Propywise, a brand under Merga Trading Limited (Reg No. 120814), is committed to upholding the highest standards in preventing money laundering, terrorist financing, and sanction evasion. Strict compliance with all applicable laws and regulations is fundamental to preserving the reputation of Propywise and ensuring public trust in our proprietary trading platform.

Our AML policy outlines the steps we take to combat money laundering, including the measures we follow to comply with the regulatory framework governing designated non-financial businesses and professions (DNFBP) globally. This policy applies to all entities under Propywise and ensures that our operations maintain the highest standards of integrity and legality.

Policy Objectives
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- Establish clear policies to prevent money laundering, terrorist financing, and sanctions evasion.
- Define compliance responsibilities for all Propywise employees.
- Provide guidance for employees to ensure business activities comply with legal requirements.
- Foster a company-wide culture of legal compliance and risk management.

Definition of Money Laundering
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As outlined in Article 2 of the Anti-Money Laundering (AML) Law, money laundering refers to knowingly engaging in the following activities using proceeds from a criminal act:
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- Transferring or moving funds to disguise their source.
- Concealing the true nature or origin of the proceeds.
- Acquiring, possessing, or using funds derived from criminal activity.
- Assisting those involved in criminal acts to evade punishment.

Money laundering is always intentional, and failure to report suspicious activity can result in criminal liability under the laws applicable to Merga Trading Limited.
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Relevant Laws and Regulations
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As Merga Trading Limited operates under the jurisdiction of the Marshall Islands, we comply with the Marshall Islands Anti-Money Laundering Act and other relevant global regulations. Additionally, we voluntarily adhere to Financial Action Task Force (FATF) guidelines and other international standards governing AML compliance, which include but are not limited to:
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- Marshall Islands Anti-Money Laundering Act (2000) and relevant amendments.
- Financial Action Task Force (FATF) Recommendations on AML/CFT.
- International conventions on combating terrorist financing and sanctions compliance.

Our AML program follows a risk-based approach that ensures customer onboarding, transaction monitoring, and compliance assessments align with global best practices.

Investigatory Powers and Criminal Enforcement
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Reporting of suspicious activities is governed by the Financial Intelligence Unit (FIU) of the Marshall Islands, which has the authority to investigate financial crimes. Any legal proceedings regarding these offenses are handled by the local criminal courts.

Transaction Monitoring System
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Propywise has implemented a transaction monitoring system designed to identify unusual or suspicious transactions. Daily transaction reports are currently manually reviewed, and we plan to introduce an automated transaction monitoring system to improve efficiency. Our transaction monitoring includes the use of identity verification services to ensure compliance with AML regulations.

Detection of Suspicious Transactions
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Propywise operates under a business-to-consumer (B2C) model, where transactions typically range from $9 to $999. Each transaction undergoes a manual approval process to ensure due diligence and detect potential money laundering or suspicious activities. We closely scrutinize all transactions to maintain compliance with international standards and relevant local laws.

Reporting Suspicious Transactions
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Propywise fulfills its obligation to report suspicious transactions to the appropriate authorities, in this case, the Financial Intelligence Unit (FIU) of the Marshall Islands. Transactions are reported through designated secure channels, and all documentation related to these reports is retained for a minimum of five years, as required by applicable law.

Risk Rating and Compliance
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Propywise employs a comprehensive risk management process, where individual client profiles are meticulously assessed based on risk factors. The evaluation of customer risk ratings allows us to take necessary steps in mitigating any potential AML/CFT risks.

Resolutions and Sanctions

In cases of non-compliance with AML regulations, the Marshall Islands law allows for a range of administrative sanctions, including:
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- Monetary fines.
- Business activity suspension.
- Imprisonment of responsible individuals.
- Board member or management accountability.
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Convictions for money laundering can result in significant financial penalties and imprisonment, as prescribed by the Marshall Islands Anti-Money Laundering Act and relevant international standards.

Employee Training
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All Propywise employees are required to undergo annual AML/CFT training to stay updated on the latest regulatory requirements and best practices. Training covers:
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- How to identify and report suspicious activities.
- Examples of money laundering and terrorist financing risks specific to our products and services.
- Internal policies for preventing money laundering and terrorist financing.

Propywise maintains thorough documentation of all training sessions, ensuring compliance with any new AML/CFT legislation and internal policy updates.

Designated Compliance Team
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Propywise has appointed a Designated Compliance Officer to oversee the implementation of our AML/CFT program. The compliance team is responsible for conducting regular audits and ensuring that all operations align with global regulatory standards. This team works closely with risk management to ensure comprehensive oversight of all compliance matters.

Propywise’s Commitment
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As part of Merga Trading Limited, Propywise is dedicated to upholding the highest standards of compliance, transparency, and ethical conduct in the prevention of money laundering and terrorist financing. By adhering to both Marshall Islands laws and international AML regulations, we aim to provide a safe, compliant, and transparent trading environment for all our users.

For any inquiries regarding AML compliance or reporting needs, contact us at support@propywise.com.