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

How can I keep safe online?

Accepted Answer

Take Five is a national campaign offering straight-forward, impartial advice that helps prevent email, phone-based and online fraud – particularly where criminals impersonate trusted organisations. Led by UK Finance and backed by His Majesty’s Government, the initiative is supported by a range of partners such as; the payment industry, financial services firms, legal sector, telecommunications providers, and commercial, public, and third sector organisations.

Stop: Taking a moment to stop and think before parting with your money or information could keep you safe.
Challenge: Could it be fake? It’s ok to reject, refuse or ignore any requests. Only criminals will try to rush or panic you.
Protect: Contact your bank immediately if you think you’ve fallen for a scam and report it to Action Fraud.

Visit the Take Five website here for more information.

We utilise best-in-class services to enhance our compliance and risk policies, and we use real-time rules-based monitoring in our automated transaction monitoring tool. To further safeguard our clients we hold all funds in segregated accounts with our banking partners.

Question 5

What security procedures will you require when I instruct you to send money from my account?

Accepted Answer

For each transaction we will ask you the destination of the funds i.e. where the funds are going, the beneficiary details, and to pass all the necessary compliance checks and transaction monitoring. Once approved, we will proceed with authorising your instruction and making the payment.

What is Freemarket's risk appetite?

How does Freemarket safeguard my money?

What are your unsupported jurisdictions?

How can I keep safe online?

What security procedures will you require when I instruct you to send money from my account?

Contact us