Legal

Reading this page should not be in place of reading the full terms and conditions of the company as they appear at https://coyken.com/about-us/legal/terms-and-conditions/

Summary Of Important Terms and Conditions

1. Every customer must send the required KYC documents as they appear at https://coyken.com/about-us/legal/kyc-policy-know-your-customer/
2. After every deposit a client makes to his / her account, the account will be automatically suspended until the account will be fully verified with the KYC documents.
3. Except for the initial deposit, after every deposit, the customer will have to sign a Declaration Of Deposit form (DOD) by hand or by e-signature (virtual signature). Until completing and signing the mentioned form, the account will be suspended and the customer will not have the option to trade, withdraw, or deposit funds.

1. Every withdrawal request must be done through the trading account and not by mail.
2. A customer may, at any time, withdraw any liquid funds (withdrawable balance) they have in the account – unless the mentioned funds are attached to the bonus t&c (to read more, please visit https://coyken.com/about-us/legal/bonus-terms-and-conditions/).
3. To prevent money laundering, a withdrawal will be sent only the same way the funds were deposited. If a deposit was made by a card, the funds will be sent only to the same card. If the deposit was made by a bank wire transfer, the funds will be sent only to the original bank account.
4. A client must approve every withdrawal telephonically with a representative of the company. If the client cannot approve it telephonically within 3 business days – the withdrawal will be cancelled and the client will have to open a new withdrawal request.
5. From the moment the withdrawal is processed it normally takes 4-7 business days to appear in the client’s bank account \ bank card.

1. Trading on leveraged CFD’s may be risky and not suitable for everyone. Do not trade with more money you can afford to lose. The leverage can work against you just as much as it can go in your favour.
2. coyken and its representatives are not financial advisors. Everything said by the company’s representatives is a recommendation and is not a guarantee. When in doubt you should always seek advice.
3. The client is fully responsible for the account’s gain or loss.

1. When clients register with Coyken they acknowledge their willingness to share with the company certain private information which we use for the purpose of confirming the client’s identity and ensuring the security of their deposits and trading account. This information is collected in line with our stringent verification procedures which are used to deter international money laundering operations and to ensure the security and safety of our customer’s trading activity throughout.
2. Our clients undertake to supply us with true, updated and accurate information about their identity. Furthermore they are required to state categorically that they are registering and trading on their own behalf and are not seeking at any time to act any manner which could be considered fraudulent nor are they seeking to impersonate any other individuals for any purposes whatsoever.
3. Coyken data collection procedures include the collection of client’s freely disclosed information as shared with the company, in addition to the placement of cookies for the purposes of gathering data about the manner in which client’s interact with the coyken website. These tools for gathering client’s information are employed for the purpose of ensuring the customer’s own security and all data collected by the company is shared only with individuals within the company who are involved with the verification of customer account information for the express purpose of ensuring the customer’s confidentiality and security.
4. Coyken will never disclose any private or otherwise confidential information in regards to our clients and former clients to third parties without the express, written consent of our clients, except in such specific cases in which disclosure is a requirement under law, or is otherwise necessary in order to perform verification analysis on the client’s identity for the purposes of safeguarding their account and securing their personal information.
5. By registering with coyken and through the voluntary interaction they undertake with Coyken products and services the clients confirm and agree that they consent to the use of all or part of the information they provide concerning their Coyken trading account, the transactions they undertake through it and the interactions which they perform with the company on behalf of the company. All interactions the customer undertakes with the company will be stored by the company for the purposes of record and as such may be employed by the company in such cases that disputes arise between clients and .
6. Coyken does its utmost to ensure the confidentiality of its clients personal information including the implementation of data protection procedures designed to ensure client confidentiality. coyken ensures that its data protection policy is regularly updated in order to ensure that client’s confidential information is continually safeguarded.
7. From time to time coyken may contact clients whether by phone or email for the purpose of offering them further information about Coyken financial market trading. In addition the company may, on occasion, seek to contact clients, whether by phone or by email, for the purpose of informing them of unique promotional offerings provided by coyken for the client. Clients consent to the receipt of such contact when they consent to our terms and conditions of use when registering with coyken. Any person wishing to opt out of further contact with Coyken at anytime whatsoever is entitled to do so, simply by contacting the company whether by phone or email and requesting that no further contact on behalf of the company will be made.
8. Coyken doesn’t sell or share private information.

I. Purpose

II. Policy

• act as a result of an inducement;
• promise issuers favourable research coverage.

