Risk appetite

Freemarket’s 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. With these systems and controls, Freemarket aims to Deter, Detect and Disrupt 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 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)
  • 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
  • Correspondent relationships with EMI or PI Agents & or small AEMI & API entities (7)
  • Cultural artefacts, ivory or other items related to protected species, or archaeological, historical, and religious significance, or of rare scientific value.

Crypto – Currency/Virtual Asset

  • Freemarket does not engage in cryptographic currency transactions for itself or for clients, or in any transactions which convert crypto currency or virtual assets to fiat currencies.

  • Freemarket will not provide payment and cash management services, such as conversion and payout of dollars to other currencies, to companies where they are incorporated offshore. Firms will need to provide verification that they are complying with the new FATF regulations / AMLD5 / application of WTRs to VASPs. All crypto firms will adhere to the Crypto Policy and procedures.

  • Freemarket will only provide these payment services for B2B crypto related activities i.e. not to Retail customers. Freemarket will only onboard Crypto firms directly i.e. not through other Payment Service Providers.

  • Freemarket will not be involved in the flows of an Initial Coin Offering (ICO). That is, Freemarket will not be in the flow of funds where retail or non-retail clients pay to subscribe to an ICO.

Excluded Virtual Asset Service Providers (VASPs, as defined by FATF) 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 crypto currency such as mixers or coinswap entities.

(1)Freemarket will consider 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 EEA licensed gambling companies that have entities within their group licensed offshore.

(5)Acquire 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. it’s underlying customers.

(7)Freemarket will consider Agents that belongs to the same group of the principle EMI/ PI or the principle completes the CDD.