Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

1. Purpose and Scope

The purpose of this policy is to describe the principles that guide Titan Capital's approach to anti-money laundering, countering the financing of terrorism and countering proliferation financing (AML/CFT/CPF).

The policy applies to customer onboarding and the ongoing customer relationship, subject to applicable laws and regulatory requirements. It should be read alongside the applicable account-opening documents, customer agreements, risk disclosures and other relevant policies.

Titan Capital maintains its AML/CFT/CPF framework in accordance with the legal and regulatory requirements applicable to its business.

2. Customer Identification and Verification

Customers must provide complete, accurate and current information during the account-opening process.

Depending on the customer type and applicable requirements, information and documentation may include:

• Identity documents and personal particulars.
• Residential or registered address and contact details.
• Occupation, business activity and source of income.
• Information about the purpose and intended nature of the customer relationship.
• Financial information relevant to the customer's circumstances and intended trading activity.
• Additional documents or information required for verification and due diligence.

Information provided by a customer may be verified using appropriate documents, verification methods and other reliable sources, as permitted or required by applicable law and regulatory requirements.

Account opening and access to services are subject to satisfactory completion of the applicable onboarding, verification and approval procedures.

3. Individual and Corporate Customers

Due diligence requirements may vary depending on whether a customer is an individual, a company or another legal arrangement.

For individual customers, we may require information to establish identity, address, occupation, source of income and other relevant particulars.

For corporate and other legal-entity customers, we may require incorporation or registration documents, information about the entity's business and ownership structure, identification of beneficial owners, and details of directors, authorised representatives or other persons exercising control, as applicable.

We may request additional documentation or clarification where necessary to establish the customer's identity, ownership, control or authority to act.

4. Source of Funds and Financial Information

Customers may be required to provide information and supporting documents concerning the source of their funds, source of income or wealth, financial circumstances and intended trading activity, where applicable.

Such information helps us assess whether the customer relationship and proposed activity are consistent with the information provided and the applicable risk assessment.

Customers must provide truthful information and respond to reasonable requests for supporting documentation. Where information is incomplete, inconsistent or cannot be satisfactorily verified, further checks may be required before an account is opened or services are provided.

5. Customer Funding and Withdrawals

Customer funds must be transferred through the funding channels and procedures prescribed by PMEX and applicable regulatory requirements.

Customers should fund their PMEX trading accounts through their own bank accounts registered in accordance with the applicable PMEX procedures. Customers must follow the prescribed payment methods and account instructions and must not use a third party's bank account to fund their trading account where prohibited by applicable requirements.

Customers should verify the beneficiary details and payment instructions before making a transfer. They should not transfer trading funds to an employee's personal account or to an account that has not been authorised for the relevant purpose.

Deposits, withdrawals and related transactions may be subject to verification and review in accordance with applicable requirements. Additional information or supporting documents may be requested where necessary.

6. Risk Assessment and Enhanced Due Diligence

Customer relationships are assessed in accordance with applicable risk-based requirements. Relevant factors may include the customer's identity, ownership and control structure, business activities, geographic connections, source of funds, expected activity and other relevant risk indicators.

Where a customer or transaction presents an elevated risk, additional due diligence and appropriate review may be required.

Enhanced checks may include obtaining further information about the customer or beneficial owner, establishing the source of funds or wealth, seeking additional supporting documents and obtaining the approvals required under applicable procedures.

Where required, a customer relationship may be declined, restricted or discontinued in accordance with applicable law and regulatory requirements.

7. Politically Exposed Persons and Sanctions

Additional checks may apply to politically exposed persons (PEPs), their relevant family members or close associates, where required under applicable law and regulatory requirements.

Titan Capital applies relevant sanctions and targeted financial sanctions requirements in accordance with applicable Pakistani law and binding regulatory directions.

Where screening identifies a potential match or other concern, appropriate verification, review and action may be required. Any applicable restrictions, reporting obligations or other measures will be handled in accordance with the relevant legal and regulatory requirements.

8. Ongoing Monitoring and Customer Information Updates

Customer due diligence is not limited to the account-opening stage.

Where required and appropriate, customer information and account activity may be reviewed on an ongoing basis. Reviews may consider changes in customer circumstances, transaction patterns, the consistency of activity with the information available, and other relevant risk indicators.

Customers must promptly notify Titan Capital of material changes to information previously provided, including changes to contact details, occupation, business activities, beneficial ownership or authorised representatives, as applicable.

Additional information or documentation may be requested to keep customer records accurate and to satisfy applicable due diligence requirements.

9. Suspicious Activity and Regulatory Reporting

Titan Capital takes concerns about potential money laundering, terrorist financing and proliferation financing seriously.

Where activity or information gives rise to suspicion, it may be subject to further review and appropriate action under applicable internal procedures and legal requirements.

Reports will be submitted to the relevant competent authority where required by applicable law. Information concerning reviews, investigations or reports will be handled in accordance with applicable confidentiality and legal requirements.

Nothing in this policy limits the obligation to comply with lawful directions, reporting requirements or requests from competent authorities.

10. Recordkeeping and Confidentiality

Customer identification records, due diligence documentation, account information and relevant transaction records will be maintained and retained in accordance with applicable legal and regulatory requirements.

Customer information will be handled with appropriate care and used for legitimate business, verification, compliance and regulatory purposes, subject to applicable law.

Information may be disclosed to PMEX, SECP, other competent authorities or other authorised recipients where required or permitted by applicable law or regulatory requirements.

11. Customer Responsibilities

Customers are expected to:

• Provide accurate, complete and truthful information during account opening and throughout the customer relationship.
• Submit genuine, valid and current identification and supporting documents.
• Provide additional information or documents when reasonably required for due diligence and verification.
• Keep their personal, financial and account information up to date.
• Use permitted funding channels and follow applicable PMEX funding procedures.
• Cooperate with lawful verification, compliance and regulatory requirements.

Failure to provide required information, an inability to complete satisfactory verification, or concerns arising under applicable requirements may result in an account-opening application being declined or services being delayed, restricted or discontinued, subject to applicable law.

12. Compliance with Applicable Laws and Regulations

This policy is intended to reflect the principles applicable to Titan Capital's AML/CFT/CPF obligations as a participant in Pakistan's regulated financial markets.

The applicable framework may include the Anti-Money Laundering Act, 2010, as amended; the Securities and Exchange Commission of Pakistan's AML/CFT/CPF Regulations, 2020, as amended; applicable futures-market legislation and regulations; relevant PMEX rules, regulations and directives; and other applicable legal requirements.

References to laws and regulations are subject to their applicability, amendments, replacement and interpretation by the competent authorities.

13. Policy Review

This policy may be reviewed and updated when necessary to reflect changes in applicable laws, regulatory requirements, PMEX procedures or Titan Capital's business and compliance arrangements.

The version published on this website is intended to communicate Titan Capital's public-facing AML/KYC principles. It does not replace the applicable account-opening documents, contractual terms, internal compliance procedures or obligations imposed by law or regulatory authorities.

Questions and Enquiries

For questions relating to account opening, customer verification or the information required to establish a trading account, please contact Titan Capital through the official contact channels listed on this website.