AML/KYC policy Market Solutions Ltd.

Policy Statement

Market Solutions Ltd. is committed to fully comply with all applicable laws and regulations regarding anti-money laundering procedures. Market Solutions Ltd. has adopted and will enforce the provisions set forth in AML/CFT Regulations in order to prevent and detect money laundering, terrorist financing and other illegal activities. If Market Solutions Ltd., its personnel and/or premises are inadvertently used for money laundering or other illegal activities, Market Solutions Ltd. can be subject to potentially serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, and employee (each, an “Employee”) is familiar with and complies with the policy and procedures set forth in this document. This Compliance Statement is designed to assist all clients in adhering to Market Solutions Ltd. policy and procedures, which, if followed diligently, are designed to protect themselves, Market Solutions Ltd., its Employees, its facilities and its activities from money laundering or other illegal activities. The Director is responsible for establishing and conducting Employee training programs to ensure that all appropriate Employees are aware of the applicable AML/CFT Laws and Regulations, Market Solutions Ltd. AML/CFT Policies & procedures and their responsibilities with respect to these policies.

Objectives of Market Solutions Ltd. Anti-Money Laundering / Counter Financing of Terrorism Policy and Procedures
  • Comply with all AML/CFT Rules & Regulations of the jurisdictions it operates in;  
  • Require all Employees to prevent, detect and report all potential instances in which Market Solutions Ltd. or its employees, its facilities or its activities have been or are about to be used for money laundering, terrorist financing and other illegal activities;
  • Require all Employees to attend anti-money laundering training sessions, so that all such Employees are aware of their responsibilities under Market Solutions Ltd. policies and procedures; and as affected by current developments with respect to anti-money laundering events.
What is Money Laundering?

Money laundering involves the placement of illegally obtained money into legitimate financial systems so that monetary proceeds derived from criminal activities are transformed into funds with an apparently legal source. Money laundering has many destructive consequences both for society as a whole and for those entities involved in money laundering activities. With respect to society as whole, money laundering may provide resources for drug dealers, terrorists and other criminals to operate and expand their criminal activities. With respect to entities, any involvement whether it be to instigate, assist, conceal, or ignore the source, nature, location, ownership or control of money laundering activities, can lead to both civil and criminal proceedings against both the individual and the entity involved.

Additionally, the adverse effects, including the adverse publicity to the Firm associated with involvement in money laundering events cannot be emphasized enough.

Money laundering transactions may include:

  • Advising a potential or existing client on how to structure a transaction to avoid reporting and/or record keeping requirements;
  • Engaging in any activity while willfully or recklessly disregarding the source of the funds or the nature of the Clients transaction;
  • Engaging in any activity designed to hide the nature, location, source, ownership or control of proceeds of criminal activity;
  • Dealing in funds to facilitate criminal activity; or
  • Dealing in the proceeds of criminal activity.

Money laundering can involve the proceeds of drug dealings, terrorist activities, arms dealings, mail fraud, bank fraud, wire fraud or securities fraud, among other activities.

What Is Terrorist Financing?

Terrorist financing refers to the processing of funds to sponsors involved in or those who facilitate terrorist activity. Terrorist individuals/ groups/ organization derive income from a variety of sources, often combining both lawful and unlawful funding, and where the agents involved do not always know the illegitimate end of that income. The forms of such financing can be grouped into two types;

Financial Support – In the form of donations, community solicitation and other fundraising initiatives. Financial support may come from states and large organizations, or from individuals.

Revenue Generating Activities – Income is often derived from criminal activities such as kidnapping, extortion, smuggling or fraud. Income may also be derived from legitimate economic activities such as diamond trading or real estate investment.

Client Identification Procedures


Market Solutions Ltd. AML/CFT policy and procedures are intended to ensure that, prior to accepting funds from Clients, all reasonable and practical measures are taken to confirm the Clients’ identities.

Market Solutions Ltd. may take assistance from the bank or other financial institutions for completing client identification process. The assistance shall not relieve the Market Solutions Ltd. for identification process to be conducted by the company.

These Client Identification Procedures are based on the premise that the Market Solutions Ltd. will accept funds from a new and existing Client only after:

  • Market Solutions Ltd. has confirmed the Client’s identity and that the Client is acting as a principal and not for the benefit of any third party unless specific disclosure to that effect is made; or
  • If the Client is acting on behalf of others, Market Solutions Ltd. has confirmed the identities of the underlying third parties.

The Client Identification Procedures should be reviewed in light of the specific characteristics presented by a Client and in any instance the Compliance Officer may determine to apply enhanced measures for reasons other than those discussed in section below.

As a reference tool, an Individual Client KYC Checklist is used.

Every Customer shall be identified for establishing business relationship. For this purpose, investors need to fill out the Form available that may be send by Market Solutions` employee to the customer.

Client Identification Procedures for Corporations, Partnerships, Trusts and Other Legal Entities

Market Solutions Ltd. shall take reasonable steps to ascertain satisfactory evidence of an entity Client’s name and address.

For Identity and due diligence purposes, at the minimum following information shall be obtained, verified and recorded on KYC/CDD from:

  • Full name as per Identity document
  • Company registration /Incorporation number
  • Date and country of Incorporation
  • Date of Business Commenced
  • Residential Status
  • Type of Business
  • Name of parent Company
  • Email, website and contact numbers
  • Registered and mailing address
  • NTN number and Sales Tax number
  • Details of Contact Person and authorized person
  • Details of Bank Account
Customers’ Screening

In terms of AML/CFT Regulations, it is prohibited to provide services to proscribed individual & entities or to those who are known for their association with such individuals & entities, whether under the proscribed name or with a different name. Accordingly, it is imperative for Market Solutions Ltd. to monitor its relationships on a continuous basis and ensure that no such relationship exists. Further, in case, if any such relationship is found, immediately report the same to Financial Monitoring Unit (FMU) and take any other action, as per law.

In pursuance of above, all customers should be prorely screened through UN/OFAC sanctioned lists as available in the data base of the company.


The customer will be approved only after it has been authorized by the Director.

The customer will not be approved in cases:

  • Where CDD Measures are not completed In case the Market Solutions Ltd. is not been able to satisfactorily completed required CDD measures, customer shall not be approved or any service provided and consideration shall be given if the circumstances are suspicious so as to warrant the filing of an STR.
  • Proscribed Individuals/Entities: Market Solutions Ltd. shall not provide services to Proscribed Individuals, Groups and Entities declared/ listed by UNSC OR those who are known for their association with such entities and persons, whether under the proscribed name or with a different name.
Policy Review Period

The AML/CFT Policy & Procedures will be reviewed on as and when required basis but not later than two years.