Terms and Conditions

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    Anti-Money Laundering Policies-Aron Broker Ltd (Mauritius)-Effective Date: July 2024

    

  • ACKNOWLEDGMENT

     

    The present document has been prepared after thorough review by the Board of Directors and Senior Management.

    The document should be read in conjunction with:

    • The Anti-Money Laundering and Countering the Financing of Terrorism Handbook, 2020, Updated on 21 September 2022;
    • The Financial Intelligence and Anti-Money Laundering (FIAML) Regulations 2018;
    • The Financial Intelligence and Anti-Money Laundering Act (FIAMLA) 2002;
    • The Anti-Money Laundering and Combating the Financing of Terrorism (Miscellaneous Provisions) Act 2020;
    • The Guidelines on the Implementation of Targeted Financial Sanctions Under the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019 on 25 August 2020;
    • The United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019;
    • The FIU, Guidance Note 4 on Suspicious Transaction Report on 21 January 2014 (updated November 2020).

     

    Application and Responsibility

     

    • The contents of this Manual apply to all employees, including but not limited to the directors, authorized individuals, managers, executives and interns of Aron Brokers Ltd (collectively EMPLOYEES), whether employed full time or part time.
    • It is the responsibility of all EMPLOYEES to read, understand and observe all the rules and procedures applicable to them, both in letter and in spirit. Failure to comply with the rules and procedures contained herein will constitute serious misconduct.
    • The overall responsibility of information dissemination and ensuring compliance lies with the Compliance Officer.
    • If you become aware of a violation of this manual, if you are instructed by your superior to act in contravention of this manual, or if you find yourself inadvertently in contravention of this manual, you must not hesitate to report such contravention to the Compliance Officer.
    • This is the first edition of the AML/CFT/GRC Operations Manual (herein referred to as, the Manual). The Manual shall be reviewed annually and at the point of a material change in the AML/CFT legal requirements as prescribed under the Financial Intelligence and Anti-Money Laundering Act (FIAMLA), FIAML Regulations, the FSC AML/CFT Handbook, amongst others. The same shall be updated on a regular basis and the latest version control applies. Should the changes required be substantial, the Compliance Officer shall request the senior management to call a meeting with the Board and review the Manual in its entirety and make the necessary revisions.

     

    Aron Brokers Ltd. shall be referred to as “the Company or Aron Broker”, throughout the Manual.

     

    PART I – GOVERNANCE, RISK AND COMPLIANCE (GRC)

    1.    Introduction

    1.1.  Why Governance, Risk and Compliance

    • Compliance with regulatory requirements, prudential norms and industry best practices enhances the efficiency and reputation of Aron Brokers Ltd (the Company), boosts investor confidence and helps the management to fulfil stakeholder’s expectations of integrity.
    • Compliance with laws, rules and standards also covers matters such as observing proper standard of market conduct, ethical business practices, managing conflicts of interest, and fair treatment of clients and stakeholders. Compliance needs to be integrated into the culture of a company and shall have to be reinforced by a close alignment of values, processes and rewards. A holistic approach to compliance ensures that the benefits of compliance far exceed the related costs.

    1.2.  Risk of Non-Compliance

    • The compliance risk is defined as the risk of impairment to the Company business model, reputation and financial condition (resulting) from a failure to meet laws, regulations, internal standards and policies, and expectations of key stakeholders such as clients, employees and society as a whole.
    • Failure to comply with the FIAML Regulations 2018 and the FIAMLA may result in a fine not exceeding one million rupees and to imprisonment for a term not exceeding 5 years, according to the FIAMLA Section 32A of 2002, and Regulation 33 of the FIAML 5 Regulations 2018.

     

    2.    GRC at Aron Brokers Ltd

    • At the Company, we place the highest priority on complying with rules and regulations required by the authorities.
    • The commitment for compliance starts at the highest levels of the firm. Our core principles of governance and compliance are to:
      • Maintain a compliance function: The role of the compliance function is to identify, asses, advice on, monitor and report on the Company’s compliance with regulatory requirements and the appropriateness, effectiveness and integrity of its supervisory procedures.
      • Act in a professional and ethical manner for the benefit of clients and always put client’s interest first; communicate with clients and others in a clear and fair manner.
      • Act with independence and objectivity; avoid relationships that may impair or appear to impair our independence and objectivity.
      • Uphold the rules governing capital markets transparency and disclosure requirements and comply with letter and spirit of laws and regulations; Develop a business culture that values and promotes not only compliance with the letter of the law, but also a high ethical and investor-protected standard.

