Q: What are your restricted jurisdictions?

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. We are regulated by the Financial Conduct Authority (FCA) take our regulatory responsibilities very seriously, taking a risk-based approach to managing transactional risk. Therefore, in line with our anti-money laundering policy and sanction screening requirements, we cannot receive funds from or send money to the following countries, although this may be subject to change. If you have any questions about making payments to restricted jurisdictions please contact your Relationship Manager, or contact us on support@wearefreemarket.com .

Question 1

What is your risk appetite?

Accepted Answer

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.

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 Subsidiaries, UBO’s, 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 and 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 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 structured and operating Piracy or illegal streaming
Political / religious organisations engaged in hate speech
Pyramid Schemes / multi-level marketing (MLM) schemes
Companies dealing in non-electronic funds
Unregulated institutions that should be regulated
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.

Question 2

What are your restricted jurisdictions?

Accepted Answer

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.

We are regulated by the Financial Conduct Authority (FCA) take our regulatory responsibilities very seriously, taking a risk-based approach to managing transactional risk. Therefore, in line with our anti-money laundering policy and sanction screening requirements, we cannot receive funds from or send money to the following countries, although this may be subject to change.

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

Question 3

Do you add fees for negative interest rates?

Accepted Answer

Custody Fee/Negative Interest

As of 1st October 2022, the applicable total negative interest ‎rate is 0.00% (0.75% ECB rate + -0.25% markup = 0.50%, however, as we are a Payment Institution, not a Bank, we are not permitted to pay interest on funds held on account with us, so the EUR custody fee is adjusted to 0.00%) per annum on the average daily balance in a calendar month on Account held in EUR. Freemarket reserves the right to charge custody/negative interest fees with respect to any other currencies which attract negative interest rate fees in the future.

Why do we charge custody/negative interest fee?

This fee is charged to recover our costs associated with holding funds in a particular currency. It includes negative interest reference rates, which are set by central banks, such as the ECB for funds held in EUR. In addition to the negative interest rates, our mark-up over the reference rate includes certain additional cost components we have to consider, including any other costs such as ECB deposit facility rates passed on to Freemarket by its banking partners.

Normally, banks do not pass their costs on to their customers as they can use the deposit base for lending activities, but due to regulatory restrictions all funds held for payment service providers like Freemarket must be 100% liquid, and so these additional costs are charged to clients like Freemarket.

Thus, as an example, the ECB base reference rate for EUR is currently +0.75% and mark-up is -0.25%, giving a total negative interest rate of +0.50% per annum for EUR balances held on account. However, as we are a Payment Institution, not a bank, we are not permitted to pay interest on funds held on account with us, so the EUR custody fee is adjusted to 0.00%.

Negative Interest Fee Illustration:

A transfer to your account of €100,000 was made on 1st April 2022 and you have given us instructions for an onward transfer of €50,000 on 16th April 2022. There have been no withdrawals from your Freemarket account since then. The remaining balance on your account on 30th April is €50,000. The average daily balance for the month is therefore €75,000 (€100,000 for 15 days and €50,000 for 15 days) The applicable total negative interest rate is 0.25% per annum based on the average daily balance in a calendar month on account held in EUR. Thus, you would be automatically charged €15.63 (€75,000 * 0.25% / 360 *30).

Effective Dates: the new rates as set out in the table below are effective as follows:

New Clients:

Corporate: 1st October 2022

Small Charity & Micro Enterprise: 1st October 2022

Existing Clients:

Corporate: 1st October 2022

Small Charity & Micro Enterprise: 1st October 2022

*As of the Effective Date and Subject to Change without notice.

**Total Interest Rate as of the Effective Date. The total interest rate is indicative only and subject to change without notice.

***Actual 360 is the method that calculates interest daily by counting the number of days in the calendar but uses a fixed 360 length.

****Adjusted to 0.00 as no custody fee is chargeable as total interest rate after applying Bank Mark-up is positive.

Question 4

How can I make a withdrawal from my account?

Accepted Answer

Once you have funds on your account, you can withdraw them any time to a beneficiary of your choice. To do this, go to the ‘Balances’ page and select the currency sum you want to transfer.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/b3SzUfe2O2/How-to-make-a-withdrawal-Screenshot-1.png (How to make a withdrawal)

Performing a withdrawal is the next step after selecting the currency you want to withdraw from. To withdraw funds, select "withdraw funds" in the upper right corner of the Balances tab. From here you can either withdraw a specific amount or withdraw your full balance. Once you’ve selected the amount, click continue.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/XKRnSRq6Gl/How-to-make-a-withdrawal-Screenshot-2.png (How to make a withdrawal)

The beneficiary, or the individual who will receive the funds, must be chosen next. If you haven't already made a transfer, a new beneficiary must be created. Click "Add New Recipient" to get started.

