Question 1

What is Freemarket's risk appetite?

Accepted Answer

Freemarket’s risk appetite is the aggregate level of risk that it is willing to assume within its risk capacity and in line with the business model, culture and ethics. Freemarket takes an appropriate risk-based approach to achieve its strategic and commercial objectives. The aim of this document is to provide guidelines on what types of business and associated risks the company would find acceptable and unacceptable.

Within the overall risk framework, Freemarket has robust systems and controls that are proportionate to the nature and scale of the business, and which continually evolve to mitigate financial crime. With these systems and controls, Freemarket aims to Deter, Detect and Disrupt financial crime. Maintaining these and treating customers fairly, is at the heart of Freemarket and such standards are expected from all stakeholders. Freemarket has stringent procedures regarding the governance of its risk framework and strict policies in relation to PEP’s, illegal activity, sanctioned counterparties, criminals, and individuals associated with terrorism. In recognition of the scale and extent of the business’s systems and policies, Freemarket prohibits payments from the following activities:

Understanding what’s prohibited

In recognition of the scale and extent of the business’s systems and policies, Freemarket prohibits engaging or pursuing clients that fall within the following set of criteria.

Prohibited Locations

Onboarding of a company with any UBO’s, Directors or Operations resident in or websites targeting the following sanctioned countries: Iran, North Korea, Syria, Cuba, Venezuela, Russia.

You can view our unsupported jurisdictions list for a full list of countries we do not do business in or with.

Prohibited Businesses

The following list of categories of businesses and business practices are explicitly prohibited from using our services and platform:

Businesses operating or running Hawala (informal banking system)
Companies engaged in or providing illegal drugs and / or unlicensed drug related activity
Unregulated pharmaceuticals / food supplement companies (nutraceuticals)
Activities relating to defence and munitions, including dual use
Adult websites or services with prostitution, and the broadcasting/publication of pornography
Binary Options or unregulated investment and / or payment services activities
Companies formed of bearer shares
Company structures which include solely nominee directors; there must always be individual directors
Companies dealing in counterfeit goods
Cultural artefacts, ivory or other items related to protected species, or archaeological, historical, and religious significance, or of rare scientific value
Companies structured and operating on Piracy or illegal streaming
Political / religious organisations engaged in hate speech
Pyramid Schemes / multi-level marketing (MLM)
Companies dealing in non-electronic funds
Unregulated or Shell Banks
Shell companies (a company having no physical presence, no employees or no commercial activity in its registered jurisdiction)
‘Get rich quick’ schemes (proposal to pay high rates of return over a small period in return for a small investment)
Unregulated charities
Banks not located/domiciled onshore

Additional requirements for the following industries

Clients who fall into any one of the four verticals identified below must meet an initial set of criteria and further set of vertical specific criteria to onboard with Freemarket.

Initial risk assessment criteria

Must have no AML/CTF failings/fines that have not been sufficiently remediated
Must adhere to Freemarket’s Industry specific policies i.e. FI Control Framework, Gambling Policy, Crypto Policy
Must adhere to regulatory limitations applicable to the jurisdiction of their client-base

Further risk assessment criteria by vertical

The following are the additional risk assessment criteria to evaluate prospective clients by.

Question 2

How does Freemarket safeguard my money?

Accepted Answer

Freemarket holds clients’ money in safeguarding accounts with its banking partners. These funds are held separately from Freemarket’s own operational funds and working capital. Freemarket’s banking partners are required to warranty that the safeguarded funds will not be used to satisfy or offset any other obligation including those obligations imposed on Freemarket itself. This means that the funds can only be used to make payment for the underlying Payment Services User. If that instruction is unable to be complied with, Freemarket must return the funds to the original source.

Freemarket does not maintain a safeguarding account for each individual client. Rather, Freemarket holds pooled accounts in the name of “FreemarketFX Ltd Client Accounts” in each currency for the purpose of providing payment services.

Individual clients’ funds in safeguarding accounts are identified through your Freemarket virtual payment account number and/or virtual reference number. These records are used to reconcile credit, debit and balance transactions each day such that (i) the recorded positions individually show what amount of the total balances held is attributable to you; and (ii) the individual amounts recorded in virtual accounts add-up to the total balance held in the real account. Freemarket also moves fees and charges out of the safeguarding account to its own account as it is required to do so at least daily.

Freemarket’s banking partners are credit institutions authorised in the UK and in the European Economic Area.

Question 3

What are your unsupported jurisdictions?

Accepted Answer

Freemarket take a risk-based approach to managing transactional risk. Thus, as Freemarket is regulated by the Financial Conduct Authority (FCA), we take our regulatory responsibilities very seriously, and therefore, on certain occasions, we aren’t able to receive and/or send funds from certain jurisdictions, although this may be subject to change in the future.

If you have any questions about making cross-border payments to restricted jurisdictions, please contact your Relationship Manager, or contact us on support@wearefreemarket.com.

Question 4

Do you have a customer complaints procedure in place?

Accepted Answer

At Freemarket, we always aim to provide you with the best standards of service when using our product.

Our customer service representatives are available at all times to help with your inquiries. Freemarket recognises that in rare circumstances, our service might not have lived up to your expectations. If this is the case, we sincerely apologise if you feel that we have let you down. We will continue to do all in our power to make things right with you.

Freemarket has a complaints mechanism in place to make sure that we handle complaints and enquiries properly as a fully regulated business. Our regulators at the Financial Conduct Authority (FCA) and the Financial Ombudsman Service (FOS) have provided suggestions and regulations that have guided the creation of the complaint procedure below.

The Head of Compliance will acknowledge and investigate each complaint. A complainant must first submit their complaint to Freemarket, and if they are dissatisfied with the outcome, they may be permitted to submit their complaint to the Financial Ombudsman. You may not be able to file a complaint with the Financial Ombudsman if you agree to our corporate terms and conditions.

To ensure that we have an audit trail and that we have all the facts to help us understand your case, we request that you email support@wearefreemarket.com with the details of your complaint, including your account number (beginning with an ‘A’).

We will then:

Send you written acknowledgement that your complaint has been received;
Contact you further should we require any additional details;
Fully investigate your case and your concerns, followed by issuing a detailed response including an explanation of our decisions and reasons for said decision. If you remain dissatisfied with our response, you have the right to forward your concerns to the Financial Ombudsman Service.

Please note: we always encourage you to allow us to undergo our internal complaints procedure before referring your concerns to the Financial Ombudsman.

Email: complaint.info@financial-ombudsman.org.uk
Mail: The Financial Ombudsman Service (UK), Exchange Tower, London, E14 9SR
Phone: 0800 023 4567

Question 5

How safe is my money?

Accepted Answer

As a condition of its authorisation as an API by the FCA, Freemarket is required to protect and keep safe its customers’ funds. Specifically, Freemarket must comply with the Payment Services Regulations 2017 (PSRs). These regulations stipulate that APIs must have appropriate and well-managed safeguarding arrangements to ensure client funds are not subject to any other claim and that in the event of insolvency, are returned to the client in full, and in a timely and orderly way.

This is set out in detail within:

PSRs regulation 23; and
Chapter 10 of the FCA Approach Document

Freemarket is not a bank; your account with Freemarket is a payment account rather than a bank account. The funds provided to Freemarket for the purposes of making a payment are not eligible for depositor protection via the Financial Services Compensation Scheme (FSCS).

What is Freemarket's risk appetite?

How does Freemarket safeguard my money?

What are your unsupported jurisdictions?

Do you have a customer complaints procedure in place?

How safe is my money?

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