AML, KYC & Sanctions Policy

1.Purpose and scope

We provide paid access to simulated trading evaluations. Customers do not deposit investment capital and customer funds are not traded or managed by the company. Successful participants may become eligible for contractual performance-based rewards based on qualifying simulated trading performance.

Next Scale Funded Trading Technologies Ltd. is not a regulated financial institution and does not hold client money. We nevertheless apply anti-money-laundering controls modelled on the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and on Financial Action Task Force guidance, because we take payments from consumers and make outbound reward payments.

This policy applies to every customer, affiliate and employee, and to every purchase and reward payment made through the platform.

2.Governance

A named senior individual is accountable for financial-crime compliance and for this policy. Decisions to restrict an account, refuse a reward or make a report are theirs to make and are recorded.

The policy is reviewed at least annually and whenever the law, our payment arrangements or our risk profile change materially. Staff receive financial-crime awareness training on joining and annually thereafter.

3.Risk-based approach

We assess risk by customer, geography, product and payment channel. Our inherent risk is limited: customers pay a small fixed fee, no customer capital is deposited, funds cannot be transferred between customers, and rewards are paid only to the verified customer who earned them.

Higher-risk indicators include high-value or repeated reward requests, mismatches between declared residence and access location, use of multiple payment instruments, connections between accounts, and any link to a higher-risk jurisdiction.

4.Customer due diligence

At sign-up we collect and verify an email address and record the country of residence declared at checkout. Every customer must confirm they are at least 18 and acting for themselves.

Before any reward is released we complete identity verification: full legal name, date of birth, residential address, a government-issued photo identity document and a liveness selfie. The name on the verified identity must match the name on the payout destination.

Enhanced due diligence — source-of-activity review, additional documentation and senior sign-off — applies to politically exposed persons, high-value rewards and any case flagged by monitoring.

We do not accept anonymous accounts, accounts in false names, or accounts operated on behalf of an undisclosed third party.

5.Sanctions and restricted jurisdictions

Customers are screened against the UK (OFSI) consolidated list, EU, UN and US OFAC sanctions lists, and against PEP and adverse-media data, at verification and periodically thereafter.

We do not onboard, and we terminate on discovery, any customer who is a designated person or who is resident in a jurisdiction subject to comprehensive sanctions or otherwise listed on our Restricted Countries page. Sign-up, checkout and payout are blocked server-side for those jurisdictions.

A confirmed sanctions match is frozen immediately, not tipped off, and reported to OFSI or the relevant authority.

6.Payments and reward controls

Purchases are accepted only through our regulated payment provider. We do not accept cash, third-party payments, or payment instruments not held in the customer's own name.

Rewards are paid only to a verified destination in the customer's own name, only after the waiting period and thresholds in the Rewards & Payouts Policy, and only after a compliance check of the underlying trading activity. Reward destinations changed shortly before a request trigger additional verification.

We do not act as a money-transmission service. A customer cannot use the platform to move value to another person.

7.Ongoing monitoring

Automated monitoring flags refund-then-repurchase cycles, chargeback patterns, linked or duplicated accounts, coordinated trading between customers, unusual reward frequency and mismatches between declared and observed location.

Flags are queued for human review. A reviewer can request further information, pause a reward, suspend an account or escalate to the compliance lead.

8.Reporting suspicious activity

Any employee who suspects money laundering or terrorist financing must escalate internally the same day and must not discuss it with the customer.

Where suspicion is confirmed, a Suspicious Activity Report is submitted to the National Crime Agency and, where a transaction requires consent, we wait for a defence against money laundering before proceeding. Tipping off is a criminal offence and is prohibited.

9.Record keeping

Verification records, screening results, monitoring alerts, reviewer decisions and reports are retained for 5 years from the end of the customer relationship, and order and payment records for 6 years, in line with the Privacy Policy.

Records are held securely with role-restricted access and are produced to law enforcement or a payment partner on a lawful request.

10.Consequences for customers

We may refuse a purchase, suspend an account, withhold or reverse a reward, and terminate the contract where verification fails, where screening produces a match, or where we have reasonable grounds to suspect financial crime. Where the law prevents us from explaining why, we will say only that we are unable to proceed.

Questions about this policy: complaints@nextscalefunded.com.