Anti-Money Laundering (AML) Policy

Halcyon Trader Funding LLC

Halcyon Trader Funding LLC is firmly committed to the prevention and active deterrence of money laundering, terrorist financing, and all illicit financial activities that could compromise regulatory compliance, investor trust, or the integrity of our operations. We fully adhere to all applicable anti-money laundering (AML) regulations and international standards and have implemented a compliance framework designed to protect the firm and its clients from financial crime.

This Anti-Money Laundering (AML) Policy outlines the principles, responsibilities, and procedures that support our efforts to maintain a secure and compliant trading environment.

Policy Objectives

The AML Policy at Halcyon Trader Funding LLC is designed to:

• Establish comprehensive procedures to detect, prevent, and report money laundering and terrorist financing.
• Define clear compliance responsibilities for all employees and associated personnel.
• Ensure that daily business operations are conducted in accordance with all applicable legal and regulatory requirements.
• Promote a corporate culture focused on ethical conduct and full compliance with financial crime legislation.

Definition of Money Laundering

Money laundering involves the process of concealing the origins of illegally obtained funds to make them appear legitimate. This process typically occurs in three stages:

• Placement – Introducing illicit funds into the financial system.
• Layering – Conducting complex financial transactions to obscure the source of the funds.
• Integration – Reintroducing the laundered funds into the legitimate economy through investments, purchases, or other means.

Money laundering is considered an intentional act. However, failure to report suspicious activity, particularly through gross negligence, may lead to liability under applicable laws.

Terrorist Financing

Terrorist financing involves the provision of funds for terrorist activities, regardless of the legality of the source of those funds. This may include donations, foreign sponsorship, business revenue, or personal income. While the motivations behind terrorist financing differ from those of traditional money laundering, the methods used—such as structuring, shell entities, and cash movement—are often the same. Detection is often more difficult due to smaller transaction amounts and complex funding structures.

Regulatory Compliance

Halcyon Trader Funding LLC complies with applicable anti-money laundering laws and regulations in the jurisdictions in which it operates, including but not limited to:

• The U.S. Bank Secrecy Act (BSA)
• The USA PATRIOT Act
• Office of Foreign Assets Control (OFAC) regulations
• Financial Crimes Enforcement Network (FinCEN) requirements
• FATF (Financial Action Task Force) Recommendations
• United Nations Security Council sanctions and directives

In the event of international expansion, Halcyon Trader Funding LLC will adopt country-specific AML frameworks as required by local authorities.

Transaction Monitoring

Halcyon Trader Funding LLC utilizes a comprehensive transaction monitoring system designed to detect and flag unusual or suspicious financial activity. All transactions are reviewed manually using daily transaction logs. Identity verification is conducted via secure platforms such as Veriff. Development is underway to implement real-time, automated transaction monitoring to further enhance detection capabilities and reduce manual review times.

Suspicious Activity Detection

The company employs risk-based criteria to detect potentially suspicious activities, including:

• High-volume or high-frequency transactions inconsistent with account behavior
• Unusual funding patterns
• Use of multiple accounts or payment methods to bypass limits
• Transactions originating from high-risk jurisdictions

All alerts and anomalies are escalated to compliance staff for further investigation and, if necessary, external reporting.

Reporting Suspicious Transactions

Halcyon Trader Funding LLC complies with all regulatory obligations to report suspicious activity. Any identified activity that appears inconsistent with a client’s known behavior or that could indicate criminal conduct is reported promptly to the appropriate financial intelligence unit or law enforcement authority in the relevant jurisdiction. In the United States, reports are made through FinCEN. Reports are submitted securely and in compliance with all relevant laws.

Document Retention

Halcyon Trader Funding LLC maintains secure records of all AML-related activities for a minimum of five (5) years. These records include:

• Customer identification and verification documentation
• Transaction history
• Compliance reviews and escalations
• Internal audit reports
• Records of suspicious activity reports (SARs)

These records are available for inspection by regulatory authorities and internal auditors as required.

Customer Due Diligence (CDD)

A risk-based approach is applied to all customers. This includes:

• Initial risk rating of each customer at the time of onboarding
• Ongoing monitoring of account activity
• Enhanced Due Diligence (EDD) for customers identified as high-risk

Additional documentation, source of funds verification, and more frequent monitoring apply to higher-risk profiles. All clients must pass identity verification before funding accounts.

Non-Compliance and Sanctions

Failure to comply with AML requirements may result in severe consequences, including:

• Immediate suspension or termination of account access
• Internal investigation and documentation of findings
• Reporting to financial regulators and law enforcement
• Monetary fines or penalties
• Legal proceedings against responsible parties

Halcyon Trader Funding LLC maintains a zero-tolerance policy for AML violations.

Employee Training

All employees and contractors are required to complete AML training on an annual basis. This training covers:

• How to identify suspicious transactions
• How to escalate and report suspicious activity
• Current money laundering techniques and red flags
• Legal obligations under AML laws

Records of attendance and training materials are maintained in accordance with regulatory guidelines. Employees are required to remain current with new regulatory developments and compliance expectations.

Compliance Oversight

Halcyon Trader Funding LLC has appointed a Designated Compliance Officer responsible for:

• Overseeing the implementation and enforcement of the AML program
• Managing suspicious activity escalations
• Ensuring timely and accurate reporting to regulatory agencies
• Conducting internal audits and compliance testing

The Compliance Officer is supported by a dedicated Risk & Compliance Team tasked with the ongoing review of internal controls, training effectiveness, and procedural improvements.

Prohibition on Shell Entities

Halcyon Trader Funding LLC does not enter into or maintain relationships with shell banks or entities that do not have a physical presence in a regulated jurisdiction. We conduct enhanced due diligence on all business relationships to ensure transparency and legitimacy.

Ongoing Review and Program Effectiveness

The AML Policy is reviewed at least annually and updated as necessary to remain compliant with changing laws and regulations. Compliance testing is conducted regularly to ensure adherence to policy and to identify areas for improvement.

Contact

For any inquiries regarding this policy or to report suspicious activity, please contact the Compliance Department at info@halcyontraderfunding.com.