• The Company or a relevant person, or a person directly or indirectly linked by control to the Company, is likely to make a financial gain or avoid a financial loss, at the expense of the client.
• The Company or a relevant person, or a person directly or indirectly linked by control to the Company, has an interest in the outcome of a service provided to the client, or of the transaction carried out on behalf of the client, which is distinct from the client’s interest in that outcome.
• The Company or a relevant person, or a person directly or indirectly linked by control to the Company, has a financial or other incentive to favour the interest of another client or group of clients over the interests of the client.
• The Company or a relevant person, or a person directly or indirectly linked by control to the Company, carries on the same business as the client.
• The Company or a relevant person, or a person directly or indirectly linked by control to the Company, receives or will receive from a person other than the client an inducement in relation to a service provided to the client, in the form of money, goods or services, other than the standard commission or fee for that service.

1. a member of the board of directors, partner or equivalent, manager or tied agent of the Company;
2. a member of the board of directors, partner or equivalent, or manager of any tied agent of the Company;
3. an employee of the Company or of a tied agent of the Company, as well as any other natural person whose services are placed at the disposal and under the control of the Company or a tied agent of the Company who is involved in the provision by the Company of investment services or/and the performance of investment activities;
4. a natural person who is directly involved in the provision of services to the Company or to its tied agent under an outsourcing arrangement for the purpose of the provision by the Company of investment services or/and the performance of investment activities.

1. Between the client and the Company.
2. Between two clients of the Company.
3. Between the Company and its employees.
4. Between a client of the Company and an employee/manager of the Company.
5. Between Company’s Departments.

• The Company is likely to sustain an overall financial loss or avoid a financial loss, by executing a client’s specific order.
• The Company is likely to sustain an overall financial gain by not executing a client’s specific order.
• The market moves to a direction of a point/timing when by executing client’s order will result in a financial loss for the Company.
• The Company’s hedging policy is affected negatively by the market movement and as a result client’s orders are rejected to prevent a financial loss for the Company.

A) Personal Transactions of Employees

• misuse or cause improper disclosure of confidential information;
• enter in a transaction that is likely to conflict with any obligations of the Company, or the employee, that are stated under the law.

B) Reporting Conflicts of Interest

• corrective and preventive actions;
• how these actions were considered appropriate;
• any conditions imposed; and
• whether there are still ongoing conflicts, how these are being managed and advised to the client;

C) Management of Conflicts of Interest

• Measures to prevent or control the exchange of information between relevant persons engaged in activities involving a risk of a conflict of interest (i.e. by establishing a Chinese wall)
• Separate supervision of relevant persons whose principal functions involve carrying out activities on behalf of, or providing services to, clients whose interests may conflict, or who otherwise represent different interests that may conflict, including those of the Company. The Company’s department whose interests may conflict with clients are:
  • Dealing Room
• Removal of any direct link between the remuneration of relevant persons principally engaged with one activity and the remuneration of, or revenues generated by, different relevant persons principally engaged in another activity, where a conflict of interest may arise in relation to those activities:
  • Dealing room employees do not relate their remuneration with clients’ performance
  • Measures to prevent or limit any person from exercising inappropriate influence over the way in which a relevant person carries out investment or ancillary services or activities. Additionally, the person who decides or influences an individual’s bonus may exert undue influence over that individual’s integrity of judgment
  • Measures to prevent or control the simultaneous or sequential involvement of a relevant person in separate investment or ancillary services or activities such as reception and transmission of clients’ orders and tasks such as portfolio decision making and calculating performance.

• Marketing Communication

• Record Keeping

• this policy, any functional variations if applicable;
• the Conflicts Log and the Conflicts Identification and Management Map;
• rules, procedures and processes;
• training material and training records;
• Conflicts of Interest Notification Forms;
• details of any review work carried out (including any decisions made on conflicts management); and
• any other documentation used to demonstrate the management of conflicts of interest.

• Responsibilities

• fully engage in the implementation of policies, procedures and arrangements for the identification, management and ongoing monitoring of conflicts of interest;
• adopt a holistic view to ensure the identification of potential and emerging conflicts within and across business lines and to ensure that informed judgments are made with respect to materiality;
• raise awareness and ensure compliance of relevant individuals by ensuring: regular training (including to contractors and third-party service providers’ staff) both at induction and in the form of refresher training; the clear communication of policies, procedures and expectations; that awareness of conflicts procedures forms part of the performance review/appraisal process, and that the best practice is shared throughout the Company;
• sponsor robust systems and controls and effective regular reviews to ensure that strategies and controls used to manage and mitigate risks remain appropriate and effective and that appropriate warnings and disclosures are issued to clients where necessary;
• utilize management information to remain sufficiently up-to-date and informed; and
• support an independent review of the processes and procedures in place.