     

    3.    Responsibilities of the Board of Directors for GRC

    • The Governing Board is responsible for overseeing the management of the Company’s governance and compliance. The Board should approve the Company’s GRC policy, including a formal document establishing a permanent and effective compliance function. At least once every year, the Board should assess the extent to which the Company is managing its compliance risk effectively.
    • The Board clearly understands that compliance policies will not be effective unless the Board promulgates the values of honesty and integrity throughout the Company. Accordingly, the Board has committed to ensure that appropriate policies are in place to manage the compliance, and employees are made aware of these policies and the modes of implementation.
    • The Board and Senior Management shall review and approve all policies, procedures, controls and manuals, prior to be put in use. The policies, procedures, controls and manuals shall have the Board approval date in it.
    • The Board will oversee the implementation of the policies and ensure that compliance issues are resolved effectively and expeditiously by Senior Management with the assistance of the compliance function.
    • The Company must ensure that the training provided to officers and employees is comprehensive and ongoing and that the officers and employees are aware of ML and TF, the associated risks and vulnerabilities of the Company, and their corresponding obligations.
    • As part of compliance arrangements, the Company is responsible for appointing a Compliance Officer (CO) who is responsible for the implementation and ongoing compliance of the Company with internal programmes, controls and accordance with the requirements of the FIAMLA and FIAML Regulations 2018.
    • In Addition to appointing a CO, an independent audit function to test the ML and TF policies, procedures and controls of the Company should be maintained.

     

    4.    Responsibilities of Directors for GRC

    • To design, establish and maintain a compliance function and related policies and procedures, keeping in mind the prevalent regulatory practices of the region where the company operates and the strategic moral and ethical obligations of the firm to its stakeholders.
    • To designate a suitable person who has the appropriate competence, to have the day-to- day responsibilities for the firm’s compliance with regulatory requirements.
    • To identify and assess on an ongoing basis the new or changed compliance requirements applicable to the company by any regulatory authorities; and take steps to modify existing policies and procedures to comply with the new or changed requirements.
    • To provide compliance advice and support in relation to new business initiatives and ensure that a robust compliance infrastructure is implemented for any new initiatives that are undertaken.

     

    5.    Money Laundering & Terrorism Financing (ML & TF), and Responsibilities of the MLRO

    • The appointment of a MLRO will be assigned in accordance with Regulations 26(1) of FIAML Regulations 2018.
    • It is imperative that every financial institution appoints an appropriate MLRO who must be of sufficiently senior status and not below the rank of Manager.
    • The MLRO officer or the Alternate/Deputy MRLO (DMLRO) must make sure that all sources of funds are supported by the relevant documents. It is very important that the MLRO adopt the policy of Know Your Client (KYC) framework as outlined in the Manual.
    • The MLRO must ensure that the clients are running according to the business plan. Any change in business activity must be addressed to the clients.
    • A proper CDD must be made to each client. Relevant online sources as well as reports provided by the authorities must be checked to ascertain if the client is risky either by virtue of Politically Exposed Person (PEP) status or has the name listed as terrorist, as listed by the US. In the case of a former PEP, it is incumbent on the MLRO to ensure that procedures are followed for enhanced due diligence and monitoring.
    • Countries with deficiencies in their AML regime will need enhanced due diligence.
    • Any suspicious transaction must be reported to the Board and the Financial Intelligence Unit (FIU) using the appropriate forms found in the Manual.
    • It is important to note that the Board has given the MLRO the freedom to make his or her decision and without influence, pressure or fear of repercussions if the senior colleagues disagree with his / her decision.
    • The MLRO shall exercise his reasonable judgement in deciding whether certain Client’s DD documentation should be acceptable to the Company, subject to the laws and practices of the Client’s jurisdiction.
    • Important Aspects Loita Management Services Limited (LMS) has a Compliance Due Diligence agreement with the Company. Therefore, the MLRO and Compliance Officer are LMS’s employees.

     

    The responsibilities of the MLRO will normally include, as stated in the FIAML Regulations 2018:

    • To undertake a review of all internal disclosures in the light of all available relevant information and determining whether or not such internal disclosures have substance and require an external disclosure to be made to the FIU;
    • To maintain all related records.
    • To give guidance on how to avoid tipping off the client if any disclosure is made.
    • To liaise with the FIU and if required the FSC and participating in any other third-party enquiries in relation to money laundering or terrorist financing prevention, detection, investigation or compliance.
    • To provide reports and other information to the Board, if any cases encountered; and to produce in an annual basis (initially) the MLRO Report and submit the same to the Board.

