What is your risk appetite?

FreemarketFX Limited’s onboarding and transactional risk appetite is the aggregate level of risk that it is willing to assume with regards to the clients it has and transactions it processes. Freemarket takes a risk-based approach to achieving its strategic and commercial objectives and a core focus of this is around both the clients and transactions it interacts with.

Within the overall risk framework, Freemarket has robust systems and controls that continually evolve to mitigate financial crime. With these systems and controls, Freemarket aims to Deter, Detect and Disrupt financial crime. Maintaining these and treating clients 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 PEPs, illegal activity, sanctioned counterparties, criminals, and individuals associated with terrorism.

FreemarketFX Limited onboards Small, Medium or Large Corporates only. This does not include Sole Traders, Micro-Enterprises or Small Charities.

What types of activity are not permitted?

Understanding what’s prohibited

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

Prohibited Locations

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

View the Freemarket restricted jurisdictions 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 or munitions, including dual use.
• Adult websites or services with prostitution, and the broadcasting/publication of pornography.
• Binary Options or unregulated investments.
• Companies formed of bearer shares.
• Company structures which include only corporate and/or nominee directors (there must always be individual directors).
• Companies dealing in counterfeit goods.
• Companies dealing with cultural artefacts, ivory or other items related to protected species, or with items of archaeological, historical, religious or rare scientific value significance.
• Companies handling the import/export or supply of products that do not comply with UK, EU and local country laws.
• Companies structured or operating Piracy or illegal streaming.
• Companies or transactions which breach environmental regulations and/or perpetrate environmental crime.
• Political or religious organisations engaged in hate speech.
• Pyramid schemes or multi-level marketing (MLM) schemes.
• Payments that appear to circumvent currency controls.
• Companies dealing in non-electronic funds.
• Unregulated institutions that should be regulated.
• Shell banks.
• Shell companies (companies having no physical presence, no employees and/or no commercial activity in their registered jurisdictions).
• ‘Get rich quick’ schemes (proposing to pay high rates of return over a small period in return for a small investment).
• Unregulated charities.
• Banks not located/domiciled in UK, EEA, USA, Switzerland, Canada, Australia, New Zealand, Hong Kong, Singapore, Japan or South Korea.

Additional requirements for the following industries

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

Initial risk assessment criteria

• Must have no AML/CTF failings or 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 used to evaluate prospective clients.