Name the beneficiary account, then choose your location. There should be a collection of input fields for bank details. Click "Submit" after providing the beneficiary account details and the transaction's explanation.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/dVXjuDVlem/How-to-make-a-withdrawal-Screenshot-3.png (How to make a withdrawal)

A confirmation notification will be sent to you once your funds have been cleared.

Question 5

I am entering the correct OTP but it still says incorrect OTP?

Accepted Answer

Freemarket sends a one-time password (or OTP) to authenticate customers, which you can receive OTP on mobile or email based on your preference. OTP is used to add extra layer of security during the sign in process or during delivery of certain orders. OTPs are unique and should not be shared with anyone.

If you have tried to access your login page multiple times, every new click on “Resend an OTP” will generate a new OTP. You should enter the latest OTP that you have received based on your preferences.

If you are still having trouble with the code, contact your Relationship Manager or email support@wearefreemarket.com.

Question 6

How can I conduct a batch payment?

Accepted Answer

Businesses may submit a single file and make numerous payments across a variety of currencies and payment types using Freemarket's batch payments capabilities at no extra cost. The transaction types of the payments might vary, and our clients are able to make cross-border payments effectively and efficiently.

Quickly; saving the time and cost of manually typing or pasting-in payments
Efficiently; using a format configurable from their ERP or treasury platform
Accurately; minimising the expensive mistakes associated with manual keying

Important information on batch transactions

The service can be switched on or off depending on the client’s needs
Any client requiring this functionality should request it through their Relationship Manager
Multiple currencies can be included in the same batch
Each payment in the file will be treated as individual payments and will be debited as such. For example, a file which has 15 USD and 12 CAD payments will see 15 debits on their USD account and 12 debits on their CAD account
Clients will upload a .CSV file to the platform containing all the required data
The web dashboard can only be used to upload the payment file
There is a guide & template .CSV file in the appendix of this article
We accept a range of payment types on the file(s) e.g. SWIFT, SEPA, Faster Payments etc.
Each payment order will be subject to initial data input validation and checks
Any payments which do not pass validation (checks on file format, message content, account numbers etc.) will be highlighted when the file is uploaded
The payments which do not pass initial validation checks will have to be corrected or withdrawn from the file and escalated separately; the successful payments that have been checked & validated will continue through the process
Uploaded files will be processed throughout the day – there aren’t any specific processing times, however, there may be certain cut-off times in some currencies
Beneficiaries which have not authorised for single payments may be included in the file
All of the files will therefore be subject to two-factor approval before processing
If the file includes new beneficiaries, they will be created in the system with unauthorised status. If a subsequent payment is made to those unauthorised beneficiaries in the future, then the payment requires authorisation
Post import, payments will be checked by Freemarket & its banking partners for sanctions, PEPs, fraud and in more detail for payment scheme rules, message content, and reachability. Payments which are stopped for investigation at those stages will be removed from the file and the remainder of the file will automatically continue for processing

The batch payment procedure from start to completion

To access the batch payments screen, log into your Freemarket account and select the batch option.

Choose the pre-formatted CSV file by selecting the file upload button. To ensure the accuracy of the information, many validations will be performed, including checks of the account balance in each currency, beneficiary information, ultimate originator, and the maximum withdrawal amount necessary to complete the file. If there is a mistake, the system will indicate the cause so that it may be fixed:

All cross-border transactions worth more than 100,000 GBP must be made individually, without using the bulk option. You will receive an email or text message telling you that all validations are completed using an OTP. The message will also provide the total number of transactions and a special batch number (identifier).

You will be prompted to confirm the beneficiaries every 30 days using the platform's 2FA function. This indicates that the user must approve the batch by verifying the specified code. The system will create beneficiaries with the status "unauthorised" if more beneficiaries are added to the batch payment. The recipients must be authorised to receive future payments. The other account user(s) will be alerted if the account is set up for approval workflow and asked to confirm authorisation and to approve the user.

Once the preceding steps are finished and you can see all the payments, a new transaction type will be generated. There is no ability to accept the individual transactions in the file; just to approve or reject the batch as a whole. Once the batch payment is accepted, the payment won't go through until the system has completed processing each transaction.

As soon as everything has been processed, the batch's status will change to complete. The entire batch will be accessible in finished transactions. In order to confirm that the batch has been processed and is therefore finished, an email or SMS will be issued to the user.