     

    6.    Responsibilities of the Compliance Officer (CO)

    • To ensure effective management of the company’s compliance function.
    • To advise management, during the inception of new business processes, of the underlying integrity and compliance implications of these processes.
    • To ensure corporate-wide communication of the compliance policy and its implementation and to report to the directors on the management the Company’s compliance risk.
    • To act as a central repository of all information on rules, codes and business practices and ensure dissemination to all appropriate people in the organization.
    • To establish detailed written compliance procedures that should be followed by all staff members.
    • To ensure that the compliance policies and procedures are observed and breaches, if any, are remedied immediately and disciplinary actions, if required, are taken against the personnel responsible for the breach.
    • To regularly report to the Board on compliance issues (if any cases encountered) and to make an informed judgment on the effectiveness corporate-wide compliance policy.
    • To produce in an annual basis (initially) a Compliance Report and submit the same to the Board.
    • To report promptly to the Board, of any material compliance failures (e.g., failures that may attract a significant risk of legal or regulatory sanctions, material financial loss, or loss to reputation).
    • To liaise with the Finance Officer to ensure accuracy of financial recording and compliance with established accounting standards (IFRS);
    • To ensure that all requests and instructions of regulators are complied with in a timely and accurate manner.
    • To ensure that day to day compliance monitoring and administration are carried out to specified standards.
    • To ensure that all registrations with the FSC and other regulatory authorities are current and up to date.
    • To work with the legal advisors and ensure that valid agreements with contracting parties or counterparties are put in place for new business initiatives.
    • To update compliance manuals and procedures.
    • To arrange training and development of staff on regulatory responsibilities.

     

    7.    Independent Compliance audit

    The FIAML Regulations 2018 requires the audit process to be carried out independently.

    The audit functions should be independent of, and separate to the executive team dealing with the Company’s Anti-Money Laundering (AML) and Combating Financing of Terrorism (CFT) processes. The auditor must not have been involved in the development of the risk assessment, or the establishment, implementation, or maintenance of the Company’s AML / CFT program. An independent audit function shall be appointed by the Company, in order to test the ML and TF policies, procedures and controls that should be maintained.

     

    7.1.  Independent Compliance Audit Frequency

    Independent compliance audit shall be conducted Annually and/or when there has been a major change in the AML / CFT risk assessment, policies, or procedures.

    7.2.      Independent Compliance Audit Depth

    The appointed Independent Audit Function shall:

    • Evaluate how the Company adheres to rules, regulations and laws.
    • Cover the adequacy and effectiveness of the Company’s policies, systems, controls, and procedures relating to AML/CFT. This is done by having a detailed plan covering access to information and relevant staff, testing of the effectiveness of existing procedures and controls and any automated systems in use by the Company, random selection of transactions/files for review and record-keeping.
    • Verify if the AML/CFT program adopted by the Company is adequate and effective; and
    • Advise on any changes that may be required.

     

    The Independent Audit shall test compliance in the following areas:

    • AML / CFT policies and procedures.
    • Internal risk assessment.
    • Risk assessment on the use of third-party service providers (Outsourcing).
    • Compliance Officer function and effectiveness.
    • MLRO function and effectiveness.
    • Implementation and effectiveness of mitigating controls, including customer due diligence and enhanced measures.
    • AML / CFT training.
    • Record keeping obligations.
    • Targeted Financial Sanctions (TFS);
    • Suspicious transaction monitoring and reporting; and
    • Technological reliance and effectiveness.

     

    8.    Internal Due Diligence and Training

    8.1.  Screening

    As part of the process of hiring staff members, the Company must ensure that the same are screened against the required numerous Sanctions, PEP, Criminal related lists as well as adverse media results, prior to finalizing the hiring process. This is conducted to assist in the prevention and detection of financial crime, as well as to ensure that the Company is compliant with the existing regulations.

    Screening of existing Staff Members and the Company’s Stakeholders in general should also be conducted periodically as part of the Company’s Business Risk Assessment (BRA).

     

    • Screening for PEPs & PEPs by Association
      • Potential Employees are screened against the PEP list to verify if any positive hit is
      • It shall be determined whether the potential employee is a PEP or PEP by association.
      • The Compliance shall conduct an EDD Assessment, including a recommendation, and submit it to the Board/Senior Management in such cases.
      • Board/Senior Management shall decide whether to proceed or not with the hiring process.

