1. Purpose
GCC Brokers is required, and committed, to prevent our services being used for money laundering, terrorist financing, the financing of proliferation, sanctions evasion, fraud or any other financial crime.
This Policy explains what we ask of you, why, and what happens if we cannot get it. It forms part of, and must be read together with, the Client Agreement (Terms of Business) and the Privacy Policy.
2. The framework we work within
Where your account is held with GCC Brokers Limited (Mauritius, company number 193243), licensed by the Financial Services Commission of Mauritius as an Investment Dealer (licence GB22200739), we are subject to Mauritian anti-money laundering law and to the FSC's requirements — including the Financial Intelligence and Anti-Money Laundering Act and its Regulations, Mauritius's counter-terrorism and UN sanctions legislation, and the FSC's AML/CFT Handbook. Our licence conditions require us to maintain an AML/CFT framework, to enforce it, to re-assess it annually, and to make our records available to the FSC on request.
Where your account is held with GCC Brokers Limited (Saint Vincent and the Grenadines, company number 25578 BC 2019), that company is not licensed for investment business. We nevertheless apply the same standards to both companies. Our controls do not vary according to which entity holds an account.
3. Before we can open your account
We must identify and verify every client. We cannot activate an account, accept a deposit or execute a trade until this is complete.
3.1 If you are an individual, we will ask for:
- Proof of identity — a valid government-issued photo identity document (passport, national identity card or driving licence), showing your full name, date of birth, and the document's number and expiry.
- Proof of address — a document dated within the last three months showing your name and residential address: a utility bill, bank or credit card statement, or a government-issued document. A post office box is not an address.
- Contact details — the email address and telephone number you will use.
- Information about you — your occupation, and your trading knowledge and experience, so that we can assess your application.
3.2 If you are applying on behalf of a company or other entity, we will ask for its constitutional and registration documents, evidence of its registered office and business address, the identity of its directors and authorised signatories, evidence of the authority of the person acting for it, and the identity and verification of its beneficial owners — the individuals who ultimately own or control it.
3.3 Quality of documents. Documents must be complete, legible, current and unaltered. We may require certified copies, a document in or translated into English, or a live verification check. We may decline a document without giving reasons.
4. Source of funds and source of wealth
These are two different things and we may ask about either.
- Source of funds — where the specific money you are depositing came from.
- Source of wealth — how your overall financial position was built: your employment or business, an inheritance, the sale of a property or a company, investment returns.
We may ask at any point — at onboarding, before a large deposit, or during the relationship — and we may ask for supporting evidence such as payslips, tax returns, audited accounts, bank statements or a sale agreement. Where we ask and do not receive a satisfactory answer, we will not proceed.
5. Screening
We screen every client, and every beneficial owner and authorised person, at onboarding and on an ongoing basis, against:
- sanctions lists — United Nations, and any other regime applicable to us;
- politically exposed persons (PEPs) — people entrusted with a prominent public function, and their family members and close associates; and
- adverse media — public reporting relevant to financial crime risk.
Being identified as a PEP is not a reason to refuse you. It requires enhanced scrutiny: the relationship is classified as high risk, we must establish your source of wealth as well as your source of funds, and senior management approval is required to open or continue the account. If your status changes during the relationship — including if you become a PEP — tell us, and we will reassess.
A confirmed sanctions match is different. We cannot open or operate an account for a sanctioned person or entity, and we must act on it.
6. Enhanced due diligence
We apply additional measures, which may include further documentation, closer scrutiny of transactions, lower limits and senior management approval, where:
- you are a PEP, or a family member or close associate of one;
- you are resident in, or connected to, a higher-risk jurisdiction;
- the account's activity is unusual, unusually complex, or inconsistent with what we know about you;
- the relationship is conducted in a way that limits our ability to verify you; or
- anything else about the relationship presents a higher risk.
7. Deposits and withdrawals
These rules affect clients more often than any other part of this Policy.
7.1 Payments must come from you. We accept deposits only from an account or instrument in your own name. We do not accept third-party payments, and a third-party payment will be returned to source.
7.2 Withdrawals return the way funds arrived. We return funds to the same source they came from, so far as possible — a card deposit is returned to that card, a bank transfer to that account. This is a financial-crime control, not an inconvenience: it prevents our services being used to move money between unrelated parties.
7.3 We may ask before processing. We may request further information or evidence before accepting a deposit or releasing a withdrawal, and we may defer either while we do.
7.4 We may refuse. We may reject or return any payment we cannot satisfactorily identify, or that is inconsistent with this Policy.
8. Ongoing monitoring
Verification is not a one-off.
- We monitor account activity and transactions on an ongoing basis, including automated monitoring, to identify activity that is unusual or inconsistent with what we know about you.
- We review and refresh client documentation periodically, more frequently for higher-risk relationships. We will ask you for updated documents when yours expire or become out of date, and your account may be restricted until you provide them.
- You must tell us promptly if your details change — name, address, nationality, tax residence, contact details, employment, PEP status, or the beneficial ownership of a corporate client.
9. What we may do
Where we are unable to complete due diligence, where information is not provided, or where we have concerns about financial crime risk, we may — at any time and without prior notice:
- decline an application;
- suspend or restrict trading, deposits or withdrawals on an account;
- freeze an account;
- return funds to source; or
- terminate the relationship and close the account.
Where we exit a relationship for these reasons, funds are returned on a source-to-source basis under Section 7.2, subject to any legal restriction that prevents us from doing so.
10. Reporting, and why we sometimes cannot explain
We are required to report suspicious activity to the relevant authorities.
The law prohibits us from telling you that a report has been made, or that one is being considered. This is known as "tipping off". It means that if your account is restricted or closed for this reason, we may be unable to give you a reason, and our staff will not be able to discuss it with you, however reasonable your request. That is not evasiveness and it is not a judgement about you personally — we have no discretion in the matter.
We are also required to cooperate with, and provide information to, regulators, financial intelligence units, law enforcement and courts, and we may be required to do so without telling you.
11. Records
We keep records of your identity, verification documents, transactions, and our internal reports for at least seven years after the end of the business relationship or the completion of the transaction, as required by Mauritian law and by our licence conditions. Those records are available to our regulator on request.
How we handle your personal data, and your rights in relation to it, are set out in our Privacy Policy.
12. Our internal arrangements
We maintain a written AML/CFT framework approved and overseen by our board, appoint officers responsible for compliance and for reporting suspicious activity, screen our staff, and train all employees on financial crime appropriately to their role and on a recurring basis. Our framework is re-assessed at least annually.
13. What we ask of you
- Give us accurate, complete and current information, and tell us promptly when it changes.
- Provide documents when we ask, and do not send altered or falsified documents. Doing so is a criminal offence in most jurisdictions and will end the relationship.
- Fund your account only from sources in your own name.
- Do not allow anyone else to use, control or trade on your account.
- Understand that delays caused by outstanding documentation are within your control, not ours.
14. Changes to this Policy
We may amend this Policy at any time by publishing an updated version on our website. The version published at the relevant time applies.
15. Contact
Questions about this Policy, or about a request we have made of you, can be sent to our compliance team using the details published on our website.