This document established the amount of risk Eqwire UK Limited (hereinafter referred to as “the
Firm”, “the Company”, “eqwire”, “Eqwire UK”, “we”, “our”, or “us”) is willing to accept in the pursuit
of its business objectives and the criteria of non-acceptable and acceptable customers to whom we
provide our services.
During its operations, the Firm aims at attracting customers within its business activities, according
to its internal segmentation, as follows:
The Company offers to the accepted customers its products and services in their respective segments.
The Company does not accept as a customer and does not perform transactions with, even if
occasionally, nominated entities which have been or still are under the restraint of international
sanctions of funds blockage.
The Company does not perform transactions involving goods or services contrary to legislation
regarding international sanctions of funds blockage and embargoes.
According to their associated risks, during the process of onboarding and due diligence, the customers
shall be classified in the following Anti-Money Laundering (AML) risk categories:
The category of “Unacceptable customers ” includes customers in one of the following situations:
The following is a list of business activities that we consider to be of prohibited risk. eqwire does not
offer services to clients in these categories and does not have a risk appetite for it.
Regarding Trusts, in particular, these are assumed to be unacceptably high risk (including where a
Trust is included in the beneficial ownership structure of a client) unless a clear rationale for the
existence of the trust can be obtained, along with acceptable documentation providing complete
clarity of the individuals involved in the trust. Such cases are subject to review and pre-approval by
the Compliance Function and acceptance by the acceptance Executive Risk & Compliance Committee,
as with all high-risk businesses, as well as being subject to review and acceptance from relevant
banking partners where required.
The category of “High-risk business and customers” includes businesses and customers in one of the
following situations:
The following is a list of business activities that we consider to be high-risk. The list is not exhaustive
and is reviewed on a quarterly basis.
Applications from such businesses are referred to the manual process for deeper review, a pre-
approval from the Compliance Function and approval by the Executive Risk & Compliance Committee
as to whether they are acceptable or not on a case-by-case basis.
Regarding Financial Services and Financial Technology businesses, the following are examples of sub-
sectors which would be of an acceptable risk level (though each business would still be subject to
individual review):
The category of “Medium risk customers” includes customers who do not fall under other risk categories.
The category of “Low-risk customers” includes customers in one of the following situations:
We are focused on attracting and servicing customers in the UK and the EU for the foreseeable future,
which reduces the risk. eqwire has no association with or processes transactions to the following
sanctioned countries:
Eqwire UK Limited will not enter into a business relationship with any client domiciled outside the EEA
and will not execute any transaction of the users domiciled in a country which is listed as prohibited
within our country risk assessment.
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