Freemarket’s risk appetite is the aggregate level of risk that it is willing to assume within its risk capacity and in line with the business model, culture and ethics. Freemarket takes an appropriate risk-based approach to achieve its strategic and commercial objectives. The aim of this document is to provide guidelines on what types of business and associated risks the company would find acceptable and unacceptable. Within the overall risk framework, Freemarket has robust systems and controls that are proportionate to the nature and scale of the business, and which continually evolve to mitigate financial crime. With these systems and controls, Freemarket aims to Deter, Detect and Disrupt financial crime. Maintaining these and treating customers fairly, is at the heart of Freemarket and such standards are expected from all stakeholders. Freemarket has stringent procedures regarding the governance of its 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: Understanding what’s prohibited In recognition of the scale and extent of the business’s systems and policies, Freemarket prohibits engaging or pursuing clients that fall within the following set of criteria. Prohibited Locations Onboarding of a company with any UBO’s, Directors or Operations resident in or websites targeting the following sanctioned countries: Iran, North Korea, Syria, Cuba, Venezuela, Russia. You can view our unsupported jurisdictions list for a full list of countries we do not do business in or with. Prohibited Businesses The following list of categories of businesses and business practices are explicitly prohibited from using our services and platform: Businesses operating or running Hawala (informal banking system) Companies engaged in or providing illegal drugs and / or unlicensed drug related activity Unregulated pharmaceuticals / food supplement companies (nutraceuticals) Activities relating to defence and munitions, including dual use Adult websites or services with prostitution, and the broadcasting/publication of pornography Binary Options or unregulated investment and / or payment services activities Companies formed of bearer shares Company structures which include solely nominee directors; there must always be individual directors Companies dealing in counterfeit goods Cultural artefacts, ivory or other items related to protected species, or archaeological, historical, and religious significance, or of rare scientific value Companies structured and operating on Piracy or illegal streaming Political / religious organisations engaged in hate speech Pyramid Schemes / multi-level marketing (MLM) Companies dealing in non-electronic funds Unregulated or Shell Banks Shell companies (a company having no physical presence, no employees or no commercial activity in its registered jurisdiction) ‘Get rich quick’ schemes (proposal to pay high rates of return over a small period in return for a small investment) Unregulated charities Banks not located/domiciled onshore Additional requirements for the following industries Clients who fall into any one of the four verticals identified below must meet an initial set of criteria and further set of vertical specific criteria to onboard with Freemarket. Initial risk assessment criteria Must have no AML/CTF failings/fines that have not been sufficiently remediated Must adhere to Freemarket’s Industry specific policies i.e. FI Control Framework, Gambling Policy, Crypto Policy Must adhere to regulatory limitations applicable to the jurisdiction of their client-base Further risk assessment criteria by vertical The following are the additional risk assessment criteria to evaluate prospective clients by.