Freemarket risk appetite is the aggregate level of risk that we are willing to assume within our risk capacity and in line with our business model, culture and ethics.
Freemarket takes an appropriate risk-based approach in order to achieve our strategic and commercial objectives. Robust systems and controls are proportionate to the nature and scale of our business and continually evolve to mitigate financial crime. Maintaining effective systems and controls and treating customers fairly is at the heart of Freemarket and such standards are expected by all stakeholders.
Freemarket have stringent procedures regarding the governance of our risk framework and strict policies in relation to PEP’s, illegal activity, sanctioned counterparties, criminals and individuals associated with terrorism.
In addition, Freemarket prohibits payments from the following activities.
- Offshore FX & CFD brokers (1)
- Hawala (informal banking system)
- Binary Options or unregulated investment and or payment services activities
- Shell and Offshore Banks located in Jurisdictions listed by the IMF as Offshore Financial Centres 2019 (2)
- Get rich quick schemes (proposal to pay high rates of return over a small period in return for a small investment)
- Unregulated charities or any regulated charity outside of EEA
- Activities relating to defence and munitions, including dual use
- Illegal Drugs and or unlicensed drug related activity
- Shell companies (a limited liability company having no physical presence, no employees or no commercial activity in its registered jurisdiction) (3)
- Companies formed of Bearer Shares
- Gambling Entities regulated outside EEA (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 and/or publication of pornography (5)
- Payment Service Providers with fifth-party payments & multi-layered MSB arrangements (Freemarket facilitating payments for its client’s, client’s, client) (6)
- Political / religious organisations engaged in hate speech
- Freemarket’s blocked country list
Crypto – Currency/virtual asset
- Freemarket will service companies where they are regulated in EEA jurisdictions and can provide verification that they are complying with the new FATF regulations/AMLD5/application of WTRs to VASPs. All crypto firms will adhere to our Crypto Policy and procedures.
Specifically excluded VASPs include:
- ICO crypto and any unlicensed facilitation of security tokens (tokens that have characteristics akin to traditional instruments like shares, debentures or units in a collective investment scheme) unregulated securities and exchanges or any regulated outside of EEA
- Providers of privacy and restricted coins or facilitating exchange of anonymous cryptocurrency.
(2)IMF as Offshore Financial Centres 2019.(3)Shell companies that are not part of an overall onshore group structure. (4)Freemarket will consider EEA licensed gambling companies that have entities within their group licensed offshore.
(5)Acquire flow from Adult content will be considered on a cases by case exception basis.
(6)E.G. Freemarket client (a regulated PSP) is facilitating payments for their client’s (PSP) clients i.e. it’s underlying customers.