(This section forms an integral part of Fortis Reserve’s Terms & Conditions and applies to every client relationship.)

Fortis Reserve adheres to the anti‑money‑laundering and counter‑terrorist‑financing requirements set out in:

• The Financial Action Task Force (FATF)‑40 Recommendations
• The EU 5th & 6th AML Directives (transposed into Estonian law via the Money‑Laundering and Terrorist‑Financing Prevention Act)
• The Swiss Anti‑Money‑Laundering Act and FINMA Circular 2017/1
• Any applicable guidance from the Estonian Financial Supervision and Resolution Authority (EFSA) and the Swiss Financial Market Supervisory Authority (FINMA)

• 2.1 Identification & Verification – All clients must provide government‑issued photo ID and a secondary proof of address before any trading or withdrawal activity is permitted.
• 2.2 Enhanced Due Diligence (EDD) – Fortis Reserve applies EDD to high‑risk customers, politically exposed persons (PEPs), and any party transacting in high‑risk jurisdictions or crypto assets.
• 2.3 Ongoing Monitoring – Client records are refreshed at least annually or sooner if risk factors change (e.g., unusual trading volumes, third‑party deposits, or adverse media).

Clients may be asked to supply documentary evidence—such as bank statements, sale contracts, payslips, or tax returns—demonstrating the lawful origin of deposited funds. Fortis Reserve will suspend trading and withdrawals until satisfactory evidence is obtained.

• 4.1 Automated Surveillance – All transactions pass through real‑time screening tools that flag typologies recognised by FATF (e.g., structuring, rapid in/out transfers, masquerading trades).
• 4.2 Manual Review – Alerts are escalated to the Compliance & Risk team for investigation.
• 4.3 Account Restriction – Fortis Reserve reserves the right to freeze, block, or close an account where suspicious activity cannot be resolved.

• 5.1 Suspicious Transaction Reports (STRs) – Where grounds for suspicion remain, Fortis Reserve files STRs with:
  • FIU‑EST (Estonian Financial Intelligence Unit) for EU‑booked transactions
  • MROS (Money Laundering Reporting Office Switzerland) for Swiss‑booked transactions
  Clients will not be informed of any STR filing, in line with “tipping‑off” prohibitions.
• 5.2 Sanctions Screening – All clients and counterparties are screened daily against UN, EU, UK‑HMT, and US‑OFAC sanctions lists. Matches result in immediate account suspension.

All CDD/EDD files, transaction logs, and STR submissions are securely retained for a minimum of five (5) years after the business relationship ends, or longer if required by local law.

By opening an account, you agree to:

• 1. Provide accurate, up‑to‑date identification documents.
• 2. Disclose the true beneficial owner of any account or transaction.
• 3. Cooperate promptly with any request for additional AML documentation.
• 4. Refrain from disguising the origin of funds or engaging in activity intended to facilitate money laundering, terrorism financing, tax evasion, or any other crime.

Failure to comply may lead to frozen funds, contract termination, and possible reporting to law‑enforcement authorities.

All Fortis Reserve employees receive annual AML/CTF training and must certify compliance with internal policies. Senior management reviews AML effectiveness quarterly and updates controls in response to evolving typologies and regulatory guidance.

Fortis Reserve is committed to maintaining the highest standards of integrity and fully supports global efforts to detect and deter money laundering and terrorist financing.