AML Policy

By applying for an account with Sprint Markets Limited, You (hereinafter ‘Client’ or ‘Wholesale Client) are taken to agree to the following terms:

1. You warrant that You comply with all applicable anti-money laundering laws and regulations, including but not limited to the AML/CTF Act and associated rules and regulations (in force from time to time);
2. You are not aware and have no reason to suspect that:
   1. the money used to fund Your deposit in Your account has been or will be derived from or related to any money laundering or other activities deemed illegal under applicable laws or regulations or otherwise prohibited under any international convention or agreement (hereinafter ‘illegal activities’); or
   2. the proceeds of Your investment in the fund will be used to finance illegal activities; and
   3. You agree to promptly provide us with all information that we reasonably request in order to comply with all applicable laws and regulations relating to anti-money laundering.

Sprint Markets Limited provides services to overseas professional wholesale entities only. If You satisfy either of the below mentioned criteria and provide us with supporting documents, You may be eligible to opt up to become a Wholesale Client and have an account with Sprint Markets Limited.

1. Net asset/Turnover test: an entity to which at least 1 of the following applied at the end of each of the last 2 completed accounting periods:
   1. at the balance date, the net assets of the entity exceeded $1 million NZD;
   2. the turnover of the entity for the accounting period exceeded $1 million NZD.
2. Wholesale investor test (developed on the basis of the Financial Markets Conduct Act 2013 and the Financial Service Providers Act 2008):
   1. the person is an investment business:
      1. an entity whose principal business consists of 1 or more of the following: 1) investing in financial products; or acting as an underwriter; or 2) providing a financial advice service; or 3) providing a client money or property service; or 4) trading in financial products on behalf of other persons; or
      2. a registered bank; or
      3. an NBDT; or
      4. a licensed insurer; or
      5. a manager of a registered scheme, or a discretionary investment management service, that holds a market services license; or
      6. a derivatives issuer that holds a market services license; or
      7. a financial adviser.
   2. the person meets the investment activity criteria, if at least 1 of the following paragraphs applies:
      1. the person owns, or at any time during the 2-year period before the relevant time has owned, a portfolio of specified financial products of a value of at least $1 million NZD (in aggregate),
      2. the person has, during the 2-year period before the relevant time, carried out 1 or more transactions to acquire specified financial products where the amount payable under those transactions (in aggregate) is at least $1 million NZD and the other parties to the transactions are not associated persons of that person.
   3. the person is large, if at least 1 of the following paragraphs applies:
      1. as at the last day of each of the 2 most recently completed financial years of the person before the relevant time, the net assets of the person and the entities controlled by the person exceeded $5 million NZD,
      2. in each of the 2 most recently completed financial years of the person before the relevant time, the total consolidated turnover of the person and the entities controlled by the person exceeded $5 million NZD.
   4. the person is a government agency
   5. the person is a wholesale investor, in relation to an offer of financial products, if—
      1. the person is an eligible investor, – that means
         1. the Client certifies in writing that the Client understands that, as a consequence of certifying himself, herself, or itself to be an eligible investor, Sprint Markets Limited may not be a member of an approved dispute resolution scheme; and
         2. the Client states the reasons for this certification; and
         3. Sprint Markets Limited signs a written acceptance of the certification; or
      2. in relation to an offer of financial products for issue or sale,—
         1. the minimum amount payable by the person on acceptance of the offer is at least $750,000 NZD; or
         2. the amount payable by the person on acceptance of the offer plus the amounts previously paid by the person for financial products of the issuer of the same class that are held by the person add up to at least $750,000 NZD; or
         3. it is proposed that the person will acquire the financial products under a bona fide underwriting or sub-underwriting agreement;
      3. in relation to an offer of a derivative for issue or sale, the notional value of the derivative is at least $5 million NZD.

This minimum information about the Client for fulfillment of Sprint Markets Limited AML obligations may include:

1. full legal name, identifier or registration number, current permanent address and/or registered office;
2. full list of shareholders and beneficiaries, their names, registration numbers, addresses;
3. list of beneficial owners and their details as requested by Sprint Markets Limited for natural persons;
4. the origin of the funds to be used for trading;
5. purpose of opening accounts.

In order to verify the abovementioned information Sprint Markets Limited will require submitting the following documents regarding the Client:

1. certificate of Incorporation or any national equivalent;
2. memorandum and Articles of Association and statutory statement or any national equivalent;
3. certificate of good standing or other proof of registered address of the company;
4. resolution of the board of directors to open an account and confer authority on those who will operate it;
5. copies of powers of attorney or other authorities given by the directors in relation to the company;
6. proof of identity of directors in case he/she will deal with Sprint Markets Limited on behalf of the Client (according to the Individual identity verification rules described above);
7. proof of identity of the beneficial owner(s) and/or the person(s) on whose instructions the signatories on the account are empowered to act (according to the Individual identity verification rules described above).