Effective Date: Sept 15, 2024
Last Updated: June 3, 2026
1. Introduction
Mockapital is committed to maintaining appropriate Anti Money Laundering (AML) and Counter Terrorism Financing (CTF) controls. As a simulated trading and evaluation services provider, Mockapital recognizes the importance of detecting and preventing money laundering, terrorism financing, sanctions evasion, fraud, and other illegal financial activities. This policy is designed to support Mockapital’s adherence to applicable AML, CTF, sanctions, and related compliance requirements in the UAE and internationally.
2. Regulatory and Sanctions Compliance
Mockapital is committed to complying with relevant AML regulations and counter terrorism financing requirements as applicable to its operations. We may adhere to:
UAE AML Requirements: Compliance with applicable AML laws, regulations, and requirements as relevant to Mockapital’s operations.
International Standards: Following relevant international standards and guidance, including those established by organizations such as the Financial Action Task Force (FATF), U.S. OFAC, the United Nations, and the European Union, where applicable.
Mockapital may screen customers and transactions against relevant sanctions lists, including UN Sanctions, OFAC, EU Sanctions, and other applicable lists, to identify prohibited individuals, entities, jurisdictions, or activities. If a confirmed match is found, Mockapital may freeze, suspend, reject, restrict, or terminate the account and report the matter where required by law.
3. Customer Due Diligence (CDD)
Mockapital may implement appropriate Customer Due Diligence (CDD) measures to understand the nature and purpose of customer relationships. This may include verifying the identity of customers using reliable and independent sources and monitoring customer activity for suspicious patterns.
Know Your Customer (KYC): Mockapital may obtain necessary documentation to verify the identity of clients, including government issued identification, proof of address, and relevant company information where applicable.
Ongoing Monitoring: Mockapital may monitor customer accounts, payments, payouts, and activity, particularly where activity appears large, unusual, inconsistent, suspicious, or linked to financial crime risks.
4. KYC Verification Timing and Control Provider
Mockapital collects basic client information during account registration and account purchase. Full KYC verification is required after a trader successfully completes the evaluation challenge and before access to a Simulated Funded Account is granted.
No trader will be provided access to a Simulated Funded Account until full KYC verification has been completed and approved. Traders who do not complete or pass KYC verification will not be eligible to receive access to a Simulated Funded Account or any related payout.
Mockapital may also request KYC verification or additional supporting documents at an earlier stage if a transaction, payment pattern, jurisdiction, account activity, or other risk indicator raises compliance concerns.
Mockapital uses Veriff as its identity verification and KYC control provider. Veriff supports customer identity verification through document checks and, where applicable, additional verification measures such as liveness checks, sanctions screening, politically exposed person screening, adverse media screening, and other risk based verification controls.
Mockapital may use the results of these checks to approve, reject, suspend, restrict, or further review a customer relationship in accordance with its AML, CTF, sanctions, and risk management obligations.
5. Prohibited Jurisdictions and Citizens
Mockapital does not onboard, serve, or provide accounts to individuals or entities located in, residing in, incorporated in, operating from, or holding citizenship from prohibited jurisdictions.
At a minimum, Mockapital prohibits customers connected to the following jurisdictions and territories: Algeria, Angola, Bulgaria, Burkina Faso, Cameroon, Côte d’Ivoire, Croatia, Cuba, Democratic People’s Republic of Korea (North Korea), Democratic Republic of Congo, Haiti, Iran, Kenya, Lebanon, Libya, Mali, Monaco, Mozambique, Myanmar, Namibia, Nigeria, Philippines, Russia, Somalia, South Africa, South Sudan, Sudan, Syria, Tanzania, Venezuela, Vietnam, Yemen, Belarus, Crimea, and the occupied parts of Donetsk, Luhansk, Zaporizhzhia, and Kherson.
Mockapital may update this list from time to time in line with applicable sanctions, regulatory requirements, payment partner requirements, platform provider requirements, verification provider requirements, and internal risk controls.
Customers from prohibited jurisdictions, or citizens of prohibited jurisdictions, will not be permitted to proceed with Mockapital services. If such a connection is identified after registration, purchase, challenge completion, payout request, or during any later review, Mockapital may reject the customer, suspend the account, cancel access, freeze activity, request additional documentation, deny payout eligibility, or take any other action required under applicable law, sanctions obligations, payment provider requirements, or internal compliance procedures.