     

    • Screening against Sanctions Lists
      • Potential Employees are screened against Sanctions lists, as required by the Commission.
      • In the event that a positive hit is triggered by the screening process, an EDD Assessment shall be conducted and submitted to the Board/Senior Management.
      • Potential Employee job application shall not be carried forward and further action shall be taken as per required by law / regulations / the Commission.

     

    • Screening against Crime Related Lists
      • Potential Employees are screened against criminal related lists;
      • In the event that a positive hit is triggered by the screening process, an EDD Assessment shall be conducted and submitted to the Board/Senior Management;
      • Potential Employee job application shall not be carried forward and further action shall be taken as per required by law/regulations/ the commission.

     

    • Screening for Adverse Media Results
      • Potential Employees are screened against several internet articles that have been made available to the public, in order to find any related adverse media results;
      • In the event that a positive hit is triggered by the screening process, the compliance shall verify the gravity of the results and give its feedback and recommendation to the Board/Senior Management on the EDD Assessment Report.

     

    8.2.  Training

    While there is no single or definitive way to conduct training, the critical requirement is that training is adequate and relevant to those being trained and that the content of the training reflects good practice.

    Training shall be carried out to meet the requirements of FIAML Regulations 2018, if new legislation or significant changes to this Handbook are introduced, or where there have been significant technological developments within the Company or with the introduction of new products, services or practices.

    The guiding principle of all AML and CFT training should be to encourage and ensure that directors, officers and employees, irrespective of their level of seniority, to understand and accept their responsibility to contribute to the protection of the financial institution against the risks of ML and TF.

    The Company shall keep records containing information and data regarding the attended trainings.

     

    • Scope, Content and Methodology of training
      • In accordance with Regulation 22(1)(c) of FIAML Regulations 2018, the ongoing training provided by the Company shall cover:
        • The FIAMLA, FIAML Regulations 2018, any AML / CFT Code issued by the FSC and this Handbook;
        • The implications of non-compliance by employees to requirements of FIAMLA, FIAML Regulations 2018, any AML / CFT Code issued by the FSC and this Handbook; and
        • The Company’s policies, procedures and controls for the purposes of foreseeing, preventing and detecting ML and TF.
      • New and existing employees, officers, Board members and Senior Management must have a good understanding of the Company’s business activities, functions and its AML / CFT policies and procedures.
      • Staff Members (including Senior Management) shall attend AML / CFT related training and acquire the equivalent of 10 hours (minimum) of CPDs per Year.
      • In-house training covering the Company’s AML / CFT Policies and procedures.
      • In-house training, on how to use the Company’s compliance due diligence software, shall be provided to all relevant staff members.
      • New employees and existing employees shall be given graded tests pertaining to the in-house training. The grades will impact on the employees’ Annual Reviews at the end of the Financial Year.
      • Staff members shall be required to provide a report / summary to Senior Management and CO, of the attended courses, webinars, seminars and trainings. The evaluation of the reports shall form part of the Annual Reviews and impact the result of the same.
      • The Company’s staff members shall receive a training program and shall be requested to attend certain trainings, seminars, webinars or courses.
      • The Company shall ensure that the ongoing training provided to directors, officers and employees also covers, to a minimum:
        • The requirements for the internal and external disclosing of suspicion.
        • The criminal and regulatory sanctions in place, both in respect of the liability of the Company and personal liability for individuals, for failing to report information in accordance with the policies, procedures and controls of the Company.
        • The identity and responsibilities of the MLRO, CO and DMLRO.
        • Dealing with business relationships or occasional transactions subject to internal disclosure, including managing the risk of tipping off and handling questions from customers.
        • Those aspects of the Company’s business deemed to pose the greatest ML and TF risks, together with the principal vulnerabilities of the products and services offered by the Company, including any new products, services or delivery channels and any technological developments.
        • New developments in ML and TF, including information on current techniques, methods, trends and typologies.
        • The Company’s policies, procedures and controls surrounding risk and risk awareness, particularly in relation to the application of CDD measures and the management of high risk and existing business relationships.
        • The identification and examination of unusual transactions or activity outside of that expected for a client.
        • The nature of terrorism funding and terrorist activity in order that employees are alert to transactions or activity that might be terrorist- related.
        • The vulnerabilities of the Company to financial misuse by PEPs, including the effective identification of PEPs and the understanding, assessing and handling of the potential risks associated with PEPs;
        • UN, EU and other sanctions and the Company’s controls to identify and handle natural persons, legal persons and other entities subject to sanction; and
        • Interruption or stop of the performance of a CDD process and file a STR, if the Company reasonably believes that the performing it will tip off the client or potential client.
      • The Board and senior management shall receive adequate training to ensure they have the knowledge to assess the adequacy and effectiveness of policies, procedures and controls to counter the risk of ML and TF. The additional training provided to the Board and Senior Management must include, at least, a clear explanation and understanding of:
        • Offences and penalties arising for non-reporting or for assisting money launderers or those involved in terrorist financing.
        • Requirements for CDD including verification of identity and retention of records; and
        • In particular, the application of the Company’s risk-based strategy and procedures.
      • Ongoing professional development, including participating in professional associations and conferences, is vital for MLROs / DMLROs. In addition, MLROs and DMLROs should receive in depth training on all aspects of the prevention and detection of ML/TF, including, but not limited to:
        • AML / CFT legislative and regulatory requirements.
        • The international standards and requirements on which the Mauritius’ strategy is based, namely the FATF 40 Recommendations and ML / TF typology reports that are relevant to their business.
        • The identification and management of ML / TF risk
        • The design and implementation of internal systems of AML / CFT control.
        • The design and implementation of AML / CFT compliance testing and monitoring programs.
        • The identification and handling of suspicious activity and arrangements and suspicious attempted activity and arrangements.
        • The money laundering and terrorist financing vulnerabilities of relevant services and products.
        • The handling and validation of internal disclosures.
        • The process of submitting an external disclosure.
        • Liaising with law enforcement agencies.
        • ML / TF trends and typologies; and
        • Managing the risk of tipping off.
      • The CO is responsible for ensuring continued compliance with the requirements of FIAMLA and FIAML Regulations 2018 and having an overall oversight of the program for combatting ML / TF amongst others – Regulation 22(3) of FIAML Regulations 2018.
      • The CO should receive in depth training on all aspects of the prevention and detection of ML / TF, including, but not limited to, addressing the monitoring and testing of compliance systems and controls (including details of the Company’s policies and procedures) in place to prevent and detect ML / TF.

