Followme is not a brokerage firm, broker-dealer, or financial intermediary of any kind. Followme does not solicit, accept, hold, manage, or otherwise handle client funds, whether in the form of deposits, withdrawals, margin, or any other monetary instrument. At no point in the user journey does Followme take custody of, or exercise control over, any user's capital or trading funds.

All trading activities undertaken by users are conducted solely through their own independently chosen, third-party brokerage accounts, over which Followme exercises no authority, custody, or control. The platform provides a digital environment in which users may share experiences, discuss strategies, publish performance records, and engage with one another on trading-related topics.

1. Purpose, Scope & Commitment
  • Purpose: Establishes the principles, governance, and procedures Followme uses to prevent, detect, and report money laundering, terrorism financing, proliferation financing, and related financial crime risks.
  • Scope: Applies to all Followme business units, employees, contractors, affiliates, and platform features involving payments, sponsorships, creator payouts, tips, advertising, or other settlements.
  • Commitment: Followme maintains a robust, risk-based approach aligned with international standards and applies a zero-tolerance policy toward confirmed financial crime, sanctions breaches, fraud, and abuse.
2. Governance, Roles & Responsibilities
  • Board & Senior Management: Responsible for programme oversight, resource allocation, and annual effectiveness reviews.
  • Compliance/AML Officer (MLRO): Oversees AML/CTF compliance, suspicious activity reporting, programme maintenance, and liaison with authorities.
  • Employees & Contractors: Must complete AML training, follow procedures, and escalate suspicious activities promptly.
  • Independent Testing: AML/CTF controls are independently reviewed at least annually or after material operational changes.
3. Risk-Based Approach (RBA)
  • Enterprise Risk Assessment: Conducted and refreshed at least annually, covering customer, product/service, geography, delivery channel, and third party risks.
  • Risk Scoring: Users and counterparties are classified (e.g., low/medium/high) using objective criteria (KYC outcomes, sanctions/PEP/adverse media results, behaviour).
  • Controls: CDD/EDD, monitoring thresholds and approvals scale with risk; higher risk relationships receive additional scrutiny and senior management approvals.
  • New Products/Technologies: Prior to launch, Followme assess ML/TF/PF risks of new features (e.g., payments, wallets, tokenised assets) and implement mitigating controls.
4. Customer Due Diligence (CDD)
  • Identification & Verification: Users must provide accurate, complete, and up to date information at onboarding and upon changes. Followme verify identity using reliable, independent sources (e.g., government issued ID, passport, driving licence) and, where applicable, liveness checks and proof of address. Followme verify any natural person acting on behalf of a customer.
  • Beneficial Ownership: For legal entity customers, Followme identify and verify beneficial owners and controlling persons.
  • Purpose & Nature: Followme collect information sufficient to understand the intended purpose and nature of the relationship (e.g., monetisation, payouts, sponsorships).
  • Ongoing CDD: Records are maintained current and KYC is refreshed on triggers (profile changes, unusual activity, sanctions updates) or on a risk based cycle.
  • Politically Exposed Persons (PEPs): Procedures determine whether any customer, beneficial owner, connected party, or authorised representative is a PEP (domestic, foreign, or international organisation) or a family member/close associate. Followme apply EDD, including senior management approval and establishing source of wealth and source of funds where required.
5. Enhanced Due Diligence (EDD)
  • Triggers: Higher risk jurisdictions; complex/unusual transactions; PEPs (including family/close associates); adverse media; non face to face anomalies; exposure to self hosted wallets (where relevant).
  • Measures: Additional identity corroboration; verification of source of funds/wealth; tighter limits/transaction reviews; enhanced ongoing monitoring; and senior management approval where applicable.
6. Sanctions & Proliferation Financing Controls
  • Screening: Followme screen customers, beneficial owners, connected parties, authorised representatives and, where applicable, transacting counterparties against applicable targeted sanctions lists and designations.
