VALOR MARKETS LTD (“VALOR MARKETS”) is committed to the highest standards of integrity, transparency, and regulatory compliance. This combined AML/KYC Policy describes the measures, controls, and procedures we apply to prevent money laundering, terrorist financing, and other illicit financial activities, and to verify and monitor all client relationships in accordance with the Union of the Comoros’ legal framework.
This Policy applies to every prospective and existing client of Valor Markets. Its purpose is to ensure that Valor Markets’ products and services are not used to launder money, finance terrorism, or facilitate other financial crimes. To achieve this, we identify and verify the true identity of all clients and perform ongoing, risk-based monitoring of client relationships and transactions.
Valor Markets complies with the Money Laundering (Prohibition) Ordinance No. 3-002/PR of 2003, also known as “La loi 12-008/AU portant lutte contre le blanchiment d’argent et le financement du terrorisme”. We further adhere to the guidelines and oversight of the Banque Centrale des Comores (“BCC”) and the Comoros Cellule de Renseignement Financier (“CRF”) for AML/CFT matters2. In addition, we respect data protection requirements enforced by the Commission Nationale de Protection des Données Personnelles (“CNPD”) under Comoros’ privacy laws.
The Board of Directors is responsible for approving this Policy and for allocating sufficient resources to ensure its effective implementation. The designated Compliance Officer maintains and updates the AML/KYC programme, files Suspicious Transaction Reports (“STRs”) and Currency Transaction Reports (“CTRs”) with the CRF and liaises with the BCC and other regulatory authorities. All employees must complete mandatory AML/KYC training and report any suspicions of illicit activity to the Compliance Officer without delay.
Before establishing any business relationship, Valor Markets conducts a risk assessment to classify each client as low, medium, or high risk based on factors such as geographic location, transaction volume, and product usage. We collect identification documents that conform to Comoros regulations: natural persons must present a valid national identity card, passport, or driver’s licence, while juristic entities must provide a certificate of incorporation, proof of registered address, and details of directors and ultimate beneficial owners. We verify these documents through reliable, independent sources or accredited electronic databases where available.
As part of our CDD procedures, we collect and record essential client information, including the client’s full name, date of birth, nationality, residential address, and contact details. We screen each client against international sanctions lists, Politically Exposed Person (“PEP”) registries, and reputable adverse-media sources to ensure that we understand each client’s background fully.
Valor Markets applies enhanced due diligence measures to clients who present a higher risk, such as PEPs, clients from jurisdictions identified as having elevated money-laundering concerns, or those with complex ownership structures. For these relationships, we obtain additional documentary evidence of source of funds and source of wealth, require senior management approval to onboard the client, and conduct more frequent reviews of the client’s profile and transaction activity.
Once a business relationship is established, we continuously monitor account activity through both automated systems and manual reviews to detect transactions that deviate from expected patterns in size, frequency, or counterparty. We refresh KYC documentation at least every twelve months for high-risk clients and every thirty-six (36) months for lower-risk clients. Any material change in a client’s profile triggers an immediate review and update of their due-diligence records.
Valor Markets files a Suspicious Transaction Report with the CRF within twenty-four hours of identifying any transaction that may involve money laundering or terrorist financing. We submit Currency Transaction Reports for all cash transactions exceeding the equivalent of ten thousand USD ($10,000) (or local currency threshold as defined by BCC) within fifteen business days of the transaction. If we detect property or funds linked to terrorist activities, we file a Terrorist Property Report with the CRF within twenty-four (24) hours of detection.
We screen all new clients against the United Nations Security Council sanctions lists and relevant Comoros domestic sanctions regulations. We re-screen our entire client base quarterly and whenever a material change occurs in a client’s profile to ensure ongoing compliance.
In accordance with Comoros law, Valor Markets retains all client identification records, transaction logs, screening results, and related correspondence for a minimum of ten years. These records are stored securely in tamper-evident systems with restricted access, and regular backups are performed to ensure data integrity and recoverability.
All new employees undergo mandatory AML/KYC induction training upon hiring, and all staff members complete annual refresher courses. We also provide role-specific training modules for frontline personnel, compliance teams, risk managers, and internal auditors. These programmes are updated regularly to reflect changes in regulatory requirements and emerging typologies of financial crime.
Valor Markets handles all personal and corporate information collected under this Policy in accordance with our Privacy and Data Protection Policy, enforced by the CNPD. Access to sensitive records is limited to authorised personnel only, and all STRs, CTRs, and internal investigation materials are treated as strictly confidential.
This AML/KYC Policy is reviewed at least annually, or sooner if there are material changes in Comoros legislation, regulatory guidance, Valor Markets’ risk profile, product offerings, or organisational structure. Any proposed amendments must be approved by the Board of Directors before implementation
If you have any questions about our AML/KYC procedures or wish to request a copy of our full AML/CFT programme, please contact our Compliance Officer at: support@valormarkets.com