reporting or record keeping requirements

xv. Unusually complex business structures, payment patterns that reflect no real business purpose

xvi. Wire transfer activity that is not consistent with the business activities of the customer, or which originates or terminates with parties unrelated to the transaction

xvii. Unexpected spikes in a customer’s activities

The above is not intended to be an exhaustive list. Deviation from customer and accepted business practice should alert you to further investigate the activity in accordance with this Policy.

8- Compliance controls

a. Senior management in each Liquid Markets business are responsible for ensuring that their business has a culture of compliance and effective controls to comply with AML laws and regulations to prevent, detect and respond to money laundering and counter-terrorism financing and to communicate the serious consequences of non-compliance to employees.

9- Employee Responsibility

a. You have the obligation to read and follow this Policy, to understand and identify any red flags that may arise in their business activities and to escalate potential compliance concerns related to AML to Ethics and Compliance or the Legal Department without notifying anyone involved in the transaction and should not take any actions prior to receiving advice and/or instructions.

10- Due Diligence and Record Keeping

a. It is our policy to carry out due diligence ("DD") at the outset of any business relationship and, if necessary, where any red flags arise subsequently on our suppliers, distributors, counterparties, agents and any person with whom Liquid Markets has an established business relationship that will involve the transfer to or receipt of funds ("Customers"), so we can be satisfied that they are who they say they are and so that we can ensure that there are no legal barriers to working with them before contracts are signed or transactions occur. Various factors will determine the appropriate forms and levels of screening.

b. You should escalate any instances where you have cause for suspicion as a result of carrying out DD and ongoing monitoring to Ethics and Compliance or the Legal Department, who will advise them regarding which tools and processes should be used to facilitate appropriate screening.

c. You must, in consultation with the Ethics and Compliance or the Legal Department, carefully consider screening outcomes before deciding whether to do business with the third party.

d. Finance managers must regularly monitor and/or review Customers to identify business activity or governance that could indicate money laundering or terrorist financing is taking place.

e. Record-keeping is an essential component of the audit trail required to assist in any investigation. You must maintain records as evidence of the DD and ongoing monitoring undertaken.

11- Non-compliance

a. Any Liquid Markets employee or contractor, who violates this Policy may be subject to appropriate disciplinary action, independently from potential other penalties resulting from their behaviour.

b. Internal Audit shall conduct regular checks on local businesses to ensure compliance with AML Laws.

12- Updates, Review and Ownership

a. Any Liquid Markets employee or contractor, who violates this Policy may be subject to appropriate disciplinary action, independently from potential other penalties resulting from their behaviour.

b. Internal Audit shall conduct regular checks on local businesses to ensure compliance with AML Laws.

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Information Collected by Liquid Markets Pty Ltd. The following categories of nonpublic personal information will be collected by Liquid Markets Pty Ltd:

Liquid Markets Pty Ltd Cookies and Privacy

The following categories of nonpublic personal information will be collected by Liquid Markets Pty Ltd:

Name, address, assets, bank account information, prior trading experience, etc., provided by the Customer when opening an account or processing a transaction.

Information used to verify the Customer’s identity, such as copies of government-issued identification documents like passports, driver’s licenses, and credit reports.

Withdrawal and deposit forms are examples of information resulting from transactions between the Customer and Liquid Markets Pty Ltd or an affiliate of Liquid Markets Pty Ltd

Information derived from the Customer’s navigation and use of the website and online platforms of Liquid Markets Pty Ltd, including account trading statements.

Information disclosed by Liquid Markets Pty Ltd and the recipients to whom it is disclosed.

Except where required by law, Liquid Markets Pty Ltd does not disclose nonpublic personal information about our customers or former customers to any third party. As permitted by law, Liquid Markets Pty Ltd may share your information with unaffiliated third parties in order to provide you with financial services. This includes a consumer reporting agency responsible for compiling your credit report.

In addition, as permitted by law, Liquid Markets Pty Ltd may provide information to government or regulatory agencies and comply with a legal summons, court order, subpoena, or similar legal process, audit, or investigation. We may also disclose your nonpublic personal information with your permission.

Security and Confidentiality Procedures

Utilizing your private information:

1.1 In addition to verifying your identity, we may use the personal information we collect for: Considering your applications. Conducting risk assessments. Performing our contractual obligations to you, if any. Managing our relationship with you, including addressing any questions or concerns. Creating and administering your account. Reviewing your ongoing needs. We will provide you with the requested information, goods, and services. The investigation of any complaints made by you. Providing evidence in the event of a dispute or anticipated dispute between us and you. Improving our products and services for customers. Conducting product analysis and development. Detecting or preventing fraud and other criminal activity.

