2. Criteria for detection and characteristics of suspicious non-trading operations
2.1. A non-trading operation may be recognised as suspicious by the Company in the following cases:
– the Company has detected excessive transfers (deposits to the client's account, withdrawals from the client's account) without making trading operations in the trading account;
– the Company has detected an unusual nature of the transactions, which have no evident economic sense or evident legal purpose;
– the Company has uncovered circumstances that give reason to believe that the transactions are aimed at legalisation of criminal proceeds (money laundering) or financing of terrorism;
– within the period set by the Company, the Client failed to provide information to identify himself/herself, provided unreliable information and/or it is impossible to contact the Client using the addresses and telephone numbers provided;
– the Client has not provided information to identify a beneficiary, i.e. the person in whose interests the Client acts (in particular, under an agency agreement, trust deed, commission agreement and fiduciary management agreement when non-trading operations are performed);
– submission of false or invalid documents and documents of poor quality (black and white, unreadable);
– the Client has not provided information to identify a beneficiary (end beneficiary), i.e. the person in whose interests the Client acts (in particular, under an agency agreement, trust deed, commission agreement and fiduciary management agreement when non-trading operations are performed) upon the Company's request;
– the Client has not provided any information and documents requested by the Company, including about the Client's financial standing.
2.2. Criteria for detection and indicators of suspicious transactions specified in this section of the Regulation are not obligatory or exhaustive. A non-trading operation may be recognised as suspicious by the Company on the basis of analysis of the nature of the transaction, its components, attendant circumstances and interaction with the Client or his/her representative even if formally there are no criteria and indicators specified in this section of the Regulation. Such transactions are detected on the basis of the Company's subjective evaluation by means of daily analysis of non-trading operations.
2.3. When suspicious non-trading operations are detected, it is the Company that makes decisions regarding further actions with respect to the Client and his/her trading and non-trading operations.
3. Payments and general provisions regarding non-trading operations
3.1. The Client may transfer funds to the Client's account at any time. The Client's money is kept in the Company's accounts, including in segregated accounts opened in the name of the Company for keeping clients' money separate from the Company's money.
3.2. Transactions involving the transfer of funds to/from the Client's account are governed by this Regulation.
3.3. The Client himself/herself is responsible for the correctness of payments he/she makes. If the Company's banking details change, once the new details are published in the Trading Terminal the Client himself/herself will be responsible for payments made using outdated details.
3.4. Each of the Client's non-trading operations shall be confirmed with an entry in the respective section of the Trading Terminal. If the Client finds an error in the entry regarding a non-trading operation, he/she shall make a claim in accordance with the requirements of the Agreement.
3.5. If the Client finds an error in the entry in his/her favour, he/she shall inform the Company about the error as soon as possible using the contact information posted on the Company's Website.
3.6. If the Company's Client performs no transactions in the trading terminal that result in a change in the Client's account balance for 6 months, the Company reserves the right to introduce a subscription fee (commission) for granting access to the trading terminal. The amount and procedure of the fee deduction will be determined by the Company at its sole discretion.
4. Transfer of funds to the Client's account