10-Four AML Policy
10-FOUR ANTI-MONEY LAUNDERING (AML) POLICY
Last Updated: 24/02/2026
1. Policy Statement
10-Four UK Ltd (Company No. 16987174), registered at 128 City Road, London EC1V 2NX, United Kingdom (“10-Four” or the “Company”), is committed to preventing money laundering, terrorist financing, sanctions evasion, fraud, and other financial crimes. The Company maintains a zero-tolerance approach toward illicit financial activity and implements a risk-based Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) framework in accordance with applicable United Kingdom legislation. This Policy applies to all directors, officers, employees, contractors, and associated persons of the Company.
2. Legal and Regulatory Framework
10-Four UK Ltd operates in accordance with applicable UK legislation, including but not limited to the Proceeds of Crime Act 2002 (POCA), the Terrorism Act 2000, the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended), the Sanctions and Anti-Money Laundering Act 2018, and UK sanctions regulations administered by the Office of Financial Sanctions Implementation (OFSI). The Company adopts a risk-based approach consistent with UK regulatory expectations.
3. Definition of Money Laundering
Money laundering involves the concealment, conversion, transfer, acquisition, possession, or use of criminal proceeds. It is an intentional criminal offense. Failure to report suspicions of money laundering or terrorist financing may also constitute a criminal offense under UK law.
4. Scope of Application
This Policy applies to all business activities of 10-Four UK Ltd, including evaluation programs, funded trading programs, onboarding procedures, payment processing, and compliance monitoring.
5. Risk-Based Approach
The Company applies a structured risk-based framework to identify, assess, and mitigate financial crime risks. This includes customer risk assessment, geographic risk evaluation, payment method risk review, behavioral monitoring, and ongoing compliance oversight. Clients are assigned internal risk ratings based on objective compliance criteria.
6. Customer Due Diligence (CDD)
The Company conducts appropriate Customer Due Diligence measures, including identity verification (KYC), sanctions screening, Politically Exposed Person (PEP) screening, payment verification controls, and ongoing monitoring of account activity. Enhanced Due Diligence (EDD) may be applied in higher-risk cases. The Company reserves the right to request additional documentation at any time.
7. Transaction Monitoring
Although 10-Four operates a simulated trading model, financial transactions occur in connection with evaluation fees and performance-based payouts. The Company monitors transactions to detect abnormal payment behavior, suspicious chargebacks, structured transactions, use of third-party payment methods, sanctions exposure, and identity manipulation. Where required, Suspicious Activity Reports (SARs) will be submitted to the UK National Crime Agency (NCA).
8. Sanctions Compliance
The Company complies with UK sanctions regulations and does not provide services to sanctioned individuals, entities, or persons located in sanctioned jurisdictions. Sanctions screening is conducted during onboarding and periodically thereafter.
9. Record Keeping
10-Four maintains AML-related records for a minimum of five (5) years or longer where required by law. Records may include identity documentation, transaction records, compliance assessments, and reporting documentation.
10. Reporting Obligations
All employees are required to report any knowledge or suspicion of money laundering or terrorist financing to the Designated Compliance Officer immediately. Failure to report suspicions may result in disciplinary action and potential criminal liability.
11. Training
The Company provides periodic AML/CFT training to relevant staff. Training includes identification of suspicious activity, reporting obligations, sanctions awareness, and internal escalation procedures. Training records are maintained for compliance purposes.
12. Designated Compliance Officer
10-Four appoints a Designated Compliance Officer responsible for oversight of the AML/CFT program, risk assessments, suspicious activity reporting, regulatory communication, and periodic policy review.
13. Internal Controls
The Company maintains internal controls including segregation of duties, payment verification procedures, monitoring systems, access controls, and periodic compliance testing to ensure adherence to legal and regulatory requirements.
14. Disciplinary Measures
Failure to comply with this Policy may result in disciplinary action, account suspension or termination, forfeiture of funds, regulatory reporting, and legal action where appropriate.
15. Policy Review
This AML Policy is reviewed periodically and updated as necessary to reflect changes in legal, regulatory, or operational requirements.