1.2 If you have agreed to receive updates from us, we may contact you via mail, email, phone, SMS, or other electronic messaging services.

1.3 Only those personnel who require the information to complete a specific transaction shall be permitted access to the information. To maintain the confidentiality of its customers’ information, Liquid Markets Pty Ltd, its employees, and its affiliates must strictly adhere to security practices and procedures. Liquid Markets Pty Ltd maintains multiple safeguards in accordance with regulations to protect your private information.

1.4 Liquid Markets Pty Ltd will continue to safeguard the non-public personal information of former customers in the same manner as when they were customers. Former customers will not receive annual privacy notices, unlike continuing customers.

1.5 Liquid Markets Pty Ltd will provide an annual notice of our privacy policy for as long as the customer maintains a Liquid Markets Pty Ltd Account. Liquid Markets Pty Ltd reserves the right to modify these terms. This policy is always accessible at https://www.liquidfx.com.

CONSENTS AND ADDITIONAL CONTRACTS

Accept electronic delivery of confirmations and account statements.

The Customer hereby consents to having the Customer’s account information and trade confirmations accessible via the Internet, as opposed to receiving such information via mail or email, as specified in the Customer Agreement’s “Statements and Confirmations” and “Communications” sections. Permission to Transfer Funds

The Customer agrees that Liquid Markets Pty Ltd may, at any time and from time to time, in its sole discretion, apply and transfer from any of the Customer’s accounts with Liquid Markets Pty Ltd to any of the Customer’s other accounts, whether held at Liquid Markets Pty Ltd or other approved financial institutions, any contracts, currencies, securities, or other property of the Customer held individually or jointly with others to another account.

Agreement To Use Security. The Customer grants Liquid Markets Pty Ltd permission to sell, pledge, rehypothecate, assign, invest, commingle, and otherwise use any Collateral held by Liquid Markets Pty Ltd, including, but not limited to, using the Contracts as collateral for a loan to Liquid Markets Pty Ltd and further trading with the Collateral, as provided in the Customer Agreement (including, but not limited to Paragraph 6 thereof).

This authorization applies to all of the Customer’s accounts with Liquid Markets Pty Ltd in the event that the Customer’s account includes more than one Account.

This agreement to Use Collateral shall remain in effect for as long as the Customer’s account with Liquid Markets Pty Ltd remains open or as long as the Customer has any obligations to Liquid Markets Pty Ltd, pursuant to the Customer Agreement. Social Security / Tax ID Identification Documentation.

The Customer certifies, under penalty of perjury, that (1) the number provided on the Customer Application is the Customer’s correct Social Security or Taxpayer Identification Number and (2) the ownership or beneficiary of the Customer’s account is not subject to backup withholding under Internal Revenue Code section 3406(a)(1)(C).

ARBITRATION AGREEMENT.

Any dispute, claim, or controversy arising out of or relating to the Customer Agreement, the Customer’s account with Liquid Markets Pty Ltd, or any other trading between the Customer and Liquid Markets Pty Ltd shall be resolved by binding arbitration. American Arbitration Association (“AAA”), within the United States of America (“USA”), in accordance with the AAA arbitration rules in effect at the time the arbitration is initiated, or another appropriate arbitration forum within the United States, may serve as the forum for the arbitration.

If the arbitration forum is located outside of the United States, any dispute between the Customer and Liquid Markets Pty Ltd shall be resolved by the AAA’s international division, the International Centre for Dispute Resolution (“ICDR”), in accordance with the International Arbitration Rules in effect at the time the arbitration is initiated.

The arbitrator’s decision shall be final and binding, and it may be entered in any court with jurisdiction. The arbitration shall be conducted unless the forum is not reasonably convenient for the Customer, in which case the arbitrator shall select an alternative forum. Customer and Liquid Markets Pty Ltd agree to take all necessary steps and execute all necessary documents to implement arbitration proceedings.

All applicable statutes of limitation apply to any arbitration between the Customer and Liquid Markets Pty Ltd The provisions of this Arbitration Agreement shall survive termination, modification, or expiration of the Customer’s account relationship or the applicable Liquid Markets Pty Ltd Customer Agreement or any other relationship between Customer and Liquid Markets Pty Ltd Customer or Liquid Markets Pty Ltd may submit the dispute to binding arbitration at any reasonable time, regardless of whether a lawsuit or other proceeding has been initiated.

