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Risk Appetite

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:

  • Offshore FX & CFD brokers (1) and consumer inbound flows for CFD’s
  • Hawala (informal banking system)
  • Binary Options or unregulated investment and or payment services activities
  • Shell Banks and Offshore Banks located in Jurisdictions listed by the IMF as Offshore Financial Centres (2)
  • Get rich quick schemes (proposal to pay high rates of return over a small period in return for a small investment.)
  • Unregulated charities
  • Activities relating to defence and munitions, including dual use
  • Illegal Drugs and or unlicensed drug-related activity
  • Shell companies (a company having no physical presence, no employees or no commercial activity in its registered jurisdiction) (3)
  • Companies formed of Bearer Shares
  • Gambling Entities regulated offshore (4)
  • Pyramid Schemes / multi-level marketing (MLM)
  • Unregulated pharmaceuticals / food supplements (nutraceuticals)
  • Remittance funded of Cash
  • Piracy or illegal streaming
  • Counterfeit goods
  • Adult Websites or services associated with prostitution, and the broadcasting/publication of pornography (5)
  • Payment Service Providers with Fifth-party payments & multi-layered MSB or gambling/gaming/crypto arrangements (Freemarket facilitating payments for its client’s, client’s, client) (6)
  • Political / religious organisations engaged in hate speech
  • Freemarket’s blocked country list
  • Correspondent style relationships with EMI or PI Agents & or small EMI & PI entities (7)
  • Cultural artefacts, ivory or other items related to protected species, or archaeological, historical, and religious significance, or of rare scientific value.
  • Crypto transactions for itself or for clients, or in any transactions which convert crypto currency or virtual assets to fiat currencies (8)
  • Flows in relation to Initial Coin Offerings (ICO) i.e., Freemarket will not engage in flow of funds where retail and/or non-retail clients pay to subscribe to an ICO.
  • Entities which are not registered with the FCA and / or not licensed in the jurisdictions in which they conduct business in and who can not provide verification that they are complying with the Financial Action Task Force (FATF) recommendations regarding the combat of money laundering and the financing of terrorism and proliferation (9)
  • Inbound consumer flow for the purchase of crypto transactions.
  • Only onboard crypto firms directly i.e., not through other Payment Service Providers. 
  • All crypto firms must adhere to our Crypto Policy and associated procedures.
  • (1) Freemarket will consider the UK and or EEA licenced forex & CFD brokers that have entities within their group licenced offshore.

    (2) IMF as Offshore Financial Centres 2019.

    (3) Shell companies that are not part of an overall onshore group structure.

    (4) Freemarket will consider licenced gambling companies that have entities within their group licenced onshore.

    (5) Acquirer flow from Adult content will be considered on a case-by-case, exception basis.

    (6) E.g. Freemarket client (a regulated PSP) is facilitating payments for their client’s (PSP) clients i.e., its underlying customers.

    (7) Freemarket will consider EMI/PI Agents or a small EMI/PI in the same group of the principal EMI/PI, Acquirer, operational and/or principle to principal flow.

    (8) Including Virtual Asset service providers (VASPs) as defined within FATF recommendations.

    (9) Freemarket does not engage with clients incorporated in jurisdictions under increased monitoring by FATF