KYC & AML Policy

1. Introduction

Navion Fx Limited is firmly committed to preventing money laundering (ML), terrorist financing (TF), and proliferation financing (PF) in accordance with the Money Laundering (Prevention) Act, the Anti-Terrorism Act, and all applicable Saint Lucia legislation and FATF Recommendations.

This policy establishes the framework, procedures, and internal controls that govern how Navion Fx identifies, assesses, and mitigates financial crime risks across all business relationships and transactions.

2. Zero-Tolerance Policy

Navion Fx Limited adopts a zero-tolerance approach towards money laundering, terrorist financing, and proliferation financing. We will not knowingly establish or maintain business relationships with clients involved in illicit financial activities.

All employees, contractors, agents, and representatives are required to comply with this policy. Non-compliance may result in disciplinary action, including termination, and may expose individuals to criminal and civil liability.

3. Know Your Customer (KYC)

All clients must complete a full KYC verification process before any trading activity can commence. No account will be opened or transaction processed without satisfactory completion of due diligence.

For Individual Clients:
Valid government-issued photo ID (passport, national ID, or driver's license)
Proof of address dated within the last 3 months (utility bill, bank statement, or government correspondence)
Declaration of source of funds and source of wealth
Occupation and expected account activity

For Corporate Clients:
Certificate of Incorporation and Memorandum & Articles of Association
Register of Directors and Shareholders
Verification of all beneficial owners holding 25% or more ownership
Verification of all authorized signatories
Source of funds declaration

Source of Funds: For any transaction exceeding $25,000, clients are required to complete a Source of Funds Declaration Form before the transaction is processed.

Failure to Complete KYC: If satisfactory due diligence cannot be completed, the account will not be opened, no transactions will be executed, and any deposited funds will be returned to their source.

4. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied when a client presents elevated risk factors, including:

Classification as a high-risk customer
Residence in or transactions involving a high-risk jurisdiction
Complex or opaque ownership structures
Unclear or unverifiable source of funds or wealth
Identification as a Politically Exposed Person (PEP)
Unusual or inconsistent transaction patterns

EDD measures include obtaining detailed source of wealth documentation, independent document verification, enhanced screening, adverse media searches, and Senior Management approval before the relationship is established.

5. Politically Exposed Persons (PEPs)

A Politically Exposed Person is an individual who is or has been entrusted with a prominent public function, including heads of state, senior government officials, senior executives of state-owned entities, and senior members of international organizations. EDD requirements also extend to their immediate family members and close associates.

All clients complete a PEP declaration at onboarding and are screened against the FIA Domestic PEP List and commercial PEP databases. PEPs are automatically classified as high-risk and require Senior Management approval before an account is opened. Enhanced monitoring applies for a minimum of 12 months after a PEP leaves their public function.

6. Transaction Monitoring

Navion Fx employs automated and manual transaction monitoring to detect activity that is inconsistent with a client's profile or that may indicate money laundering or terrorist financing. Monitoring considers transaction thresholds, behavioral patterns, geographic risk, and cumulative activity over defined periods.

All clients are regularly screened against the UNSCR Consolidated Sanctions List, FATF High-Risk Jurisdiction updates, and FIA advisories. When an alert is generated, compliance staff investigate the activity, review the client's profile and transaction history, and determine whether a Suspicious Activity Report (SAR) is required.

7. Suspicious Activity Reporting

Under Section 16(1)(k) of the Money Laundering (Prevention) Act, Navion Fx is legally obligated to report suspicious transactions to the Financial Intelligence Authority (FIA) within 7 days of a transaction being deemed suspicious.

All employees must immediately report any suspected ML/TF/PF activity to the Compliance Officer. The Compliance Officer reviews every internal report and files a SAR with the FIA where the suspicion threshold is met. It is strictly prohibited to inform a client that a SAR has been filed or to take any action that could alert them to an investigation (tipping-off). Violations of this prohibition may result in criminal prosecution.

Employees who report suspicious activity in good faith are fully protected from liability.

8. Sanctions & Restricted Regions

Navion Fx does not accept clients from, or process transactions involving, the following jurisdictions:

Regulatory Restrictions:
United States of America
European Union member states
Iceland, Liechtenstein, Norway

Sanctioned & FATF High-Risk Jurisdictions:
Democratic People's Republic of Korea (North Korea)
Iran, Myanmar, Cuba, Syria
Any jurisdiction subject to active international sanctions

All clients are screened against applicable sanctions lists at onboarding and on an ongoing basis. Where a confirmed sanctions match is identified, the account is frozen immediately, no transactions are processed, and the matter is reported to the FIA.

9. Record Keeping

All KYC documents, transaction records, risk assessments, SAR filings, training records, and audit reports are retained for a minimum of 7 years from the date of the last transaction or termination of the business relationship, as required under Sections 163–174 of the MLPA Regulations.

Records are stored securely with access restricted to authorized personnel and must be readily retrievable upon request by the FIA, FSRA, or law enforcement authorities.

10. Contact

For queries related to KYC verification or AML compliance, please contact our Compliance Officer:

Email: compliance@navionfx.com
Phone: +1 758 486 0469