Neither the Customer nor Liquid Markets Pty Ltd shall have the right to join or consolidate disputes by or against others in any arbitration, to include in any arbitration any dispute as a representative or class member, or to act in any arbitration in the public interest or as a private attorney general.

Neither a party nor an arbitrator may disclose the existence, content, or outcome of any arbitration conducted pursuant to this agreement without the prior written consent of both parties, unless required by law.

TRADING RULES AND PROCEDURES

The following Trading Rules and Regulations will outline Liquid Markets Pty Ltd’s trading and account opening procedures and policies. All customers must read, comprehend, and comply with these rules and regulations. Liquid Markets Pty Ltd reserves the right to modify any rules or regulations at any time and at its sole discretion.

Business Hours:

The normal trading week for Liquid Markets Pty Ltd begins on Sunday at 19:00 (7:00 PM EST) and concludes on Friday at 16:00 (2:00 PM EST) (time is subject to change.)

Liquid Markets Pty Ltd will, to the best of its ability, publish and display a holiday schedule on its website when trading will be suspended.

In the event of a holiday, Liquid Markets Pty Ltd will make reasonable efforts to announce the resumption of trading in advance and post the information on its website.

Liquid Markets Pty Ltd reserves the right, at its sole discretion, to conduct technical maintenance periods during which electronic trading may be unavailable.

Account and Deposit Information:

Liquidation level: Liquid Markets Pty Ltd reserves the right to automatically liquidate the position, and the Customer will be liable for any resulting losses. Liquid Markets Pty Ltd reserves the right, at its sole discretion, to modify the Liquidation Level.

The prices offered by Liquid Markets Pty Ltd are unrelated to those found elsewhere. Customers acknowledge that the prices reported by Liquid Markets Pty Ltd for buying and selling are independent and may differ from prices displayed elsewhere or from other liquidity providers in the interbank due to changes in liquidity from the interbank to Liquid Markets Pty Ltd, an unbalanced position or exposure at Liquid Markets Pty Ltd, or differing expectations regarding price movements. Liquid Markets Pty Ltd anticipates that the prices it offers its customers will be in line with the interbank market in the majority of instances, but does not guarantee or imply that this will always be the case.

Rollover rates for open positions are determined by Liquid Markets Pty Ltd and are independent of Interbank market prices found elsewhere. The Customer acknowledges that, when applicable, all existing open positions that remain open past the end of the business day for Liquid Markets Pty Ltd, defined as 5:00 PM EST/EDT, are automatically rolled over to the next available Spot Settlement Date at a net debit or credit to the Customer(s) Account based on spot interest rates determined solely by Liquid Markets Pty Ltd Rollover debits and credits are also affected by the number of days required to roll the position. For positions that must be rolled from a spot settlement date of Friday to Monday, the debit or credit will reflect a rollover of three business days, or from Friday to Monday. For Monday-to-Tuesday, Tuesday-to-Wednesday, Wednesday-to-Thursday, and Thursday-to-Friday rollovers, the debit or credit is only for one business day. If Liquid Markets Pty Ltd is closed on a holiday, the rollover would take the holiday into account. For instance, if Tuesday is a holiday, Monday rollovers will be for two (2) business days (i.e. from Monday to Wednesday). Due to the fact that rollover debits and credits are determined by the respective short-term spot interest, a large spread can result in a significant debt or credit rollover amount. This spread may result from countries tightening credit conditions to discourage speculators from shorting one trading product versus another, but this is not the only cause. If the original credit or debit amounts are incorrect due to an error or omission, Liquid Markets Pty Ltd reserves the right to make adjustments at its sole discretion.

Sweep rates for balances in currencies other than USD are determined by Liquid Markets Pty Ltd and may be independent of other Interbank market prices. When open positions are closed and the Profit and Loss is realized, profits calculated in a foreign currency are “swept” into dollars. The Customer acknowledges that neither Liquid Markets Pty Ltd nor any of its representatives guarantee the Customer a profit from trading. The Customer further acknowledges that they could sustain the loss of their entire Risk Capital deposited in their Account and that they are financially able to withstand any losses.

Liquid Markets Pty Ltd does not guarantee it will be able to execute stop-loss orders, limit orders, or OCO Orders at the Customer Entered Price. Customer acknowledges and agrees that market, liquidity, or other conditions may prevent Liquid Markets Pty Ltd from executing customer-specific stop-loss orders, limit orders, or OCO orders at the price specified by the Customer. In some instances, orders will be executed at less favorable prices than those entered and desired by the Customer. The Customer acknowledges and agrees that they remain responsible for trades executed at different levels than their orders, and that Liquid Markets Pty Ltd is not liable for failure to do so.

