1. Commitment
Cirqle LTD has a zero-tolerance approach to money laundering, terrorist financing, fraud, and the evasion of international sanctions. We comply with the EU's 6th Anti-Money Laundering Directive, the Cyprus Prevention and Suppression of Money Laundering Activities Law, and FATF recommendations.
2. Customer due diligence (CDD)
Every user undergoes a tiered verification process:
- Tier 1 (instant): verified email + Google sign-in. Demo trading and live trading up to $500 cumulative deposit / month.
- Tier 2 (light KYC): government-issued ID + selfie. Up to $5,000 / month.
- Tier 3 (full KYC): Tier 2 + proof of address dated within 3 months + source-of-funds declaration. Unlimited (subject to risk review).
3. Enhanced due diligence (EDD)
EDD applies when:
- The customer is a Politically Exposed Person (PEP) or close family member of a PEP.
- The customer is established in a high-risk third country.
- Transactions are unusually large, complex, or have no apparent economic purpose.
- The customer requests anonymity, refuses identification, or uses obfuscation services.
4. Transaction monitoring
All deposits, withdrawals and trades are monitored against rule-based and statistical models to detect:
- Structuring (multiple deposits just below reporting thresholds).
- Rapid in-out flow without trading.
- Use of mixers, tumblers or sanctioned wallets (for crypto deposits).
- Coordinated bonus or funded-trader abuse across multiple accounts.
5. Sanctions screening
We screen all users at onboarding and on a recurring basis against: UN Consolidated, EU Restrictive Measures, OFAC SDN, and HM Treasury lists. Hits result in immediate freeze and review.
6. Reporting
Suspicious activity is reported to MOKAS (Cyprus FIU) within the statutory deadlines. We may not be able to inform you when a Suspicious Activity Report has been filed — "tipping off" is a criminal offence.
7. Record keeping
We retain KYC records for at least 5 years after the end of the business relationship, and transaction records for at least 7 years.
8. Your obligations
- Provide truthful, current information at onboarding and on request.
- Use only payment methods registered in your own name.
- Disclose if you become a PEP after registering.
- Do not facilitate trading on behalf of third parties.
9. MLRO contact
Money Laundering Reporting Officer (MLRO), Cirqle LTD
Email: cirqle@briceka.com (subject: "MLRO")
Questions? Contact cirqle@briceka.com or use the in-app live chat (bottom-left). Cirqle LTD is a company registered in the Republic of Cyprus.