Prime execution designed by Asset Managers for Asset Managers

    Statement of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policies and Principles

    Money laundering and terrorist financing have been identified as significant threats to the Xprime Markets Group and, indeed, the international financial services community. The United Kingdom, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for UK firms and outline the offences and penalties for failing to comply.

    Tax evasion is a financial crime and a predicate offence to money laundering in the UK and in many other countries in which we operate. Xprime Markets is committed to dealing only with clients who have appropriately declared their assets to the relevant tax authorities. We take a zero-tolerance approach to the facilitation of tax evasion in any country and have procedures in place to prevent it. We expect the same from our agents and third parties providing services for or on our behalf. 

    The requirements of EU/UK legislation apply to the Xprime Markets Group globally and to its parent, subsidiary and associated companies. Group Companies may have additional local policies and procedures designed to comply with their local legislation, regulations and any government approved guidance in the jurisdiction(s) in which they operate. Xprime Markets Limited is authorised and regulated by the UK Financial Conduct Authority (FCA). Its registered number is 931063.

    Legal and Regulatory Framework

    The principal requirements, obligations and penalties currently in force, on which Xprime Markets Financial Crime Systems and Controls are based, are contained in:

    • The Proceeds of Crime Act 2002 (POCA), as amended by the:
      1. Serious Organised Crime and Police Act 2005 (SOCPA); and the
      2. Proceeds of Crime Act (Amendment) Regulations 2007;
    • The Terrorism Act 2000, as amended by the:
    1. The Anti-Terrorism, Crime & Security Act 2001; and the
    2. Terrorism Act (Amendment) Regulations 2007;
    • The Terrorism Act 2006;
    • The Bribery Act 2010;
    • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, transposing the requirements of the EU’s Fourth Money Laundering Directive;
    • The FCA Handbook of Rules and Guidance, and in particular, the Senior Management Arrangements, Systems and Controls (SYSC) Sourcebook, which relates to the management and control of money laundering risk;
    • The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector on the prevention of money laundering/combating terrorist financing; and
    • The Criminal Finances Act

    Xprime Markets Group Policies & Principles

    Xprime Markets Financial Crime function owns and is responsible for the following Group Policies covering:

    1. Anti-Money Laundering/Counter-Terrorist Financing;
    2. Sanctions;
    3. Anti-Bribery & Anti-Corruption; and
    4. Introducers

    These policies and principles are designed to ensure that all Group Companies complies with the legal and regulatory requirements applicable in the UK as well as with their local obligations.

    1.   Anti-Money Laundering (AML) Policy

    The Xprime Markets Group AML Policy is designed to ensure that all Group Companies comply with the requirements and obligations set out in UK and EU legislation, regulations, rules and industry guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by all Xprime Markets Group Companies and includes: 

    • The appointment of a Group Money Laundering Reporting Officer (GMLRO) and Business Unit Heads of Financial Crime of sufficient seniority, who have responsibility for oversight of Group and Business Unit compliance with relevant legislation, regulations, rules and industry guidance;
    • Establishing and maintaining a Risk Based Approach towards assessing and managing the money laundering and terrorist financing risks to the Group;
    • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as:
    1. Politically Exposed Persons (PEPs);
    2. Countries identified by the European Commission as having strategic deficiencies in their national AML/CTF frameworks;
    • Corresponding and Counterparty relationships; and
    1. if providing any tax advice or tax planning services to customers;
      • Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;
      • Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
    • Maintenance of appropriate records for the minimum prescribed record-keeping periods;
    • Training and awareness for all employees; and
    • Provision of appropriate management information and reporting to senior management of the Group’s compliance with the

     2.    Sanctions Policy

    The Xprime Markets Group Sanctions Policy is designed to ensure that Xprime Markets comply with applicable sanctions laws in every jurisdiction in which it operates. 

    Xprime Markets relies on a robust Global Sanctions Compliance Programme (“the Sanctions Programme”) to ensure adherence to applicable sanctions regulation throughout its subsidiaries and branches. The Sanctions Programme is underpinned by the Sanctions Policy and associated Sanctions Standard and all are designed to ensure Xprime Markets and its employees know how to identify and manage the risks associated with sanctions, including the risk of Xprime Markets products being used to contravene sanctions.

    3.    Anti-Bribery & Anti-Corruption Policy

    Xprime Markets has a zero tolerance policy towards bribery and corruption. Xprime Markets recognises that bribery and corruption, including the facilitation of tax evasion, have an adverse effect on communities wherever they occur. If endemic, bribery and corruption can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organised crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.

    Xprime Markets is committed to applying high standards of honesty and integrity consistently across our global operations, in all our business dealings, of all employees’ and of any third party acting on Xprime Markets behalf. We are subject to the provisions of the UK Bribery Act and the US Foreign Corrupt Practices Act, which have extra-territorial effect globally, as well as applicable local antibribery laws.

    Xprime Markets has no appetite for Xprime Markets products or services to be used to facilitate bribery or corruption. Xprime Markets has developed a robust anti-bribery and corruption control framework to manage the legal and regulatory risks faced.

    4.     Introducer Policy

    As part of that framework, Xprime Markets additionally has an Introducer Policy. The Policy covers the activities of third parties that generate or retain business, or secure a business benefit, for Xprime Markets – collectively introducers. Potential examples would include senior advisors, lead generators and financial advisers. The Xprime Markets Introducer Policy is designed to protect Xprime Markets against bribery and corruption risk, facilitations of tax evasion risk, reputational risk, and wider operational and conduct risk associated with introducers. Xprime Markets employees must apply the specific controls and procedures set out in the policy and accompanying standard.

    All of Xprime Markets financial crime Group Policies are supported and endorsed by the Xprime Markets Board of Directors and apply to all Xprime Markets’ business dealings globally. All employees receive training on the financial crime Group Policies at least once a year, with more detailed and advanced training for those whose roles involve heightened risks. Failure to comply with the policies may give rise to disciplinary action, up to and including dismissal.

    Group Governance & Conformance

    Regular reviews of the effectiveness of these Group Policies are carried out in addition to audits periodically undertaken by the Xprime Markets Internal Audit function. This provides senior executive management oversight committees and the Board Audit Committee with the necessary assurance regarding the operating effectiveness of the Group’s controls.

    XPrime Markets Limited is registered in England Number 12450749 and with the Information Commissioner under the UK Data Protection Act, Number ZA296584.
    XPrime Markets Limited is authorised and regulated by the Financial Conduct Authority (Ref number: 931063).
    © 2021 XPrime Markets Limited. All Rights Reserved.