     

    9.    Cost of Compliance

    • There is a cost to compliance which needs to be factored into the operations of the Company.
    • Prior to the annual budget preparation, the Compliance Team should be consulted about their budget and expectations.
    • The budget allocated to the project will directly correlate to the Company’s risk exposure.
    • If there are budget cutbacks, these need to be clearly explained and documented.

     

    10. Conduct of Business Policies in Governance & Compliance

    10.1.      Client Restrictions

    Aron Brokers Ltd must ensure that the business is conducted only with genuine and trustworthy clients

    • Our procedures will ensure a check on the individual client’s past experience and CDD
    • And relevant KYC check.
    • We will devise appropriate systems and controls that shall ensure that the financial status of the individual client and his/her credentials to qualify as a client are checked prior to being admitted as a client.

     

    10.2.    Responsible Conduct

    As a registered company providing Global Business Services, including “Investment Dealer Licence (excluding underwriting)”, it is our professional and ethical responsibility to conduct ourselves in the most responsible manner and with clients’ best interests in mind.

    The client’s interest is paramount to the firm. We are responsible to safeguard our client’s interest, to avoid conflict of interest situations, to communicate with the client in an honest and fair manner, deal fairly and objectively with the clients and treat all clients fairly and equally.

     

    10.2.      Conflict of Interest

    • All clients shall be treated fairly. Any conflict of interest between the client and the firm shall be avoided.
    • Client interests are paramount. All employees of our company including Managers should ensure that client interests supersede employees’ interests in all aspects of client relationship, including (but not limited to) recommendations, advice or change in prior recommendations and actions.
    • Where the conflict of interest is unavoidable such conflicts shall be managed in such a way that the client’s interest has priority and is protected. If the conflict of interest is of a significant nature, the firm shall decline to act for the client.
    • We must not act, or cause others to act, on material non-public information or knowledge that could affect the value of a publicly traded investment. Procedures shall be established to create effective information barriers (“Chinese walls”) to prevent the disclosure and misuse of material non-public information.

     

    10.3.      Dealing with Clients’ Money

    Segregation of client money in a separate CLIENTS Bank account is important and money is to be monitored and documented.

     

    11. Confidentiality

    We will treat all information collected from its clients and employees for the purpose of carrying out its business or administrative functions as confidential.

