Our Compliance Framework

01 Regulatory Overview

Moorgan Trade Wealth is incorporated and operates from Larnaca, Cyprus, within the European Union. As an operator of AI-powered investment and cryptocurrency portfolio services, we are committed to adhering to all applicable EU and Cypriot financial regulations.

Our compliance framework is designed to meet the standards set by the following regulatory bodies and legal frameworks:

02 KYC — Know Your Customer

All users of the Moorgan Trade Wealth platform are required to complete a thorough identity verification process before accessing our services or making any investments. Our KYC process includes:

• Identity Verification: Government-issued photo ID (passport or national identity card)
• Proof of Address: Utility bill or bank statement dated within 3 months
• Source of Funds: Documentation demonstrating the legitimate origin of invested funds
• Enhanced Due Diligence (EDD): Applied to high-value investments or politically exposed persons (PEPs)

We periodically re-verify client information to ensure our records remain current, particularly for clients who significantly increase their investment amounts.

03 AML — Anti-Money Laundering

Moorgan Trade Wealth maintains a robust AML programme that complies with both Cypriot law and EU directives. Key components include:

• Transaction Monitoring: Automated systems flag unusual patterns, including sudden large deposits, rapid withdrawal requests, or round-number transactions inconsistent with investment activity.
• Suspicious Activity Reports (SARs): We are legally required to file SARs with the Cyprus Unit for Combating Money Laundering (MOKAS) when suspicious activity is identified.
• Blockchain Analytics: We use blockchain analytics tools to assess cryptocurrency wallet risk scores and trace transaction histories.
• Staff Training: All team members involved in client onboarding and transactions receive regular AML training.

Funds identified as potentially linked to illicit activity will be frozen pending investigation and may be reported to relevant authorities. We cooperate fully with law enforcement upon receipt of valid legal process.

04 Data Protection (GDPR)

As an EU-based operator, Moorgan Trade Wealth fully complies with the General Data Protection Regulation (GDPR — Regulation 2016/679). Our data protection commitments include:

• Appointing a Data Protection Officer (DPO) responsible for compliance oversight
• Maintaining a Record of Processing Activities (ROPA)
• Conducting Data Protection Impact Assessments (DPIAs) for high-risk processing activities
• Implementing data minimisation and purpose limitation principles
• Ensuring lawful bases for all data processing activities

Full details of how we handle personal data are set out in our Privacy Policy.

05 Risk Management

We maintain a comprehensive risk management framework to protect client assets and ensure operational resilience:

• Client Risk Profiling: Each investor completes a risk assessment during onboarding to ensure AI strategy settings are appropriate for their profile.
• Operational Risk Controls: Redundant systems, regular backups, and disaster recovery protocols to ensure platform availability.
• Cybersecurity: Ongoing penetration testing, vulnerability assessments, and incident response procedures. See our Online Safety page for more detail.
• Counterparty Risk: All third-party technology and service providers are vetted and subject to contractual compliance obligations.

06 Reporting Obligations

Moorgan Trade Wealth fulfils all mandatory reporting obligations under applicable law, including:

• Suspicious Transaction Reports (STRs) to MOKAS (Cyprus Financial Intelligence Unit)
• Large cash and cryptocurrency transaction reporting as required by regulation
• Annual compliance reports to relevant regulatory bodies
• Cooperation with CySEC and European Securities and Markets Authority (ESMA) supervisory requests

07 Sanctions Screening

Prior to onboarding and on an ongoing basis, all clients and beneficial owners are screened against international sanctions lists, including:

• EU Consolidated Sanctions List
• UN Security Council Consolidated List
• OFAC Specially Designated Nationals (SDN) List
• UK HM Treasury Financial Sanctions List

Any match results in immediate account suspension and reporting to the relevant competent authority. We do not provide services to sanctioned individuals, entities, or jurisdictions.

08 Contact Compliance Team

If you have compliance-related questions, wish to report a concern, or need to submit documentation, please contact us:

• Email: Tom@moorgantrade.com
• Address: T.Th. Kon. Palaiologou, Larnaca, Cyprus — P.O. Box 42281 6532

We take all compliance enquiries seriously and aim to respond within two (2) business days.