Placement: At this stage, the funds are turned into financial instruments, such as checks, bank accounts, and money transfers, or they can be used to buy high-value goods that can be resold. They can also be physically deposited in banks and non-bank institutions (e.g., exchange houses). To avoid suspicion, the launderer can make several deposits instead of depositing the entire sum at once. This form of placement is called smurfing.

Layering: The funds are transferred or moved to other accounts and financial instruments. It is done to disguise the origin and interrupt the tracking of the entity that carried out the multiple financial transactions. Moving funds and changing their form makes it difficult to track the money being laundered.

Integration: The funds are re-circulated as legitimate to purchase goods and services. BRILLANT CAPITAL MARKETS adheres to the principles of Anti-Money Laundering (AML) and actively prevents any action that targets or facilitates the legalization process of illegally obtained funds. The AML policy means preventing the use of the company's services by criminals for money laundering, terrorist financing, or other criminal activities.

To prevent money laundering, BRILLANT CAPITAL MARKETS does not accept or pay in cash under any circumstances. The company reserves the right to suspend the operations of any client that may be considered illegal or, in the opinion of the staff, related to money laundering.

Company Procedures:
BRILLANT CAPITAL MARKETS will ensure that it is dealing with a real or legal person. BRILLANT CAPITAL MARKETS also performs all the necessary measures in accordance with applicable laws and regulations issued by monetary authorities. The AML policy is implemented within FX of BRILLANT CAPITAL MARKETS by the following means:

Know Your Client (KYC) policy and due diligence
Monitoring customer activity
Maintaining registry records
Know Your Customer: Due to the company's commitment to AML and KYC policies, each customer must complete a verification procedure. Before BRILLANT CAPITAL MARKETS initiates any cooperation with the client, the company ensures that satisfactory evidence is presented, or other measures are taken to produce satisfactory proof of the identity of any client or counterparty. The company also applies increased scrutiny to clients who are residents of countries identified by credible sources as having inadequate AML standards, posing a high risk of crime and corruption, and beneficial owners whose funds are sourced from such named countries.

Valid passport (showing the first page where the photo and signature are clearly visible), or

Driving license with photograph, or

National identity card (showing both front and back)

Additionally, documents proving the current permanent address, such as utility bills or bank statements, containing the customer's full name and residence, are required. These documents must not be older than 3 months from the submission date.

Information regarding a client’s income, occupation, source of wealth, trading habits, and the economic purpose of any transaction is typically gathered as part of the provision of advice. At the start of the relationship personal information is also obtained such as nationality, date of birth, and residential address. These pieces of information should also be considered concerning the risk of financial crime (including AML and CTF). For high-risk transactions, it might be appropriate to seek verification of the information the client has provided.

Customer Risk

Different customer profiles have different levels of risks attached to them. A basic Know your Customer (KYC) check can establish the risk posed by a customer.

For example, near-retired individuals making small, regular contributions to a savings account in line with their financial details pose less of a risk than middle-aged individuals making ad-hoc payments of ever-changing sizes into a savings account that does not fit into the profile of the customers’ standing financial data. The intensity of the due diligence conducted on the latter would be higher than that carried out on the former as the potential threat of money laundering in the second case would be perceived as being greater. Corporate structures can be used as examples of customers that could carry a higher risk profile than the one just seen, as these can be used by criminals to introduce layers within transactions to hide the source of the funds, and like that, clients can be categorized into different risk bands.

Product Risk

This is the risk posed by the product or service itself. The product risk is driven by its functionality as a money-laundering tool. The Joint Money Laundering Steering Group has categorized the products with which firms typically deal into three risk bands – reduced, intermediate and increased. Typically, pure protection contracts are categorized as reduced risk and investments in unit trusts as increased risk. Additionally, a factor that will contribute to the classification of the risk category is the sales process associated with the product. If the transaction in the product takes place on an advisory basis as a result of a KYC, this will carry less risk than an execution-only transaction, whereby you know significantly less about the customer.

Country Risk

The geographic location of the client or origin of the business activity has a risk associated with it, this stems from the fact that countries around the globe have different levels of risk attached to them.

A firm would determine the extent of their due diligence measure required initially and on an ongoing basis using the above four risk areas.