     

    11.1.      Maintenance of Records

    • We will review the advanced information and documentation management policies, procedures and standards of ISO 9001, ISO 154489 and ISO 27001 and implement where necessary.
    • All records obtained through CDD measures, including account files, business correspondence and copies of all documents evidencing the identity of clients and beneficial owners, and records and the results of any analysis / assessment undertaken in accordance with the FIAMLA, all of which shall be maintained for a period of not less than 7 years.
    • Adequate records will be maintained by the Firm for all transactions it undertakes, including but not limited to the following summation:

     

    11.2.      Detail   Record keeping requirement

    • Client verification, due diligence, client agreements, complaints and any other client-related documentation. A minimum period of 7 years from the date on which the business relationship ended.
    • Financial statements and reports. Minimum period of 7 years from the date on which it was provided.
    • All records and documents not mentioned in the preceding table shall be maintained for a minimum period of 7 years.
    • Records on transactions, both domestic and international, that are sufficient to permit reconstruction of each individual transaction for both account holders and non-account holders, which shall be maintained for a period of 7 years after the completion of the transaction; and
    • Copies of all suspicious transaction reports or other reports made to the FIU in accordance with the FIAMLA, including any accompanying documentation, which shall be determined for a period of at least 7 years from the date the report was made.
    • All records shall be available for inspection by the FSC at all times during office hours.
    • The joint authorisation of the CO and one Director shall be required before destruction of any record.
    • The CO ensures that the compliance policies and procedures are observed properly and breaches if any are remedied immediately and disciplinary actions if required are taken against the personnel responsible for the breach.
    • The CO ensures that all regulators’ requests and instructions are complied with in a timely and accurate manner.
    • The CO will ensure that compliance monitoring and administration is carried out strictly according to the compliance program.

     

    The following information should be kept for every transaction carried out in the course of a business relationship or one-off transaction:

    • The name and address of the client;
    • If a monetary transaction, the kind of currency and the amount;
    • If the transaction involves a client’s account, the number, name or other identifier for the account;
    • The date of the transaction;
    • The details of the counterparty, including account details;
    • The nature of the transaction; and
    • The details of the transaction.

     

    PART II – RISKS

    1.    Risk

    Aron Brokers Ltd will ensure that the approved party / parties carrying out its controlled function:

    • Act with integrity.
    • Act with due skill, care and diligence;
    • Observe proper standards of market conduct.
    • Deal with the FSC and other regulators in an open and co-operative way; and
    • Disclose appropriately any information of which the FSC would reasonably expect notice;
    • Take reasonable steps to ensure that the regulated business of the company is organized so that it can be controlled effectively.
    • Is of financial soundness;
    • Reports to the Board;
    • Is aware of emerging regulatory issues.

     

    Compliance mode culture along with a values-led culture within the Company will together create a symbiotic relationship to a full Compliance Program. Implementation of appropriate Risk Controls will also be more effective built on Trust and not if the GRC Officer/Responsible is seen as an enforcer, opportunist or snitch. Personal Integrity forms part of the fundamental aspects of a good compliance model. The objective is the same – a successful company that observes the relevant codes of practice.

    Reports regarding the Risk Classification, Expired or Missing KYC, PEPs, etc., are generated on a regular basis, in order to keep timely and updated information, which can be provided to the relevant stakeholders, and authorities at short notice.

     

    2.    Risk Based Approach

    A risk-based approach requires us to assess the risks of how we might be involved in ML and TF, taking into account clients, countries or geographic areas, the products, services and transactions the clients offer or undertake, and the delivery channels by which those products, services and/or transactions are provided.

    The following are procedural steps to manage the ML and TF risks, according to the FSC AML CFT Handbook 2020, Updated on 21 September 2022

     

    2.1.  Identifying the Risk

    • Identifying the specific threats posed to the Company by ML and TF and those areas of the Company’s business with the greatest vulnerability;
    • A periodic review of clients’ existing activities should be conducted using the necessary and available means;
    • The Company and client’s risk is reviewed whilst taking into account that the problem may also be considered as an opportunity.

     

    Aron Brokers Ltd’ MLRO and CO may have the further following queries:

    • Are we tracking changes on beneficial owners over time?
    • Are we completing our periodic screening using the CDD tools?
    • Did we check the FSC recommended Sanctions and PEP lists and any other Public Records Data Sources?
    • Are the financial transactions in accordance with the business plan and the contracts in place?
    • Are transactions being thoroughly monitored?
    • Is the risk related to Market Abuse?
    • Is data destruction properly managed? Both physical and digital?
    • Is training in place for both initial and knowledge update, to all staff members, to ensure that policies and procedures regarding ML and TF are being strictly followed?
    • Are the policies read and understood by all staff members?
    • Are the authority limits clear?
    • Is the business plan verified against the business transactions / operations on a regular basis?
    • If the above conflicts with the actual operations, are the necessary procedures in place to ensure updating of the business plan with the relevant submission to the authorities?

