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Anti-Money Laundering (AML) Policy

VR Capitals is committed to the highest standards of anti-money laundering compliance and requires management and staff to adhere to these standards to prevent the use of its services for money laundering purposes. Last updated: 18 June 2026.

1. Purpose

This Anti-Money Laundering (AML) Policy establishes the framework within which VR Capitals detects, prevents, and reports activities that may relate to money laundering, terrorist financing, or other financial crimes. VR Capitals applies AML controls in accordance with applicable international standards including the Financial Action Task Force (FATF) recommendations.

2. Scope

This Policy applies to all clients, accounts, transactions, and business relationships managed by VR Capitals. It covers all services provided through the VR Capitals platform, client portal, VR Web Trader, and VR5 mobile application.

3. Restricted Jurisdictions

VR Capitals does not offer services to residents or nationals of the following jurisdictions, and will not open accounts or process transactions for such persons or entities:

  • United States of America (USA) — including US persons as defined under applicable law
  • European Union (EU) member states
  • Iran
  • North Korea (Democratic People's Republic of Korea)

This list may be updated at any time to reflect changes in international sanctions, regulatory guidance, or VR Capitals business policy. Additional jurisdictions may be restricted where required by law or operational risk considerations.

4. Know Your Customer (KYC)

VR Capitals requires all clients to complete identity verification (KYC) before live account trading is enabled. KYC procedures include:

  • Verification of government-issued photo identification
  • Proof of residential address (utility bill, bank statement)
  • Source of funds declaration where applicable
  • Enhanced due diligence (EDD) for high-risk clients or large transactions

5. Customer Due Diligence (CDD)

VR Capitals applies a risk-based approach to customer due diligence. Clients are assessed at onboarding and on an ongoing basis. The level of due diligence applied — standard, simplified, or enhanced — is determined by the assessed risk profile of the client and transaction patterns.

6. Transaction Monitoring

VR Capitals monitors transactions for patterns consistent with money laundering or terrorist financing. Suspicious activity includes, but is not limited to: structuring of deposits or withdrawals to avoid reporting thresholds, sudden large transfers inconsistent with client profile, and requests to transfer funds to unrelated third parties.

7. Politically Exposed Persons (PEPs)

Clients identified as Politically Exposed Persons (PEPs) or closely associated with PEPs are subject to enhanced due diligence. Senior management approval is required before establishing or continuing a business relationship with a PEP.

8. Sanctions Screening

VR Capitals screens all clients and transactions against applicable international sanctions lists including those issued by the United Nations Security Council (UNSC), the Office of Foreign Assets Control (OFAC), and other relevant authorities. Any match will result in immediate account suspension and regulatory notification where required.

9. Suspicious Activity Reporting

Where VR Capitals has reasonable grounds to suspect that a transaction or activity is related to money laundering or terrorist financing, it will file a Suspicious Activity Report (SAR) with the appropriate financial intelligence unit. Clients are not to be informed (tipped off) that a SAR has been filed.

10. Record Keeping

VR Capitals retains all client identification records, transaction records, and supporting documentation for a minimum of five (5) years from the date of account closure or the date of the relevant transaction, in accordance with applicable AML regulations.

11. Training and Awareness

All personnel with client-facing or compliance responsibilities receive regular AML training to ensure awareness of legal obligations, red-flag indicators, and internal reporting procedures.