Customer Acceptance Policy

FXDD Mauritius Ltd. is regulated by the Financial Services Commission in terms of the Financial Services Act 2007 and Securities Act 2005 as an Investment Dealer licence holder to provide any investment service and to hold and control Clients’ Money or Customers’ Assets. The Company falls within the scope of the Financial Intelligence and Anti-Money Laundering Act and Regulations.

To the fullest extent achievable by the Company, the Company does its utmost to ensure the privacy, confidentiality and security of its customers is preserved throughout their interaction with the Company,

CUSTOMER ACCEPTANCE POLICY

The main purpose of the Customer Acceptance Policy is to protect the Company’s good reputation continuously and consistently, and to prevent the Company from being used for fraudulent or criminal purposes.

The underlying principle of the Customer Acceptance Policy is that the Company should “know its customers” (Know-your-Client process / “KYC”). The Company’s reputation can be harmed either by failing to act in accordance with applicable law or by dealing with counterparties whose business activities and reputation may cause harm to the Company’s reputation.

The Compliance function is responsible for monitoring developments in the field, identifying required action and informing and training all relevant personnel. The Compliance function is also responsible for the general monitoring of the Company’s policies and procedures and the improvement / amendment of these procedures if and when the need arises.

ONBOARDING PROCESS

The onboarding process is detailed in the Company’s Client Onboarding Procedure. In view of the fact that all retail customers are on-boarded non face-to-face, the Company has adopted the use of an identity verification software for this purpose.

RISK BASED APPROACH

The Company has adopted a risk based approach for the onboarding and monitoring of its customers. The methodology and process of the risk based approach is provided in the Risk Assessment Policy. The main principle of the risk based approach as adopted by the Company is the following:

1. At onboarding, retail customers are risk rated based on the geographical provided in the application form and cross-checked with the Proof of Residence Document.

2. A monitoring schedule is applied to the retail customer at onboarding based on the geographical location on the ID document collected at onboarding.

3. A retail customer’s risk rating may change following a review of the retail customer’s profile and transaction history.

4. A log of all retail customers’ risk rating is maintained by the Compliance Department.

5. Due to the high-risk nature of the business, all Corporate Customers are classified as high risk at onboarding and will retain that rating throughout the lifetime of the customer.

6. The Risk Matrix will be reviewed annually as a minimum.

THE FOLLOWING ACTIVITIES OR APPLICANTS FOR BUSINESS ARE PROHIBITED:

(i) Affiliated persons – no current employees of FXDD Malta may carry an account on our platform. The only proprietary accounts allowed are those which are opened and held by and for FXDD Mauritius Limited (own funds) or for testing purposes by the operations/IT/compliance teams;

(ii) Employees of exchanges and regulatory bodies outside the US are not allowed to open an account with FXDD Mauritius unless with the prior permission of the Compliance Officer in charge. In this regard, the client has to provide the latest statement of financial instruments held;

(iii) Applicants for Business who fail or refuse to provide the necessary account information;

(iv) Applicants for Business whose World-Check/MIS search reports derogatory information on the client in question which in the determination of the Compliance Officer disqualifies the prospect. In this regard, the relative report shall be forwarded to the Money Laundering Reporting Officer in charge. The section on reporting a suspicious transaction shall be followed. Such account may only be opened with the approval of the Money Laundering Reporting Officer.

(v) No anonymous accounts or accounts in fictitious names shall be opened.

(vi) Applicants for Business seeking to fund their accounts through cash deposits and cheque deposits. This is due to the fact that it is time consuming to establish the origin on the funds involved. This increases the money laundering and funding of terrorism risk for FXDD Mauritius.

(vii) Applicants for Business are located in jurisdictions with strategic deficiencies or where the funds have originated from these countries.

(viii) A customer whose funds is derived from criminal activities or whose occupation is not legal.

(ix) Applicants for business who have been sanctioned by the UN, OFAC, or the EU or are related persons to individuals who have been sanctioned;

(x) Corporate Customers whose shares are bearer shares; and

(xi) Corporate customers for which it is not possible to identify the ultimate beneficial owner.

HIGH RISK CUSTOMERS & PEPS

FXDD does accept customers that are classified as High Risk, including PEPs, in accordance with its Client Onboarding Procedure.

PEPs are to be approved by the MLRO following the receipt of a signed self-certification form from the customer. PEPs are automatically classified as high risk.

PEPS and Customers that are classified as High Risk shall be required to undergo an enhanced due diligence onboarding process.

BANNED COUNTRY LIST

The Company has a list of countries from which it shall not accept customers. This list is made up of the list of countries identified by FATF as having AML deficiencies as well as those countries which have restrictions on the offering of FX to its citizens.

REACTIVATION OF ACCOUNTS

Inactive accounts, that is, accounts which show no activity over a 180-day time-frame will be frozen and trading from such account after the above period will be prohibited. To begin trading again, the client in question is required to complete the Re-activation of Account Form and CDD shall be carried out again as applicable. The approval of the Compliance Unit shall be requested prior to the re-activation of such an account.