     

    In the case of card-based products for Electronic Funds Transfer, the application of the ACI product –Proactive Risk Manager is in place.

     

     

    2.2.  Assessing the Risk

    • Assessing the likelihood of those threats occurring and the potential impact of them on the Company.
    • All changes to the activities from both the original activities and from the original business plan are to be reviewed and graded.
    • The assessment of risk should be completed independently from the Senior Management of the client companies.
    • The current legislation and the adherence to the same will form part of the compliance risk. Any mitigating factors will be considered when reviewing the risk profile.
    • The problem or opportunity may be able to generate alternative solutions – these should be considered when assessing the risk.
    • The client product needs to be reviewed for changes over a period of time and how this impact (if at all) the risk profile of the client.

     

    2.3.  Mitigating the Risk

    Mitigating the likelihood of occurrence of identified threats and the potential for damage to be caused, primarily through the application of appropriate and effective policies, procedures and controls.

     

    Examples of mitigating measures:

    • The application of additional elements of enhanced due diligence;
    • The introduction of enhanced relevant reporting mechanisms or systematic reporting of financial transactions;
    • The limitation of business relationships or transactions with natural persons or legal entities from the countries identified as high risk countries.

    2.4.  Managing the Risk

    Managing the residual risks arising from the threats, and vulnerabilities that the Company has been unable to mitigate. The risk assessment of Clients is conducted using the Compliance Due Diligence (CDD) Software, Cleversoft KYC. The Cleversoft KYC sums up all risk factors (each one has an assigned risk rate/score) in order to provide us with the final Client’s risk rate / score and classification. For further information on the CDD Software, Cleversoft KYC, and risk rating, please refer to the “Cleversoft KYC Manual / User Guide”.

     

    2.5.  Reviewing and Monitoring the Risk

    • Reviewing and monitoring those risks to identify whether there have been any changes in the threats posed to the Company which necessitate changes to its policies, procedures and controls.
    • Once the risk has been assessed, the inherent risks reviewed, the mitigating factors considered, the residual risk is then at hand. An action plan is put in place for execution under the supervision of compliance. The follow-up and review should be at regular intervals depending on the nature of the transactions or business under review. The monitoring reviews should be documented.
    • The client along with the business manager need to closely manage the associated risks and should be encouraged to work within the guidelines proposed.

     

    Aron Brokers Ltd Compliance and Risk Officer will ask the following questions:

    • Is pattern detection in place?
    • Are there periodic BRAs, clients risk assessments (CRAs), third-party reliance risk assessments, etc., reviews which may further implicate the risks of Aron Brokers Ltd? And If so, are those periodic reviews being completed and properly documented?

     

    2.6.  Advising on the Risk

    Evaluating alternatives and selecting a solution may be done by ensuring the staff members put forward the problems:

    • Persistently and in pursuit of common goals;
    • With rational persuasion, a consultative approach, a positive exchange and in collaboration with the departments concerned;
    • The staff members should be encouraged to refrain from legitimization, pressure, ingratiation and personal or emotional appeals.

     

    Market Efficiency need to be assessed against Social Justice

    • The DOCUMENTATION on the Risk advice needs to be comprehensive and more specifically documented WHY the risk profile has increased / decreased or requires reporting. Emails, operational and Board minutes as well as bank transfers and statements may all be used in the documentation trail. Formal Board minutes are not the only method of documentation.
    • A business Conduct Committee may be established depending on the volume of high risk clients identified and who should work within the Policy Documents provided.

     

    Aron Brokers Ltd’ Compliance Officer will ask the following questions:

    • Have the high-risk client reports been delivered to the Board?
    • Have appropriate steps been taken to minimize the risk for the client and for Aron Brokers Ltd?

     

    2.7.  Reporting the Risk

    • If the risk needs to be reported to the Board, has this been done properly and documented after following the above steps?
    • Have the appropriate corrective measures been taken to monitor and contain the risk?