• establishing the policy in relation to conflicts of interest;
• providing training oversight and aid;
• monitoring compliance with arrangements;
• the oversight of conflicts management;
• maintaining records in relation to conflicts of interest;
• reviewing and challenging the Conflicts Identification and Management Map; and
• providing appropriate internal reporting to the Board of Directors.

1. Introduction.

2. Definitions:

3. Procedure for Handling Client Complaints

• E-mail to info@coyken.com.
• The client’s name and surname.
• The clients trading account number.
• The identification numbers of the relevant orders and positions (if applicable).
• The date that the issue arose and the description of the issue.
• The capital and the value of the financial assets which belong to the client.
• Reference of any correspondent exchanged between the Company and the client.

• Upon receipt of the complaint, the client shall receive a formal written acknowledgement within five (5) business days by the Support Department. The client will also receive an email advising him that the complaint has been received and it is under review.
• The complaint will be reviewed and if deemed necessary it will be escalated to the Compliance Department, where the complaint will be addressed to be further verified and investigated.
• The events leading to the complaint or grievance and all the information provided by the client, will be examined and assessed for the purpose of reaching a fair outcome for both sides.
• The client will be constantly informed by the Company regarding the handling process of his/her complaint. Particularly, about the findings and proposed solutions that shall be clearly explained in written form to the client within the agreed time frame.
• If an issue cannot be resolved within the specified period due to the complicated nature of the complaint or if further clarification of circumstances is required, the complainant shall be notified about the new timeframes of response for the complaint. This shall not exceed a 3 months’ time frame. In the event that the Company is unable to respond within two months, it informs the complainant about the reasons for the delay and indicates the period of time within it is possible to complete the investigation. This time period cannot exceed three months from the submission date of the complaint.
• In case the Support Department is unable to respond within two months, it informs the complainant of the reasons for the delay and indicates the period of time within it is possible to complete the investigation. This time period cannot exceed three months from the submission date of the complaint.

• The Company has the right to refrain from reviewing a complaint when:
  • The complaint does not comply significantly with the format requirements as outlined in Section 3.1 – How to file a complaint
  • It does not enable to identify the applicant’s identity
  • It includes offensive language directed either to the Company or towards an employee of the Company.

4. Record Keeping

5. Review of the CHP

• The characteristics of the client;
• The characteristics of the client order;
• The characteristics of the financial instruments that are the subject of that order;
• The characteristics of the execution venues to which that order can be directed.

• Price
• Speed and likelihood of execution
• Costs or commissions
• Size and nature of the order
• Market conditions and variations
• Execution capability
• Any other direct consideration relevant to the execution of the order

In consideration of coyken (hereafter the “Company”) agreeing to enter into over-the-counter (“OTC”) contracts for differences (“CFDs”) and foreign exchange contracts (“FX Contracts”) with the undersigned (hereinafter referred to as the “Customer”, “you”, “your”), Customer acknowledges, understands and agrees that:

1. Trading is very speculative and risky.

Trading CFDs and FX Contracts is highly speculative, involves a significant risk of loss and is not suitable for all investors but only for those customers who:

understand and are willing to assume the economic, legal and other risks involved;
are experienced and knowledgeable about trading in derivatives and in underlying asset types; and
are financially able to assume losses significantly in excess of margin or deposits, because investors may lose the total value of the contract, not just the margin or the deposit.

Neither CFDs nor FX Contracts are appropriate investments for retirement funds. CFD and FX transactions are among the riskiest types of investments and can result in large losses. Customer represents, warrants and agrees that Customer understands these risks, is willing and able, financially and otherwise, to assume the risks of trading CFDs and FX Contracts and that the loss of Customer’s entire account balance will not change Customer’s lifestyle.

2. Risks related to long CFD positions, i.e. for purchasers of CFDs.

Being long in CFD means you are buying the CFDs on the market by speculating that the market price of the underlying will rise between the time of the purchase and sale.