  • Immediate Actions: Followme do not establish or continue relationships or process transactions involving designated persons or their owned/controlled entities. Where required by law, Followme freeze without delay and report to the competent authority.
  • Ownership & Control: Followme consider indirect ownership/control and attempts to evade screening (e.g., use of intermediaries or third party accounts).
7. Transaction & Behavioural Monitoring
  • Followme use rules and behavioural analytics to detect unusual patterns (e.g., rapid fund movement, structuring, circular flows, copy trading abuse, account takeovers). Alerts are triaged, investigated, documented, and escalated to the MLRO as appropriate. Where required by law, the MLRO files suspicious transaction/activity reports within statutory timelines. Tipping off is prohibited.
8. Cross-Border Transfers & Digital Asset Controls
  • If Followme introduces any digital-token, virtual-asset, or wallet-related functionality in the future, additional controls may apply in accordance with applicable laws and platform-specific terms.
  • Wire Transfers: For cross border wire transfers processed through our systems or arranged via partners, prescribed originator and beneficiary information must accompany the payment. Transfers with incomplete information may be rejected or held pending remediation.
  • Digital Token Value Transfers (Travel Rule): Where applicable, Followme will comply with the applicable Travel Rule thresholds, information requirements, and value-transfer obligations under the laws and regulatory guidance of the relevant jurisdiction:
    • Followme collect and securely transmit required originator and beneficiary information with the transfer.
    • For value transfers ≥ USD 1,500 (or equivalent), Followme transmit the full prescribed details; for lower amounts, Followme transmit, at minimum, names and account/wallet identifiers.
    • Followme screen both originator and beneficiary (and, where applicable, counterpart VASPs) before execution.
    • Followme decline, hold, or exit transfers where information is incomplete, a sanctions/AML hit is identified, or risk cannot be mitigated.
    • Self Hosted Wallets: Where interacting with self hosted wallets, Followme apply enhanced measures (ownership verification, purpose assessment, heightened monitoring) and consider suspicious activity reporting where warranted.
9. Record Keeping
  • Retention: CDD/EDD files, transaction records, and AML related reports are retained securely for at least seven (7) years after relationship end or transaction date, or longer where law requires.
  • Security & Confidentiality: Records are protected by access controls and encryption; disclosures are limited to authorised, lawful purposes.
10. Training & Awareness
  • Mandatory AML/CTF training is provided at onboarding and annually, tailored to role and risk. Training covers red flags, sanctions/TFS/PF, STR processes, data protection duties, and the prohibition on tipping off. Completion and competency records are retained.
11. Third-Party & Payment Partner Risk
  • Due Diligence: Followme assess and approve payment processors, payout providers, KYC vendors, and other partners prior to onboarding; contracts require equivalent AML/CTF standards, audit rights, and timely incident notifications.
  • Reliance: Where reliance on third party KYC is permitted by law, Followme ensure equivalence and immediate access to underlying CDD records.
12. Data Protection & Privacy
  • Processing for AML/CTF purposes follows applicable legal bases and our Privacy & Cookie Policy. Sensitive documents are stored securely and accessed strictly on a need to know basis. Where data is transferred across borders (e.g., hosting in Singapore), appropriate safeguards are applied.
13. Zero-Tolerance & Disciplinary Action
  • Breaches of this Policy or applicable AML/CTF laws may result in disciplinary action (up to termination), reporting to authorities, and other remedies. Followme cooperate with lawful requests consistent with our Law Enforcement & Transparency Policy.
14. Review & Continuous Improvement
  • This Policy and the enterprise risk assessment are reviewed at least annually and sooner upon material business, product, or regulatory change. Key risk indicators, audit outcomes, and regulatory feedback inform improvements.
15. Reporting Channels
  • Internal escalation (staff): escalate red flags immediately to the MLRO via internal channels.
  • User concerns: [email protected].
  • Regulatory filings: performed by the MLRO to the competent authority in the relevant jurisdiction within statutory timelines.
16. Contact Us