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

Can I make a payment from my Freemarket account?

Accepted Answer

Your Freemarket account does allow you to send and receive money. This may be a pooled account or vIBAN account that accepts payments or makes payments to the beneficiaries. You may start to make payments right away by setting up an account and confirming payments on it.

A variety of online payments can be made using your Freemarket account, but they must be within our risk tolerance and not breach sending or receiving funds to or from countries where we do not have support. Being a regulated company, we take this seriously and update it frequently. Our operations team occasionally blocks specific payments that violate this.

How you want to send a payment may differ, by which scheme and channel, this could be SWIFT, SEPA, FPS and so on. Each payment has different costs, receipts (transaction message) and reporting.

SWIFT: this is used to send or receive international payments via the SWIFT payment network.
SEPA: SEPA stands for Single Euro Payments Area and it's a payment type used to transfer euro within the EEA.
SEPA Instant: allow you to send 100,000 per transaction, they are available 24/7, 365 days a year, and take no more than 10 seconds to reach payee’s account from the payer’s.
FasterPayments: for the majority of UK-based payments Faster Payments is in place for bank-to-bank payments and designed to speed up the process of sending money. It has a limit in place of £1m per transaction.
Target2: is the real-time gross settlement (RTGS) system with payment transactions being settled processing euro payments.

If more funds are required for the payment in the platform, add them to generate a new payment. By navigating to the add funds area towards the top of the page's main menu, you may add funds to your account. Choose the currency of the funds you want to use for the payment from the add funds page, and the necessary bank information will then show up. After the funds have arrived in your account and are available for allocation, you will get an email confirmation.

After you have the funds, establish a new payment to continue, go to the transactions page, choose the beneficiary of the money (the beneficiary information will appear if it has already been used), and authorise the payment.

Question 2

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 3

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” and “FreemarketFX Ireland Limited” 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. For more information on our safeguarding processes please see our other articles on the subject here.

Question 4

Do you have a client 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 Relationship Managers and Client Support team are available at all times to help with your inquiries. We recognise 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 and will continue to do all er can 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

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 6

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). Freemarket Ireland must comply with the Payment Services Regulations 2018 (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
(For Freemarket Ireland) within PSRs 2018 Regulation 17

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) and/or the Deposit Guarantee Scheme (DGS).

Question 7

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 8

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 9

How much do you charge?

Accepted Answer

Freemarket features variable pricing choices based on the volumes and currencies that you desire to deal. For deposits and FX, we are able to provide the best flat rate we can or tier our fees based on your volume projections.

The tiering will be based on the monthly values, and will encourage greater volume to be handled since the tiers will decrease proportionally. Each agreed-upon price is bespoke & tailored to each user, and factors risk and return into account. We aim to be able move funds all over the world cheaper, quicker and more secure.

Please email sales@wearefreemarket.com or support@wearefreemarket.com if you have any questions about our account or cost structure, and a member of our team will get back to you. If wish to register for an account with us, please do here.

Question 10

Can I have a vIBAN for cross-border payments?

Accepted Answer

What is a vIBAN?

A virtual IBAN is an IBAN (International Bank Account Number) reference issued by a bank to allow incoming payments to be rerouted to a different, physical bank account.

Virtual IBAN accounts can be used to send and receive payments worldwide, allowing businesses to extend their value chain to provide settlement services to its global clients.

Freemarket and vIBAN accounts

Freemarket can request a vIBAN on the clients’s behalf to a bank for multiple currencies. This will allow the client to provide their own account number stating their own company name instead of Freemarket’s for B2B payments.

The request should be placed with a Relationship Manager. We will follow the internal compliance procedure to create the account on your behalf.

How does the vIBAN work?

From the client’s point of view, a virtual IBAN works in exactly the same way as a regular IBAN account – once they make a payment, their funds will end up in the physical bank account linked to the virtual IBAN.

The vIBAN account is made of:

Account owner name: the client’s name (to be provided by the client – must be the company registered company name or individual’s legal name).

BIC: A bank identifier code (BIC) is a unique identifier for a specific financial institution. This will be provided by the bank upon vIBAN creation.

In addition, the bank can provide:

Sort code: identifies both the bank (in the first digit or the first two digits) and the branch where the account is held.

Account number: the domestic bank account number.