AML & CTF Policy

Last updated on: July 22, 2025

1. Introduction

Please note that Core Funded (Fingrow LTD) is not a company regulated by the CySEC in Cyprus, as it does not fall under the definitions of performing regulated activities according to Cypriot financial laws. Nevertheless, at Core Funded we are committed to upholding the highest standards in anti-money laundering (AML) and counter-terrorism financing (CTF). This policy serves to protect our company, our customers and society from money laundering, terrorism financing and other illegal financial activities.

As such, we verify and document information that identifies every person who opens a Core Funded account with us - whether Instant Funding, One-Step Challenge or Two-Step Challenge.

2. Scope

This policy applies to all users of the Core Funded platform as well as to all employees, service providers and partners involved in the provision of our services.

Core Funded offers only simulated trading evaluations ("Challenge Evaluations"), in which synthetic capital is used. Nevertheless, preventive measures against money laundering and terrorism financing apply, in particular to:

• Payment transactions in connection with challenge registration

• Customer data management

• Payouts of generated profits

• Refunds, if relevant in exceptional cases

3. Definition of money laundering

Money laundering - the process of converting funds derived from illegal activities (such as fraud, corruption, terrorism, etc.) into other funds or investments that appear legitimate in order to hide or conceal the true source of the funds.

Examples of money laundering:

• Use of stolen credit card data

• Channeling payments via third-party accounts

• Use of stolen identities

The money laundering process can be divided into three successive stages:

Placement - In this phase, funds are converted into financial instruments such as checks, bank accounts and money transfers or may be used to purchase high-value goods that can be resold. They can also be deposited physically at banks and non-bank institutions (e.g., currency exchange offices). To avoid suspicion, the launderer may also make multiple deposits instead of the entire sum at once - this form of placement is called smurfing.

Layering - Funds are transferred or moved to other accounts and other financial instruments. This is done to obscure the origin and to disrupt signs of the entity that performed the multiple financial transactions. Moving funds and changing their form makes it complicated to trace the laundered money.

Integration - Funds return to circulation as legitimate means to purchase goods and services.

4. Preventive measures

4.1 Know Your Customer (KYC) and Due Diligence

Core Funded conducts identity checks where necessary before entering into a business relationship with customers. Due to the company's commitment to AML and KYC policies, every customer who reaches the "Payout" stage must complete a KYC verification by Core Funded.

Depending on the risk profile, the following documents may be requested:

• Valid photo ID (identity card, passport)

• Proof of residence (e.g., utility bill, bank statement, not older than 3 months)

• Additional documents if there are irregularities, where applicable

KYC is applied in particular to:

• Suspicious transaction behaviour

• Refund requests

• Suspected fraudulent activities

• Customers originating from high-risk countries

We will also apply enhanced scrutiny to customers who are residents of other countries identified by credible sources as having inadequate AML standards or as high risk for crime and corruption, as well as to beneficial owners who live in those countries and whose funds originate from those countries.

4.2 Payment processing

To prevent money laundering, Core Funded under no circumstances accepts or pays out cash. Core Funded accepts payments exclusively through established and secure payment service providers. Cash payments or anonymous payment methods are not accepted.

4.3 Monitoring & surveillance

Core Funded takes all necessary measures in accordance with applicable laws and regulations issued by financial supervisory authorities. This includes:

• Monitoring transactions for irregularities

• Detection of suspicious behaviour (e.g., multiple registrations, implausible information)

• Automated and manual checks when there are suspicions

• Monitoring customer activity

4.4 Data retention

All collected data is processed in accordance with the GDPR (EU) and Cypriot data protection laws and retained for at least 5 years to meet regulatory requirements.

5. Reporting obligations and right to refuse

Core Funded reserves the right to refuse to process a transaction/payment at any stage where it believes the transaction is in any way connected to money laundering or criminal activity. The company reserves the right to suspend any customer operations that staff consider may be illegal or may be related to money laundering.

Suspicions of money laundering or terrorism financing are reported to the competent authorities. In accordance with international laws, Core Funded is not obliged to inform the customer when suspicious activities are reported to the relevant regulatory or legal authorities.

6. Training & awareness

All employees and partners of Core Funded who come into contact with payments or customer data receive regular training on AML and CTF topics to ensure that all parties are informed about the latest developments and requirements.

7. Sanctioned countries

Although we welcome customers from around the world, government restrictions together with our company policies prohibit Core Funded from opening accounts from the following restricted and/or sanctioned countries:

Afghanistan, Belarus, Burundi, Central African Republic, Republic of the Congo, Cuba, Crimea, Democratic Republic of the Congo, Eritrea, Guinea, Guinea-Bissau, Iran, Iraq, Liberia, Libya, Myanmar, North Korea, Papua New Guinea, Russia, Somalia, South Sudan, Sudan, Syria, Vanuatu, Venezuela, Yemen and Zimbabwe.

8. Disclaimer

Core Funded offers only simulated trading evaluations with synthetic capital. No real trading with real capital takes place, however the profits generated are real and payable. Nevertheless, we are committed to strict compliance with AML/CTF requirements to minimize any risk of misuse and to ensure the integrity of our platform.

9. Contact

Please direct suspicious reports, compliance questions or general inquiries regarding our AML policy to:

Email: [email protected]

Fingrow LTD Istanbul 10, Athanasia Court, Office No.9, 6025 Larnaca, Cyprus