6. Enhanced Due Diligence (EDD)
Mockapital adopts a risk based approach to compliance. Enhanced Due Diligence (EDD) may be applied selectively based on indicators of higher risk, including:
- Customers from high risk jurisdictions.
- Customers exhibiting unusual or suspicious behaviour.
- Politically Exposed Persons (PEPs).
- Multiple transactions or attempts to evade normal procedures, such as paying from different sources for the same challenge.
- Unusual payment behaviour, inconsistent identity information, sanctions exposure, or attempts to conceal location, nationality, ownership, or source of funds.
If any of these risk indicators are detected, Mockapital may review the customer relationship and request additional documentation or clarification to support compliance requirements.
7. Country Risk Matrix
Mockapital maintains a country risk based approach for customer onboarding and monitoring. Countries may be classified as low risk, medium risk, high risk, or prohibited based on sanctions exposure, FATF status, AML and CTF risk, regulatory restrictions, payment partner requirements, and internal business risk considerations.
Customers from high risk jurisdictions may be subject to Enhanced Due Diligence, additional documentation requests, manual compliance review, or rejection where the risk cannot be appropriately managed.
The prohibited jurisdiction list overrides the country risk matrix. Customers linked to prohibited jurisdictions will not be accepted regardless of other risk factors.
8. Record Keeping
Mockapital may retain records of customer identification documents, verification results, transaction records, and relevant correspondence for a minimum of five years, or longer where required by applicable law, regulatory requirements, payment partner requirements, dispute handling, fraud prevention, or internal compliance procedures.
9. Suspicious Activity Reporting (SAR)
Mockapital is committed to monitoring suspicious activity and taking appropriate action where required.
Monitoring Transactions: Transactions may be reviewed for unusual patterns, large sums, high risk jurisdictions, atypical payment structures, or other risk indicators.
Reporting Suspicious Activity: Where required by applicable law or relevant compliance obligations, Mockapital may report suspicious activity to the appropriate authority, regulator, payment provider, compliance provider, or other relevant party.
Cooperation with Authorities: Where legally required, Mockapital may cooperate with relevant authorities and may take appropriate action, including freezing, suspending, rejecting, or restricting accounts.
10. Responsibilities of Employees
All employees and contractors of Mockapital are required to adhere to the provisions of this AML Policy. Specific responsibilities include:
Compliance Officers: Ensuring the implementation of this policy and overseeing customer due diligence, transaction monitoring, sanctions screening, escalation, and reporting.
Front Line Staff: Supporting customer verification procedures and remaining vigilant in identifying suspicious behaviour, unusual transactions, or risk indicators.
Training and Awareness: Employees may receive AML training to ensure they are aware of money laundering, terrorism financing, sanctions, and fraud risks, along with appropriate mitigation steps.
11. Risk Based Approach
Mockapital adopts a risk based approach to AML, ensuring that higher risk customers, transactions, jurisdictions, and business relationships receive enhanced scrutiny. Risk may be assessed based on factors such as:
- The customer’s country of origin, residence, citizenship, and operating location.
- The customer’s business activity, industry, and profile where applicable.
- The transaction size, frequency, source, and pattern.
- Any sanctions, PEP, adverse media, or other risk indicators identified during screening or monitoring.
12. Review and Auditing
Mockapital’s AML Policy may be reviewed on an annual basis or as required by changes in regulations, sanctions requirements, payment partner requirements, or business practices. Internal reviews may be conducted to assess compliance with AML procedures and identify areas for improvement.
13. Conclusion
Mockapital is committed to maintaining a compliant environment that helps prevent money laundering, terrorism financing, sanctions evasion, fraud, and other illegal financial activity. By following this policy and working with legal experts, compliance providers, payment partners, and AML professionals where appropriate, Mockapital aims to protect its business and support the integrity of its services.
This AML Policy should be read together with Mockapital’s main Terms and Conditions, Privacy Policy, Website Terms of Use, program rules, and any other policies published on the Mockapital website or dashboard.
14. Contact Information
For any further inquiries, please contact our Compliance Team at:
Email: compliance@mockapital.com