As owner of a long position, you will generally make a profit if the market price of the underlying rises whilst your CFD long position is open. On the contrary, you will generally suffer a loss, if the market price of the underlying falls whilst your CFD long position is open. Your potential loss may therefore be bigger than the initial margin deposited. In addition, you might suffer a loss due to the closure of your position, in case you do not have enough liquidity for the margin on your account to maintain your position open.

3. Risks related to short CFD positions, i.e. for sellers of CFDs.

Being short in CFD means you are selling the CFDs on the market by speculating that the market price of the underlying asset will fall between the time of the purchase and sale. As owner of a short position, you will generally make a profit if the market price of the underlying asset falls whilst your CFD short position is open. On the contrary, you will generally suffer a loss, if the market price of the underlying asset rises whilst your CFD short position is open. Your potential loss may therefore be bigger than the initial margin deposited. In addition, you might suffer a loss due to the closure of your position, in case you do not have enough liquidity for the margin on your account to maintain your position open.

4. High leverage and low margin can lead to quick losses.

The high degree of “gearing” or “leverage” is a feature of both CFDs and FX Contracts. The effect of leverage makes investing in CFDs riskier than investing directly in the underlying asset. This stems from the margining system applicable to CFDs, which generally involves a small deposit relative to the size of the transaction, so that a relatively small price movement in the underlying asset can have a disproportionately dramatic effect on your trade. This can be both advantageous and disadvantageous. A small price movement in your favor can provide a high return on the deposit, however, a small price movement against you may result in significant losses.

Your losses will never exceed the balance of your account, which is balanced to zero, if the losses are higher than the amount deposited. Such losses can occur quickly. The greater the leverage, the greater the risk. The size of leverage therefore partly determines the result of your investment.

5. Margin Requirements.

Customer must maintain the minimum margin requirement on their open positions at all times. It is Customer’s responsibility to monitor his/her account balance. Customer may receive a margin call to deposit additional cash if the margin in the account concerned is too low. The Company has the right to liquidate any or all open positions whenever the minimum margin requirement is not maintained and this may result in Customer’s CFDs or FX Contracts being closed at a loss for which you will be liable.

6. Cash Settlement.

Customer understands that CFD and FX Contracts can only be settled in cash and the difference between the buying and selling price partly determines the result of the investment.

7. Conflicts of Interest.

The Company is the counterparty to all Transactions entered into under the Customer Agreement and, as such, the Company’s interests may conflict with yours. Our conflict of interest policy is available at the Company’s website.

There is no central clearing and no guarantee by any other party of Company’s payment obligations to the Customer, thus Customer is exposed to credit risk with the Company. Customer must look only to the Company for performance of all contracts in Customer’s account and for return of any collateral.

8. OTC Transactions.

When trading CFDs or FX Contracts with us, such Transactions will not be executed on a recognized or designated investment exchange and are known as OTC transactions. All positions entered into with us must be closed with us and cannot be closed with any other entity. OTC transactions may involve greater risk than investing in on-exchange contracts because there is no exchange market on which to close out an open position. It may be impossible to liquidate an existing position, to assess the value of the position arising from an OTC transaction or to assess the exposure to risk. Bid Prices and Ask Prices need not be quoted by us, based on best execution policies applicable in the market. There is no central clearing and no guarantee by any other party of the Company’s payment obligations to the Customer. The Customer must look only to the Company for performance of all contracts in the Customer’s Account and for return of any Margin or collateral.

9. CFDs and FX Contracts.

Trading CFDs and FX Contracts carries a high degree of risk. The gearing or leverage often obtainable in such trading means that a relatively small market movement can lead to a proportionately much larger movement in the value of your liability. You should be aware of the implications of this, particularly, the Margin requirements.

10. Prices, Margin and Valuations are set by the Company and may be different from prices reported elsewhere.

The Company will provide prices to be used in trading, valuation of Customer positions and determination of Margin requirements in accordance with its Trading Policies and Procedures.

The performance of your CFD or FX Contract will depend on the prices set by the Company and market fluctuations in the underlying asset to which your contract relates. Each underlying asset therefore carries specific risks that affect the result of the CFD concerned.

11. Extent of Losses.

Where you are short in the market and the price rises, it is possible that the extent of your losses may not become clear until the position has been closed. You must undertake sufficient analysis prior to entering into a Transaction to ensure you are able to support the extent of the risk arising.

12. Rights to Underlying Assets.

You have no rights or obligations in respect of the underlying instruments or assets relating to your CFDs or FX Contracts. The Customer understands that CFDs can have different underlying assets, such as stocks, indices, currencies and commodities.

