Anti money laundering (“AML”) policy

Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicions.

Within the EU including the UK, it is estimated that more than €50 billion is laundered annually and globally, in terms of revenue, the amount of money laundered would make it the third largest industry in the world. In response to the scale and effect of money laundering, many countries have passed legislation designed to prevent money laundering and to combat terrorism.

This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML obligations and outline the offences and penalties for failing to comply. DAX Malta Ltd is regulated and has implemented systems and procedures that meet the global best practises of AML legislation. This decision reflects our company’s desire to prevent money laundering and not be used by criminals to launder proceeds of crime.


The DAX Malta Ltd AML Policy is designed to prevent money laundering by meeting AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

  • The appointment of a Chief Compliance Officer (CCO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
  • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employees 


DAX Malta Ltd is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. DAX Malta Ltd will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.