Technology risk is inherent to trading online or through a software application. Although Liquid Markets Pty Ltd has invested significant resources developing, testing, configuring, and integrating the Trading Platform and other relevant software and hardware, the Customer acknowledges and agrees that Liquid Markets Pty Ltd does not guarantee that the Customer will be able to successfully execute a transaction, monitor their positions, or perform other essential tasks while using the public Internet and other technology from Liquid Markets Pty Ltd or a third party. Liquid Markets Pty Ltd cannot control, including but not limited to, the routing, Internet connectivity, reliability of customer or Liquid Markets Pty Ltd equipment, network connections, or any other technology hardware malfunction caused by Liquid Markets Pty Ltd hardware, hardware, and connectivity that comprise the public Internet, or hardware at the Customers location. Although every effort has been made to the contrary, Liquid Markets Pty Ltd does not guarantee that the Trading Platform and Associated Back Office and Broker Software Interfaces nor any other code or application, including but not limited to the interface with Liquid Markets Pty Ltd liquidity provider(s) or the interface with the escrow Account institution or any other technology application that would fall under the heading software, are error-free and would not result in communications disruptions. Customer acknowledges and agrees that Liquid Markets Pty Ltd provides the Trading Platform and Associated Back Office and Broker Software Interfaces “as is,” without any express or implied warranties of merchantability, fitness for a particular purpose, or other warranties.

Trades Done Utilizing chat programs. Liquid Markets Pty Ltd may utilize an electronic conversational application or other chat-like applications. This application will be utilized by Liquid Markets Pty Ltd to provide customers with an additional means of communicating order information to the Liquid Markets Pty Ltd Trading Desk.

The origin of funds. The Customer certifies that he or she has sufficient funds and risk capital available for immediate transfer to support a margin-based brokerage account with Liquid Markets Pty Ltd for over-the-counter and/or off-exchange trading products. Customer acknowledges the high degree of risk inherent in trading and releases Liquid Markets Pty Ltd from liability. The Customer acknowledges that these funds serve as protection for any of their own customers who may take trading positions resulting in a loss, negative balance, or margin call.

Know Your Customer (KYC) Policy. In order to prevent identity theft, money laundering, financial fraud, and terrorist activity, Know Your Customer (KYC) policies have become increasingly important globally, particularly among banks and other financial institutions. Liquid Markets Pty Ltd has a zero-tolerance policy for fraud and is taking every precaution to prevent it. Any fraudulent activity will be recorded, and all associated accounts will be closed immediately. These accounts will be completely emptied.

One can make deposits via wire transfer. Prior to clearing at the bank and posting to the Customer’s trading account, funds are not available for trading.

All bank fees, such as wire transfer fees, will be debited from the Customer’s trading account as they occur.

When a Customer closes an account with instructions to wire the remaining balance, the wire transfer fee will be deducted from the Customer’s Final Account Balance.

Unless otherwise agreed upon, all deposits must be made in U.S. dollars. Customers from foreign countries have the option of converting their foreign currency into U.S. dollars prior to wiring funds to Liquid Markets Pty Ltd’s clearing bank, or wiring foreign currencies to our clearing bank, at which point our clearing bank will convert the balances into U.S. dollars at the current exchange rate.

The minimum deposit required to open an account with Liquid Markets Pty Ltd is $10.

Liquid Markets Pty Ltd will under NO CIRCUMSTANCES accept payment or deposit into an account from anyone other than the person or entity whose name appears on the Account.

Liquid Markets Pty Ltd will under NO CIRCUMSTANCES make a payment to a person or entity other than the person or entity whose name appears on the Account.

Under NO CIRCUMSTANCES will Liquid Markets Pty Ltd transfer funds from one account to another with different Account Authorization information.

Telephone Orders. The qualified staff at Liquid Markets Pty Ltd can execute telephone trade orders from customers. Telephone execution is designed for situations in which trading via the Trading Platform is unavailable due to technical issues with the Customer’s internet connection or in which the Customer has no other connectivity option. This option can only be implemented if the technical issues are unrelated to a general server issue at Liquid Markets Pty Ltd The following steps should be taken for telephone transactions:

a) The Liquid Markets Pty Ltd representative will request the Customer’s Username and Account Number, verify that they are identical, and confirm the Customer’s identity.

b) Liquid Markets Pty Ltd will request the Customer’s Order after confirmation. (i.e. “What is your Order?”)

c) The Client must specify the desired Order Type, Trade Action, Quantity, Trading Product, and Price (if not a Market Order).