13. Currency Risk.

Investing in FX Contracts and CFDs with an underlying asset listed in a currency other than your base currency entails a currency risk, because when the CFD or FX Contract is settled in a currency other than your base currency, the value of your return may be affected by its conversion into the base currency.

14. One click trading and immediate execution.

The Company’s online trading system provides immediate transmission of Customer’s order once Customer enters the notional amount and clicks “Buy/Sell.” This means that there is no opportunity to review the order after clicking “Buy/Sell” and Market Orders cannot be cancelled or modified. This feature may be different from other trading systems you have used. Customer should utilize the Demo Trading System to become familiar with the Online Trading System before actually trading online with the Company. Customer acknowledges and agrees that by using the Company’s online trading system, Customer agrees to the one-click system and accepts the risk of this immediate transmission/execution feature.

15. The Company is not an adviser or a fiduciary to customer.

Where the Company provides generic market recommendations, such generic recommendations do not constitute a personal recommendation or investment advice and have not considered any of your personal circumstances or your investment objectives, nor is it an offer to buy or sell, or the solicitation of an offer to buy or sell Foreign Exchange Contracts or Cross Currency Contracts. Each decision by Customer to enter into a CFD or FX Contract trading with the Company and each decision as to whether a transaction is appropriate or proper for Customer, is an independent decision made by the Customer. The Company is not acting as an advisor or serving as a fiduciary to Customer. Customer agrees that the Company has no fiduciary duty to Customer and no liability in connection with and is not responsible for any liabilities, claims, damages, costs and expenses, including attorneys’ fees, incurred in connection with Customer following the Company’s generic trading recommendations or taking or not taking any action based upon any generic recommendation or information provided by the Company.

16. Recommendations are not guaranteed.

The generic market recommendations provided by the Company are based solely on the judgment of the Company’s personnel and should be considered as such. Customer acknowledges that Customer enters into any Transactions relying on Customer’s own judgment. Any market recommendations provided are generic only and may or may not be consistent with the market positions or intentions of the Company and/or its affiliates. The generic market recommendations of the Company are based upon information believed to be reliable, but the Company cannot and does not guarantee the accuracy or completeness thereof or represent that following such generic recommendations will reduce or eliminate the risk inherent in trading CFDs and/or FX Contracts.

17. No guarantees of profit.

There are no guarantees of profit nor of avoiding losses when trading CFDs and FX Contracts. Customer has received no such guarantees from the Company or from any of its representatives. Customer is aware of the risks inherent in trading CFDs and FX Contracts and is financially able to bear such risks and withstand any losses incurred.

18. Customer May Not Be Able To Close Open Positions.

Due to market conditions which may cause any unusual and sharp market price fluctuations, or other circumstances the Company may be unable to close out Customer’s position at the price specified by the Customer and the Customer agrees that the Company will bear no liability for a failure to do so.

19. Internet Trading.

When Customer trades online (via the internet), the Company shall not be liable for any claims, losses, damages, costs or expenses, caused, directly or indirectly, by any malfunction, disruption or failure of any transmission, communication system, computer facility or trading software, whether belonging to the Company, Customer, any exchange or any settlement or clearing system.

20. Quoting Errors.

Should a quoting error occur (including responses to Customer requests), the Company is not liable for any resulting errors in account balances and reserves the right to make necessary corrections or adjustments to the relevant Account. Any dispute arising from such quoting errors will be resolved based on the fair market value, as determined by the Company in its sole discretion and acting in good faith, of the relevant market at the time such an error occurred. In cases where the prevailing market represents prices different from the prices the Company has posted on our screen, the Company will attempt, on a best efforts basis, to execute Transactions on or close to the prevailing market prices. These prevailing market prices will be the prices, which are ultimately reflected on the Customer statements. This may or may not adversely affect the Customer’s realized and unrealized gains and losses.

21. Compensation.

The Company participates in the Investor Compensation Fund for clients of Investment Firms regulated in the Republic of Cyprus. Customers will be entitled to compensation under the Investor Compensation Fund where we are unable to meet our duties and obligations arising from your claim. Any compensation provided to you by the Investor Compensation Fund shall not exceed twenty thousand euro (EUR 20.000). This applies to your aggregate claims against us.

22. Updates.

The Company has the right to amend the current Policy as per its discretion and at any time it considers is suitable and appropriate. In such an event the Company will notify the client accordingly. The Company shall review and amend the current policy at least on an annual basis. The Policy is available for review by clients upon request and it is uploaded to the Company’s website.

