Anti-Money Laundering and Counter-Terrorism Financing Policy
Quantum Fund Traders Inc. (hereinafter referred to as “the Company”) establishes this policy to prevent money laundering and terrorist financing (hereinafter collectively referred to as “ML/TF”), ensure compliance with relevant laws and regulations, and maintain the integrity of its operations.
1. Key Management Priority
The Company recognizes the prevention of ML/TF as a critical management issue and is committed to developing and operating systems that ensure timely and appropriate countermeasures.
2. Chief Compliance Officer
A director or executive officer shall be appointed as the Chief Compliance Officer responsible for ML/TF prevention. Under the direction of this officer, the Company will implement ML/TF prevention measures in an organized and effective manner.
3. Customer Due Diligence Policy
At the commencement of business relationships, the Company will perform customer due diligence based on a risk-based approach, taking appropriate measures in accordance with customer profiles. Ongoing due diligence will also be conducted, including timely investigations and analysis of customer transactions, with continual review and improvement of countermeasures as necessary.
4. Economic Sanctions and Asset Freezing
The Company will establish systems to properly and promptly carry out measures such as filtering to exclude sanctioned parties and freezing of assets of terrorists and other designated entities. In accordance with the Act on Prevention of Transfer of Criminal Proceeds, appropriate actions including refusal or termination of transactions will be taken.
5. Reporting of Suspicious Transactions
Periodic and ad-hoc transaction monitoring will be conducted, and when “suspicious transactions” are identified, appropriate responses will be taken and reports will be promptly filed with the relevant supervisory authorities.
6. Internal Training
The Company will provide regular and ad-hoc training for all officers and employees to ensure understanding of relevant laws and regulations, company policies, and procedures related to ML/TF prevention, fostering knowledge and awareness.
7. Audit of Compliance
The internal audit department will appropriately and timely audit the overall implementation of ML/TF prevention measures under this policy. Based on audit results, the Company will maintain and improve its AML/CFT framework.