Anti-Money Laundering (AML) & KYC Policy

1. Purpose and scope

TradegovernorPro (“we”, “us”), based in Eastleigh, Nairobi, Kenya, is committed to preventing its services from being used for money laundering, terrorist financing, sanctions evasion or any other financial crime. This policy sets out the measures we apply to every customer and every payment, including payments made in cryptocurrency.

It applies to all customers, all payment methods we accept (cryptocurrency, mobile money and bank transfer), and everyone who works on our behalf.

2. Our business and risk profile

TradegovernorPro is a software subscription. It enforces risk-management rules on a customer’s own MetaTrader 5/4 trading account. We are not a broker, bank, exchange, wallet provider or investment scheme, and we never hold, transfer or manage customer funds. Customers pay only a fixed subscription fee (USD 29.99 per month, USD 89.97 per quarter or USD 359.88 per year).

Because we accept only small, fixed subscription payments, do not store value and do not pay out funds, our money-laundering risk is low. We still apply the controls below to keep it that way.

3. Legal framework

We operate under the laws of Kenya, including the Proceeds of Crime and Anti-Money Laundering Act, 2009 and the Prevention of Terrorism Act, 2012. We follow the recommendations of the Financial Action Task Force (FATF) and comply with the sanctions programmes listed in section 6. Where a payment partner, such as our cryptocurrency payment processor, applies stricter rules, we follow those as well.

4. Compliance responsibility

The management of TradegovernorPro has appointed a Compliance Officer who is responsible for implementing this policy, reviewing suspicious activity, keeping records and liaising with payment partners and authorities. The Compliance Officer can be reached at support@tradegovernorpro.com.

5. Customer due diligence (KYC)

Every customer must, before their subscription is activated:

• register with their real name and a valid email address that they control;
• confirm that they are of legal age in their jurisdiction;
• connect a trading account held in their own name. The broker account itself has already been identity-verified by the customer’s regulated broker or prop firm.

We apply enhanced due diligence when there is a higher risk, for example when a red flag from section 8 appears, when a customer is linked to a high-risk jurisdiction, or when a payment partner asks us to. Enhanced due diligence may include requesting a government-issued photo ID, proof of address, an explanation of the source of funds, or confirmation that the customer owns the paying wallet or account. We may suspend activation until the checks are complete.

6. Sanctions and prohibited customers

We do not accept customers, or payments from wallets or accounts, that are:

• named on the sanctions lists of the United Nations Security Council, the United States (OFAC), the European Union or the United Kingdom, or those adopted in Kenya;
• located in, or acting for persons in, comprehensively sanctioned jurisdictions or jurisdictions on the FATF “call for action” list;
• acting on behalf of an undisclosed third party, or using the Service for any unlawful purpose.

We also take account of screening results from our payment processors. A payment flagged by their screening is not accepted.

7. Cryptocurrency payments

Cryptocurrency payments are processed only through our licensed payment partner. For these payments:

• payments must be sent from a wallet that the customer owns or controls. Payments from third parties are not accepted;
• payments routed through mixers, tumblers, privacy-enhancing services or wallets linked to illicit activity are refused;
• we accept only the exact subscription amount. Overpayments are not used to buy credit or value that can be withdrawn;
• any approved refund is returned only to the original sending wallet, or by the original payment method, and never to a different person or address;
• we do not exchange, store or pay out cryptocurrency on behalf of customers.

8. Monitoring and red flags

We review payments and account activity for unusual behaviour, including:

• payments from a name, wallet or account that does not match the customer;
• repeated overpayments followed by refund requests, or requests to refund to a different destination;
• many accounts opened by the same person, or many payments split to avoid notice;
• false, inconsistent or reused identity details, or refusal to provide information when asked;
• links to sanctioned persons, high-risk jurisdictions or known illicit wallets.

9. Reporting suspicious activity

Any staff member who suspects money laundering or terrorist financing must report it to the Compliance Officer straight away. The Compliance Officer reviews the case and, where required, files a report with the Financial Reporting Centre (FRC) of Kenya and informs the relevant payment partner. We will not tell the customer that a report has been made or is being considered (“tipping off”).

We may refuse, suspend or terminate any account or payment, and withhold any refund, where we suspect a breach of this policy or of the law.

10. Record keeping

We keep customer identification data, payment records and records of any AML review or report for at least seven (7) years after the end of the customer relationship, as required by Kenyan law. Records are stored securely and handled in line with our Privacy Policy.

11. Cooperation, training and review

We cooperate fully with law-enforcement authorities, regulators and our payment partners, including their information requests. Everyone who handles payments or customer verification is made aware of this policy and how to spot red flags. We review this policy at least once a year, and whenever our services, payment methods or legal obligations change.

12. Customer acknowledgement

By creating an account or making a payment, you confirm that the funds you use are from a lawful source, that you are paying for yourself, and that you will provide the information we reasonably request under this policy. This policy forms part of our Terms & Conditions.