The Company is not responsible for the processing activities of such third-party sites and to re-direct the user to such third parties’ privacy notices and relevant policies.

By breaching this provision, you would commit a criminal offense under the Convention on Cybercrime. We will report any such breach to the relevant law enforcement authorities, and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, or other technologically harmful material that may infect your computer equipment, computer programs, data, or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical). We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor, or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not foolproof. Minors who are using any interactive service should be made aware of the potential risks to them. The company is prohibiting providing services to minors under the age of 18. Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Contributions to our site must not:

Contain any material which is defamatory of any person
Contain any material which is obscene, offensive, hateful, or inflammatory
Promote sexually explicit material
Promote violence
Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation, or age
Infringe any copyright, database right, or trademark of any other person
Be likely to deceive any person
Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence
Promote any illegal activity
Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience, or needless anxiety
Be likely to harass, upset, embarrass, alarm, or annoy any other person
Be used to impersonate any person, or to misrepresent your identity or affiliation with any person
Give the impression that they emanate from us if this is not the case
Advocate, promote, or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.
Any material you upload to our site will be considered non-confidential and non-proprietary, and we have the right to use, copy, distribute and disclose to third parties any such material for any purpose. We also have the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to our site constitutes a violation of their intellectual property rights or their right to privacy.

Also, we reserve the right to investigate complaints and/or reported violations of the Terms and to take any action we may at our sole discretion deem appropriate, including but not limited to reporting any suspected unlawful activity to the appropriate law enforcement officials, regulators, or other parties, as applicable, and disclosing to them any information necessary or appropriate under the circumstances relating, among others, to user profiles, e-mail, and IP addresses, usage history, posted materials and traffic information.

We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by you or any other user of our site.
We have the right to remove any material or posting you make on our site if, in our opinion, such material does not comply with the content standards set out in our acceptable use policy.

Whenever you make use of a feature that allows you to upload material to our site, or to contact other users of our site, you must comply with our content standards. You warrant that any such contribution does comply with those standards, and you indemnify us for any breach of that warranty.

Contributions to our site must not:

Contain any material which is defamatory of any person
Contain any material which is obscene, offensive, hateful, or inflammatory
Promote sexually explicit material
Promote violence
Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation, or age
Infringe any copyright, database right, or trademark of any other person
Be likely to deceive any person
Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence
Promote any illegal activity
Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience, or needless anxiety
Be likely to harass, upset, embarrass, alarm, or annoy any other person
Be used to impersonate any person, or to misrepresent your identity or affiliation with any person
Give the impression that they emanate from us if this is not the case
Advocate, promote, or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.
Any material you upload to our site will be considered non-confidential and non-proprietary, and we have the right to use, copy, distribute and disclose to third parties any such material for any purpose. We also have the right to disclose your identity to any third party who is claiming that any material posted or uploaded by you to our site constitutes a violation of their intellectual property rights or their right to privacy.

Also, we reserve the right to investigate complaints and/or reported violations of the Terms and to take any action we may at our sole discretion deem appropriate, including but not limited to reporting any suspected unlawful activity to the appropriate law enforcement officials, regulators, or other parties, as applicable, and disclosing to them any information necessary or appropriate under the circumstances relating, among others, to user profiles, e-mail, and IP addresses, usage history, posted materials and traffic information.

We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by you or any other user of our site.
We have the right to remove any material or posting you make on our site if, in our opinion, such material does not comply with the content standards set out in our acceptable use policy.

Verification of the source of funds to ensure compliance with legal standards.
Assessment of clients identified as high-risk, including politically exposed persons (PEPs) or those from high-risk jurisdictions.
Approval from senior management for clients flagged as high-risk.

Continuous monitoring of client transactions to detect suspicious patterns, including unusual trading volumes or withdrawal behaviors.
Immediate flagging and review of transactions outside typical behavior.
Reporting any suspicious activities to relevant regulatory authorities.

Regular updates to clients’ risk profiles based on changes in trading behavior or financial circumstances.
Re-assessment of risk profiles following significant financial events such as large deposits or withdrawals.

Screening clients against global sanctions lists, including OFAC, UN, and EU watchlists.
Ongoing cross-checking against updated sanctions and blacklists to ensure compliance.