I /We have read, understood and agree to the risk disclosure statement and the trading policies and procedures set out above.

• A copy of your valid passport or government ID.
• Proof of address – a utility bill or a bank statement. The document should display your full name and residential address as well as a date of issue. It should not be older than 3 months.
• A copy or a clear picture of the debit/credit card used to make the deposit. Please ensure that the first 12 numbers in front of the card are not visible (you can cover it with a paper), the CVV (3 numbers at the back of the card) are not visible and you have manually signed the back of your card.
• A Declaration Of Deposit form signed by the trader after every deposit.

When do I need to provide these documents?

How can I send you these documents?

General

In order to ensure the compliance with international trade standards we operate exclusively in accordance with the legislation on combating illicit money laundering and countering terrorist financing. To monitor the accordance with legal requirements and recommendations of the FATF, we have established a Compliance department developing Anti-Money Laundering and Know Your Customer (AML / KYC) measures and procedures, obligatory for all employees and customers and determining the policy of engagement with any person who intends to become our customer.

The Compliance Department ensures that all the operations of the Company are consistent with the international standards to combat money laundering and all the documents provided by the customer are up-to-date and comply with relevant legal requirements.

AML / KYC rules

As our client you irrevocably agree with the following rules and undertake to observe them:

• You are obliged to follow our AML and KYC requirements while you are our client. Upon the request of the Company the additional documents and information should be provided by you. Filling of the respective KYC questionnaire may also be an obligatory requirement under the Company’s sole decision. You agree with such requirements of the Company and undertake to follow them;
• The withdrawal of any assets is carried out only to the account that belongs to you. The withdrawal of assets to third parties is prohibited. Internal transfers between the Company’s customers are also forbidden;
• The Company is obliged and has the right without obtaining prior consent to share with financial institutions and law enforcement agencies any information about you, as required by applicable law, and you give the Company your consent to these actions. In order to comply with this paragraph, the Company holds a record of your transactions for at least five years;
• You undertake to follow legislations, including international ones, aiming to combat illicit trafficking, financial fraud, money laundering and legalization of funds obtained by illegal means. You should use your best efforts to avoid direct or indirect participation in illegal financial activities and any illegal transactions using the Company’s website and services;
• You guarantee the legal origin, legal ownership and the right to use the assets transferred to your account. In case of the evidence of suspicious transactions in your account, cash replenishments from untrusted sources (for example, the data of assets’ sender and trading account owner is different) and / or any actions with attributes of fraud (including any refunds or cancellation of payments), the Company reserves the right to conduct an internal investigation, to block or close your trading account or any account, cancel any payment or trading order and to suspend operations on the accounts before the end of the official investigation. When making the decision the Company is guided by the provisions of the applicable law, FATF recommendations or by common practice;
• The Company has the right to request additional information about you if the method of withdrawal is different from the depositing method. The Company also reserves the right to block your trading account or any account during an investigation if you refused to provide the additional information requested by the Company;
• In the course of an investigation, the Company has the right to request additional copies of documents confirming your identity or identity of other individuals in corporate structure, as well as documents confirming place of residence and lawful possession and legal origin of funds. The Company also has the right to demand the provision of original documents for review in case of any doubts from the Company’s side;
• The Company does not provide services to the persons and legal entities who are located in the jurisdictions that are “blacklisted” by the FATF. Also, the Company does not provide services to citizens and residents of the U.S.A;
• The Company refuses to perform operations that from Company’s point of view are considered to be suspicious. The use of preventive measures (such as blocking or closing of a customer’s trading account or any account) is not the reason for civil liability of the Company for failure to fulfill obligations to you;
• The Company is not obliged to inform you or other persons about the measures taken to fulfil the AML/CFT legislation. Also, the Company is not obliged to inform you or other persons about any suspicions, about the reasons for refusal of execution of your trading order, refusal to open the account, need for providing any documents, etc;
• This document is just a summary, which goal is to clarify our rights and our intention to contribute in the worldwide AML initiative. However, each Company has its own internal AML&KYC procedures and rules, that may supplement rules specified in this summary. Nothing in this summary should be understood as an immutable rule that cannot be supplemented by a local AML policy of respective Company;
• This anti-money laundering and know your customer policy is an integral part of the any agreement concluded between you and the Company. Non-compliance with this policy can be grounds for termination of the agreement at the Company’s sole discretion.