Regulation

Anti-Money Laundering

In accordance with the FSA Anti-Money Laundering and Counter Terrorism Financial Act 2020, DPL has in place policies and procedures to ensure compliance with the law. These policies and procedures are designed to prevent money laundering activities from occurring. DPL’s AML Policy outlines the documents that you must provide us before opening an account.

Individual Account Opening Document Requirements

In accordance with the FSA Anti-money Laundering and Countering the Financing of Terrorism Act 2020 we are required to verify your identity prior to opening a trading account.

We are required to collect official Government ID as well as proof of official residence. Please note that these documents are also required to be certified as true copies of the originals by a lawyer, government official, member of a regulatory body, etc.
The following are acceptable forms of photo identification:

• A valid Passport
• A valid Government ID, such as a Driver’s License or State ID
• A valid National Identity Card

Photo ID must show full name and date of birth.

The following are acceptable forms of proof of residence:

• A Utility Bill (phone, gas, electricity)
• Bank or Credit Card Statement
• Government-Issued Tax Document

All proof of residences must be current and not outdated by more than 90 days, show the full document, clearly display the name and address (no PO Boxes), and show a provision of services such as money owed or paid.

We must be able to understand the language shown on your Photo ID and Proof of Residence. We may require documents provided in languages other than English to be accompanied by an English translation.

Corporate Account Opening Document Requirements

In accordance with Anti-money Laundering and Countering the Financing of Terrorism Act 2020, we are required to verify information about your company prior to opening a corporate trading account for you. To ensure that your account is approved please submit the following:

Legal Person documentation:

• Certificate of Incorporation/Registration
• Articles of Association/Memorandum
• Certificate Directors and all Shareholders/Members/Partners including the percentage of their ownership
• A proof of company’s registered address not older than 90 days / as well as principal place of business (Utility bill)
• A resolution of the board of directors of the legal person for the opening of the account and granting authority to those who will operate it; and
• LEI number

Officers and persons with significant control:

Documents and data for the verification of the identity of:

• The persons that are authorised by the legal person to operate the account

• Registered shareholders/beneficial owner/s of the legal person
• Directors
      o A valid photo ID (National ID or Passport)
      o A proof of residence (Utility Bill, Bank Statement), not older than 90 days

In the case of a legal person whose direct/immediate and principal shareholder is another legal person, registered in the Republic or abroad, the Company verifies the ownership structure and the identity of the natural persons who are the beneficial owners and/or control the other legal person.

Segregation of Client Funds

When funding your trading account client funds are held in client segregated accounts with top tier banking institutions. DPL complies with the Securities (Conduct of Business) Regulations 2018 and employs strict policies and procedures regarding the maintenance and operation of these accounts.

Funds Withdrawal Procedures

The AML policy and procedure at DPL detailed below is structured around strict guidelines to make sure that funds are securely sent back to their originating source and beneficiary.

• DPL customers must complete a withdrawal request containing their correct account information.

• All withdrawal requests are submitted to DPL accounts department for processing. Our Accounts department confirms the account balance, verifies that there are no holds or withdrawal restrictions on the account, and then approves the withdrawal request, pending compliance approval.

• DPL department reviews all withdrawal requests, verifying the original funds are withdrawn via the same method of deposit and to the account holder on file. Our accounts department examines the withdrawal request against the customer’s deposit history to make sure there is no suspicious activity and verifies the bank account on file.

• Withdrawal requests approved are processed by the accounts department and the funds are released to the client.

• If a withdrawal is flagged for suspicious activity, the withdrawal is placed on hold, pending further investigation by DPL Management staff.

AML Policy Details

The AML policy and procedure at DPL detailed below is structured around strict guidelines to make sure that funds are securely sent back to their originating source and beneficiary.

• DPL monitors funding from various bank accounts outside of the account holder’s home country.

• DPL performs its actions based on the anti-money laundering framework.

• DPL neither accepts credit card or cash deposits nor disburses cash under any circumstances.

• DPL does not accept third-party deposits of any kind.

• DPL matches each deposit to the account name on file for that customer.

• DPL reserves the right to refuse processing a transaction at any stage where it believes the transaction to be connected in any way to money laundering or criminal activity. In accordance with international law, DPL is not obligated to inform the client if suspicious activity is reported to any corresponding regulatory or legal bodies.