Risk Appetite Policy
As per the Money Laundering Regulations Act 2017, each regulated firm must exercise a ‘risk based approach’ to its Clients, products and business practices.
XCHANGE FINANCE operates a regimented system based upon processes.

5-step approach is:
● Identify the money laundering risks that are relevant to XCHANGE FINANCE LIMITED business;
● Carry out periodic risk assessments on various parts of XCHANGE FINANCE LIMITED business, focusing on Client behavior, delivery channels, patterns, irregularities and other;
● MLRO to design and put in place effective controls to manage and reduce the impact of the risks;
● MLRO/Compliance to monitor the controls and improve efficiency;
● Maintain records of processes/systems that were checked and why we checked them. The results of XCHANGE FINANCE LIMITED annual risk assessment will be presented and approved by the Board of directors.

Xchange Finance Limited expect our customers to value and show similarly high ethical principles, high standards of compliance and risk management. Xchange Finance Limited has strict policies regarding trading with PEP’s, sanctioned counterparties, criminals and persons involved with terrorism. In addition to the common practice of prohibiting payments linked to illegal activities, Xchange Finance Limited prohibits industries, payment linked to the following business activities:

● Unregulated financial services (where licensing required)
○ Pyramid schemes / multi-level marketing (ML)
○ Hawala
○ Unlicensed FX broker
○ Binary options
○ Get rich quick schemes
○ Unlicensed gambling (e.g. provision of services using offshore licence)
● Crypto-currency
○ Facilitating the exchange of anonymous crypto-currency
○ Unlicensed facilitation of security tokens (e.g. tokens that have characteristics akin to traditional instruments like shares, debentures or units in a collective investment scheme)
● Unregulated pharmaceuticals / food supplements (e.g.“nutraceuticals”)
● Piracy or illegal streaming
● Counterfeit goods
● Arms / dual-use goods
● Unregistered Charities
● Carbon Credits
● Multi-Level Marketing
● Pawnbrokers
● Drug paraphernalia
● Unlicensed charities
● Shell companies
● Companies formed of Bearer Shares
● Remittances funded in cash
● Offshore and shell banks
● Adult Entertainment
● Firms involved in the servicing of illegal goods/services including but not limited to: Counterfeit Goods/trademark infringement, Human Trafficking, Child Labour, Prostitution
● Fifth-party payments & multi-layered MSB arrangements
● Financial Institutions making payments on behalf of other financial institutions, also known as ‘nested relationships’ or ‘Layering’
● Political / religious organisations engaged in hate speech
● Jurisdiction Jurisdictions listed by the IMF as Offshore Financial Centres and European Commission blacklist - Common EU list of third country jurisdictions for tax purposes

Prohibited business activities
XCHANGE FINANCE in considering money laundering risks, regulations and guidance decided that certain types of relationship are unacceptable:

● shell banks;
● individuals or entities that are on relevant sanctions lists issued by countries in compliance with UN resolutions or to which countries have applied sanctions unilaterally (UK, US and others);
● individuals or entity whose identity cannot be verified or who refuses to provide information required to verify identity or required for account opening purposes;
● who has provided information that contains inconsistencies that cannot be resolved after further investigation;
● Where there is suspicion or evidence of found, money laundering or other criminal activity or involvement;
● If falsified documentation or information is detected during the account opening/relationship establishment process;
● Individuals, entities and organizations sanctioned by UN, EU, LV, HM Treasury list or OFAC; An account using a pseudonym or number rather than the actual name of the Client;
● Anonymous ownership entity accounts, where the ownership of the entity cannot be determined because the entity has a form or structure that prevents an account accurate identification of the Beneficial Owners;
● Unlicensed financial institutions, including unlicensed currency exchange houses and money transmitters and Persons involved in unlawful internet gaming business;
Merchants, whose business Merchant Category Code (MCC) is included into the International Card organizations prohibition list.

Failure to comply with these restrictions can result in delayed payments or rejected payments with continuous breaches leading to account closure

Xchange finance reserve the right to report and disclosе the information to law enforcement authorities.