Appendix

1.0 Format Guide

Note: comma is not allowed on the provided CSV as it will cause an error in the file.

Important: all mandatory fields need to be populated and field format adhered to for the file to be processed with no errors. Non-mandatory fields will need to remain blank.

Question 7

What are the withdrawal transaction charges?

Accepted Answer

The possibility to apply OUR and SHA fees to withdrawals has been made available by Freemarket.

SHA (Shared): The recipient will be charged fees from other banks handling the payment in addition to the payer paying the Freemarket fee for the withdrawal.
OUR: The payer will bear the Freemarket cost in addition to any additional fees incurred by other banks executing the payment.

The different cost charge categories will be provided for selection when making a withdrawal. The charge for the transaction will vary depending on the type selected.

Steps to be followed are outlined below:

Step one

Log into the platform.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/yQbK8TpEr5/Withdrawal-Transaction-Charges-image-1.jpeg (Withdrawal Transaction Charges)

Step two

Head to balances and select an account to withdraw funds.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/xvQcOhpwsJ/Withdrawal-Transaction-Charges-image-2.jpeg (Withdrawal Transaction Charges)

Step three

Beneficiary selection step will follow:

a. Depending on the payment destination country, transaction Charges option will or will not be displayed: i. Payment outside the European Economic Area (EEA)1 region: SHA/OUR option will be available:

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/BeyTFm0ato/Withdrawal-Transaction-Charges-image-3.jpeg (Withdrawal Transaction Charges)

An explanation of the different charges available will be shown when hovering over the (i) tooltip.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/LeE8eSDVAJ/Withdrawal-Transaction-Charges-image-4.jpeg (Withdrawal Transaction Charges)

ii. Payment within EEA region: SHA/OUR option will not be displayed as all payments within the EEA region will be defaulted to SHA.

Step four

After selecting the desired transaction charges, the payment will need to be confirmed and the details will be displayed. A breakdown of the service fee will be available, and the transaction charges selected.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/MWlQo1zVF3/Withdrawal-Transaction-Charges-image-5-2048x1476.jpeg (Withdrawal Transaction Charges)

(1) EEA countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.

Question 8

How can I use the withdrawal approval function?

Accepted Answer

Using the "Withdrawal Approval Function," designated users can approve withdrawal requests made by "regular" users. Every time a withdrawal instruction needs approval, users having "Withdrawer Approver" access will be notified by email. Although the "Withdrawal Approval Function" is by default disabled, you may turn it on and off on the platform as desired for your ease.

Please be aware that, if the function is enabled, solely administrators and withdrawal approvers may authorise withdrawals.

The process is as follows: following implementation, any withdrawal instruction created (other than by a withdrawal approver) will show up in the "Transactions" tab with a "Approval pending" status. A withdrawal is automatically accepted if it is initiated by a withdrawal approver. The account's withdrawal approver(s) will then get an email containing the withdrawal's information and a link to confirm it. The "Approve" button may be found underneath the withdrawal status on the transactions page (you might need to login in to access this page). Our payment systems will produce the withdrawal as soon as the withdrawal approver chooses "Approve" to continue.

User Interface: The functionality in account settings allows you to turn on or off the workflow for withdrawal approval. If the "on" button is blanked out, you do not have the necessary rights to turn this feature on. By default, only the user who created the account will have access to these rights. However, this may be changed by getting in touch with your Relationship Manager and asking them to provide permissions to additional users.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/oIYZRLTqpa/Withdrawal-approval-1.png (Withdrawal approval)

Click "on" to start the workflow. You must choose one or more users to have the "withdrawal approver" role by using the search bar on the overlay that will display. Once the users have been identified and assigned, click "confirm," and a notification confirming the activation of the new approvers should appear at the top right of the page.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/FeMT1Fx38b/Screenshot-2019-10-29-at-12.48.35-1024x434.png (Withdraw approval)

Note: by selecting "Change Approved Users" from the account settings menu, you may change and update withdrawal approvers at any time.

Question 9

How do I set up 2FA on my account?

Accepted Answer

Two-factor authentication (2FA) or multi-factor authentication adds an extra degree of protection, and all users have to provide this code in order to access their account and make cross-border payments.

A user is only permitted access to an application or website using the 2FA electronic authentication procedure after successfully showing two or more pieces of evidence, including knowledge, possession, and inherent characteristics. Here are a few examples of this:

Something you know - a password or a pin
Something you have - a smartphone
Something you are - a fingerprint or facial recognition

Each user must configure 2FA, you can't do this for others at your organisation.

With the two-factor authentication enabled on your account, you would require an additional 6-digit verification code for a successful sign in to Freemarket.