PREVENTION:

Using a variety of security measures and fraud controls, Liquid Markets Pty Ltd seeks to ensure the integrity of any sensitive data it obtains, such as your account information and the transactions you conduct. To protect your electronic transactions, we require certain information from you, including your preferred deposit method.

When making a deposit, we require the following documents:

A copy of your valid passport’s page containing your signature

Copies of the credit cards utilized for the deposit (the Front side with only the 4 last digits visible, backside with the CVV covered).

A recent utility bill that includes your name and address.

Signed record of all of your online purchases.

If you have any questions, please contact our customer service team at support@liquidfx.com.

When must I present these documents?

To avoid any delays in processing your transactions, we would greatly appreciate it if you could provide us with all the required documentation as soon as possible. Prior to conducting any cash transactions for your benefit, we must receive all necessary documentation.

In certain instances, we may be required to request these documents prior to authorizing other account activities, such as deposits or trades.

Please note that your pending withdrawals will be cancelled and refunded to your trading account if we do not receive the required documents. This will be communicated to you via our system.

How do I send these documents to you?

Please scan or photograph your documents with a high-resolution digital camera, save the images as jpegs, and then upload them to your Liquid Markets Pty Ltd portal.

How do I know that my documents are secure?

Liquid Markets Pty Ltd places the utmost importance on document security and treats all documents it receives with the utmost discretion. At every stage of the review procedure, we employ the highest level of encryption to safeguard all files obtained.

We appreciate your assistance in making Liquid Markets Pty Ltd a safer trading environment.

ANTI-MONEY LAUNDERING.

Liquid Markets Pty Ltd does not tolerate money laundering and is dedicated to combating money launderers. Liquid Markets Pty Ltd adheres to the Joint Money Laundering Steering Group’s guidelines. The United Kingdom is a full member of the Financial Action Task Force (FATF), which aims to combat money laundering and terrorism financing. Liquid Markets Pty Ltd has implemented measures to prevent money laundering. These policies consist of:

Ensuring that customers have valid identification.

Maintaining identification information records.

Checking client names against lists of known or suspected terrorists to determine that they are not known or suspected terrorists.

Informing clients that their information may be used for identity verification.

Closely monitoring the financial transactions of clients.

Not accepting cash, money orders, transactions with third parties, transfers from exchange houses, or Western Union transfers.

Money laundering occurs when funds from an illegal or criminal activity are moved through the financial system to make it appear as though they originated from legitimate sources.

Typically, money laundering involves three steps:

Initial placement of cash or cash equivalents into the financial system.

Second, funds are transferred or moved to other accounts (e.g., futures accounts) through a series of financial transactions designed to conceal the source of the funds (e.g. executing trades with little or no financial risk or transferring account balances to other accounts).

The funds are then reintroduced into the economy so that they appear to have originated from legitimate sources (e.g. closing a futures account and transferring the funds to a bank account).

Trading accounts can be utilized to launder illegal funds or conceal the true owner of the funds. In particular, a trading account can be used to conduct financial transactions that help conceal the origins of the funds.

As a precaution, Liquid Markets Pty Ltd redirects funds withdrawals to the original source of remittance. International Anti-Money Laundering requires financial services institutions to be aware of potential money laundering abuses in customer accounts and to implement a compliance program to deter, detect, and report suspicious activity.

These rules have been established to safeguard Liquid Markets Pty Ltd and its customers.

Please contact us at support@liquidfx.com with any questions or feedback regarding these guidelines.

Legal Restrictions. You acknowledge, without limiting the following provisions, that laws regarding financial contracts vary from country to country and that it is your responsibility to comply with any law, regulation, or guideline in your country of residence regarding your use of the Site. For the avoidance of doubt, the ability to access our Site does not imply that our Services and/or your activities on the Site are legal under the laws, regulations, or directives applicable to your country of residence.

If the Customer has not traded within the past six months, they will be charged a $10 inactivity fee or its equivalent in the alternative currency.

Additionally, the Customer confirms that these funds are free of any liens or debts, are clean and non-criminal in origin, and do not originate from the United States or any country on the Office of Foreign Assets Control (OFAC) List. As such, the Customer agrees to comply with any requests made by Liquid Markets Pty Ltd and its representatives for additional documentation.

Liquid Markets Pty Ltd (ABN 79664904027)

1601/2015 Gold Coast Highway Miami, Queensland, 4220, Australia

Corporate Authorised Representative (CAR Number 001302232)

OZ Telephone: +61 2 5604 0625

Email: support@liquidfx.io

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