Strict Regulation Compliance

SpotFX is works to meet strict financial regulation standards including capital adequacy requirements. The regulators require several that our company: * Maintains sufficient liquid capital, * Does not include any debt outstanding to the company as part of this capital, * Holds deposits with reputable financial institutions. All funds, whether they are classified as company funds or client funds, are kept in the safest top-tier banks such as Barclays Commercial and Deutsche Bank. Segregation of Client Funds SpotFX is obliged to segregate the money that our clients deposit with us. This means that we take steps to ensure that our clients’ money is held in a separate account away from any accounts used to hold money belonging to the firm. The purpose of this separation is to prevent the use of clients’ money by the firm for its own account at all times. In terms of where the client funds should be held, i.e. with which institution, we are obliged to exercise all due skill, care and diligence in our selection, taking into account the expertise and market reputation of the institution. SpotFX segregates all funds clients deposit with us in client accounts that we hold with top tier banks, including Barclays Bank and Deutsche Bank. Conflicts of Interest Statement Introduction As an investment firm, SpotFX faces potential conflicts of interest. By identifying the existing and potential conflicts of interest, SpotFX endorses all reasonable steps to establish, implement and maintain an effective conflicts of interest policy to prevent any risk that may damage the interests of our clients. This statement discloses the conflicts of interest you, as an existing client or potential client might face when engaging in business dealings with SpotFX; the laws and regulations subject to conflicts of interest that SpotFX is required to comply with; and the policy SpotFX adopts for the aim of preventing and managing the conflicts of interest. Identification and Examples of Conflicts that might arise In general, conflicts of interest may be caused by the superior knowledge of employees and the variety of products on offer and may arise between a firm and a client, or between a client and another client. When a firm provides service to a client, conflicts of interest may arise in one or more of the following situations when a firm or a relevant person: * is likely to make a financial gain, or avoid a financial loss, at the expense of the client * has an interest in the outcome of a service provided to or a transaction carried out on behalf of the client, which is different from the client interest in that outcome; * has a financial or other incentive to favour the interest of another client(s) over the interests of the client; * carries on the same business as the client; or * receives or will receive from a person other than the client an inducement, other than standard commission or fee in relation to a service provided to the client (e.g. our Partnerships Department). In respect to SpotFX , the following are some of the main conflicts of interest that may occur when providing services to our clients; (a) When SpotFX executes a transaction for you, we are entering into the trade as principal and; (b) You may have been introduced to us by a third party who receive remuneration from your trades Laws and Regulations SpotFX recognizes that conflicts of interest exist in financial services industry and we are set out to manage conflicts of interest fairly, both between the company and our customers and between a customer and another client (introducing brokers). Furthermore, our management arrangements and systems and controls are required to manage the conflicts so that they do not damage the interest of any client. SpotFX Policy SpotFX implements and maintains an effective conflicts of interest policy for the aim of preventing conflicts of interest or potential conflicts of interest from causing a material risk of damage to the interests of clients. SpotFX keeps record of its business activities so that it can identify any conflict that might entailing a material risk of damage to the interests of our clients. SpotFX conflicts of interest policy adopts procedures and measures to manage and control the conflicts of interest identified; acting on the best interest of the clients; and in some cases declining to act for a client or potential client. Review SpotFX is devoted to provide more services and products to meet our clients’ demand. At the same time, SpotFX frequently reviews and assesses our conflicts of interest policy so that can ensure the adequacy of such policy. SpotFX statement on Anti Money Laundering and Financial Crime SpotFX serves many thousands of customers around the globe and is committed to participating in international efforts to combat Money Laundering and preventing financial crime. SpotFX implements a program that includes the following principals: * Policies and procedures * Money Laundering Reporting * Identification of all relevant clients * Training of all relevant staff * Retention of records * Staff being subject to Personal Account Dealing rules * Operation of a Code of Conduct and whistle blowing policies By following the principals above, the firm aims to comply with all relevant rules and regulations regarding financial crime issues in the currency trading environment.