To create a time-based one-time password (TOTP) that will change each time you use it, we advise setting up two-factor authentication on an app. For this, we advise adopting a cloud-based application. The majority of applications available would support this. Below we've listed some of the options available to you.

You must enter a verification code if 2FA is enabled on your Freemarket account in order to sign in successfully.

After setting up 2FA, a 30-day window will open for your account. Otherwise, on the 30th day, you will be asked to perform 2FA during a period of activity. If you are unable to execute 2FA in order to pass the checkup, you must utilise the given shortcut to modify your 2FA settings and maintain platform access.

First time setup

Log into the platform here

2FA Screenshot 1

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/pXeX4Nv2Vt/2FA%20Screenshot%201.png (2FA Screenshot 1)

Once logged in, you will be presented with the page provided below. Please click on receive code to get the verification code depending on your current 2FA

2FA Screenshot 2

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/rrV9Wmzpr8/2FA%20Screenshot%202.png (2FA Screenshot 2)

If there is a phone number registered on the account, then a verification code will be sent to the registered mobile number as a primary option for 2FA
If there is no phone number registered on the account, the verification code will be sent to the registered email address as a primary option for 2FA

Type in the verification code you were supplied

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/Yx9AyMmDcs/New%20QR%20code.png (New QR code)

If you'd like not to be prompted for another 30 days, choose to remember the device
When you log in to your account, the next screen will appear
Download an authenticator app from the Google Play Store or the App Store that is compatible

Microsoft Authenticator for Android, iOS
Google Authenticator for Android, iOS

After downloading one of the authenticator applications, you have the option of manually entering the information or scanning a QR code
The authenticator app will display a 6-digit verification number after scanning the QR number; this code automatically refreshes every 30 seconds. You must enter this code in the verification code text box above and select verify
If everything goes smoothly the app's setup will be finished

Please note: If your current password does not meet the new complexity rules you will be prompted to change your password: once the password is updated, you will be sent back to the sign in page so you can log in with your updated credentials to sign in.

2FA Screenshot 4

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/frPNeQDAEc/2FA%20Screenshot%204.png (2FA Screenshot 4)

Signing into Freemarket using the authenticator app

Once you've successfully set up the authenticator app, subsequent logins will require the verification code it creates, so when you enter your credentials, the next screen you'll be provided with will ask you to input the verification code.

2FA Screenshot 5

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/kSw1rDStX8/2FA%20Screenshot%205.png (2FA Screenshot 5)

Open the authenticator app
Enter the the 6-digit verification code displayed on the authenticator app and click on sign in

Please email support@wearefreemarket.com to disable or resetting your authenticator app if you experience any difficulties logging in. This will enable you to install the authenticator app on either your current or new smartphone.

Question 10

What is a scheduled exchange?

Accepted Answer

Scheduled exchanges are the unique mechanism by which we are able to achieve mid-market rates of exchange. By using peer-to-peer technology and aggregating our client’s requirements into one exchange we can optimise the opportunity to match currency and deliver the best possible rate for all involved.

Here’s how we do it:

Step one: clients transfer funds into their segregated Freemarket escrow account

The nature of the scheduled exchange requires us to operate a pre-funded model, as this is how we are able to match our clients’ currencies – achieving mid-market rates. This means that client’s must transfer the required funds in their entirety prior to the scheduled exchange taking place.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/3junOv9K5E/Screenshot-2019-10-23-at-11.31.35.png (Customer transfer overview)

Step two: clients book their payment order via the platform

After the exchange procedure is complete, you let us know whether you want to buy or sell, the currencies you want to use for the transaction, and where you need the funds allocated. You will then be included to the following exchange that is scheduled.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/jzzkEQKGAE/Screenshot-2019-10-29-at-13.34.16.png (Booking exchange instruction overview)

Step three: The scheduled exchange takes place

Depending upon the currency pairing and demand we operate exchanges at periodic intervals throughout the day, with a minimum of one scheduled exchange at midday.

We aim to achieve mid-market rates as often as possible, for as many participants as possible. If your funds are wholly matched with other participants, you both achieve the mid-market rate. If an exchange is incompletely matched, you benefit from our market buying power. We pass on the institutional rate from our network of global banks onto all parties and provide a true banking as a service.

https://malcolm-en-gb.s3.eu-west-1.amazonaws.com/instances/fnDSsgZVaa/resources/pPLqgSm3BO/Screenshot-2019-11-14-at-10.15.00-1024x226.png (Step 3 overview)

Step four: we pay out to your nominated beneficiary

That's it; we transfer the transferred funds to your chosen bank account.