01 Regulatory Framework
Sun Capital FX operates under anti-money-laundering (AML) and counter-terrorist-financing (CTF) laws applicable in Seychelles (FSA), the UAE (DET), South Africa (FSCA), Pakistan (SECP/FMU), and other jurisdictions where we conduct business. We follow the recommendations of the Financial Action Task Force (FATF).
02 Customer Identification (KYC)
Before opening an account, all clients must provide:
Individual clients
- Full legal name, date of birth, and nationality;
- Residential address and contact details;
- Government-issued photo ID (passport, national ID);
- Proof of address dated within the last 3 months.
Corporate clients
- Certificate of incorporation and memorandum/articles of association;
- Register of directors and shareholders;
- Ultimate Beneficial Owner (UBO) identification — any individual owning 25% or more;
- Board resolution authorising account opening;
- KYC documents for all authorised signatories.
03 Verification Procedures
We verify identity documents using both automated and manual methods. Verification typically completes within 24 hours. In some cases we may request additional documentation or a video call for liveness check.
Accounts cannot be funded or traded until KYC verification is complete. This is a legal requirement, not a commercial choice.
04 Enhanced Due Diligence (EDD)
Higher-risk clients are subject to enhanced due diligence, which may include:
- Source of funds and source of wealth documentation;
- Additional verification of business activities;
- Senior management approval for onboarding;
- More frequent monitoring and periodic reviews.
EDD is applied to politically-exposed persons (PEPs), clients from high-risk jurisdictions, and clients with complex ownership structures.
05 Ongoing Monitoring
We monitor client activity on an ongoing basis, including:
- Transaction patterns and volumes;
- Deposits and withdrawals against expected profiles;
- Trading behaviour indicating market abuse;
- Changes in personal circumstances or documentation.
Monitoring is automated with human review of flagged activity.
06 Suspicious Activity Reporting
When we detect activity that may constitute money laundering or terrorist financing, we are legally obliged to file a Suspicious Activity Report (SAR) with the relevant Financial Intelligence Unit. We may not inform you that a report has been filed.
Attempting to structure transactions to avoid reporting thresholds is itself a criminal offence.
07 Record Keeping
We retain KYC documentation, transaction records, and internal reports for a minimum of five years after the end of the business relationship, as required by AML regulations. Records are stored securely and access is restricted.
08 Politically Exposed Persons (PEPs)
We screen all clients against PEP databases. A PEP is anyone who holds or has held a prominent public function — heads of state, senior politicians, judges, military officials, and their close associates and family members.
PEPs are subject to EDD and require senior management approval before onboarding.
09 Sanctions Screening
All clients are screened against sanctions lists maintained by the UN, EU, OFAC, UK HMT, and other relevant authorities. We re-screen continuously and block or terminate relationships with sanctioned individuals or entities.
10 Employee Training
All Sun Capital FX employees complete annual AML/CTF training. Compliance and client-facing staff receive additional role-specific training. Training records are maintained and audited.