What is the Freemarket risk appetite?

Freemarket is committed to complying with all applicable laws and regulations including those related to anti-money laundering, PEP’s, counter-terrorism financing, sanctions, and export control laws. We maintain robust systems, policies, procedures and controls to help protect our platform and to deter, detect and disrupt financial crime. In addition, our banking partners also maintain requirements and restrictions that must be adhered to, including restrictions on certain industries, activities, and countries, as listed below.

Failure to comply with these restrictions can result in delayed payments or declined payments with continuous breaches leading to account closure. Please contact your Relationship Manager for additional information.

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 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 restricted jurisdictions list for a full list of countries we cannot receive funds from or support payments to.

Non-permitted industries and 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 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.