     

    3.    Business Risk Assessment (BRA)

    • The Business Risk Assessment considers the extent of the Company’s exposure to risk.
    • Identifying areas where the Company’s services could be exposed to the risks of ML and TF, and taking appropriate steps to ensure that any identified risks are managed and mitigated, are crucial aspects of a risk-based approach.
    • Section 17(2) of the FIAMLA requires businesses to assess 6 key areas when undertaking the BRA, amongst other risk factors:
      • The nature, scale and complexity of the Company’s activities;
      • The products and services provided by the Company;
      • The persons to whom and the manner in which the products and services are provided;
      • The nature, scale, complexity and location of the client’s activities;
      • Reliance on third parties for elements of the customer due diligence process; and
      • Technological developments and reliance on the same.
    • The Company shall record and document its risk assessment in order to be able to demonstrate its basis. The assessment shall be regularly reviewed and amended to keep it up to date.
    • The BRA Policy and the BRA Report are set to be reviewed annually as part of the Company’s operations, or when changes within the Company, as well as changes in the respective Regulations and Acts take place. The same shall be included in the Board Report, so that evidence that an appropriate review has taken place.
    • The BRA Policy and the BRA Report shall address and cover the following not only the inherent risks of the Company, but the residual risks after applying mitigating controls of the latter.

     

    4.    Customer Risk Assessment (CRA)

    • The CRA must be conducted before establishing a business relationship or carrying out transactions with or for, the client. This will allow us to verify the risk of ML / TF regarding our clients, transactions, etc., beforehand.
    • This Assessment needs to be documented in order to be able to demonstrate its basis.

     

    This risk assessment will let us determine the following:

    • The extent of identification information to be sought;
    • Any additional information that needs to be requested;
    • How that information will be verified;
    • The extent to which the relationship will be monitored on an ongoing basis.

     

    It should be noted that the FSC has no objection to a financial institution having higher risk clients, provided that they have been adequately risk assessed and any mitigating factors documented. When the client is assessed as presenting a higher risk, Enhanced Due Diligence must be obtained.

     

    A basic Risk Assessment will consist of the following processes:

    • Collecting information;
    • Assessing and evaluating;
    • Determining initial risk rating;
    • Collecting additional information and documentation;
    • Assessing and evaluating additional information and documentation;
    • Confirming risk rating;
    • Conducting on-going due diligence.

     

    The Customer Risk Assessments (including Third-party Service Providers) frequency shall be as follows:

    • At least once, annually for higher risk customers / entities (or those that make part of a group structure where any entity is rated high risk);
    • At least every 2 years, for Medium risk customers / entities (or those that make part of a group structure where any entity is rated medium risk);
    • At least every 3 years, for Low risk customers / entities (or those that make part of a group structure where any entity is rated low risk);
    • At the point of a material change in customer’s profiles or circumstances, for example,
    • establishing connections with a higher risk jurisdiction or engaging in a higher risk business.

     

    Risk Assessment Factors Taken into Consideration:

    • The nature, scale, complexity and location of the client’s activity;
    • The services / products provided by the client, and to whom the same is provided to;
    • The involvement of third-parties in the client’s activity;
    • Location – Individuals, business entities or organizations that are located in any country or territory or doing business with a country or territory that is featured from time to time on any Sanctions Lists or the list of Business from Sensitive Sources will automatically be rated as high risk;
    • Political exposure of the Beneficial Owner or Beneficiary of the Corporate Client (Legal Arrangement / Legal Body / Entity);
    • Commercial rationale for the relationship;
    • The nature and value of assets concerned in the relationship;
    • The Client’s Source of Funds and where necessary the source of wealth;
    • Powers of Attorney;
    • Bearer Shares;
    • Status of Litigation – Although the Company anticipates that most client relationships will not be litigious, it recognises that where litigation is pending, threatened or current, additional management attention and focus is warranted. As such, higher risk scores are associated with these litigation categories;
    • Investments – Types and Asset Value.

     

    Risk Factors taken into consideration when identifying the level of TF risk associated with a country or territory included:

    • Is there information (for example, from law enforcement or credible and reliable open media sources) suggesting that a country or territory provides funding or support for terrorist activities or that groups committing terrorist offences are known to be operating in the country or territory?
    • Is the country or territory subject to financial sanctions, embargoes or measures that are related to terrorism, financing of terrorism or proliferation issued by, for example, the UN or the EU?
    • Risk factors that the Company can consider when identifying the risk associated with the level of predicate offences to ML in a country or territory include:
      • Is there information from credible and reliable public sources about the level of predicate offences to ML in the country or territory, for example, corruption, organized crime, tax crime and serious fraud? Examples include corruption perceptions indices; OECD country reports on the implementation of the OECD’s anti-bribery convention; and the UN Office on Drugs and Crime World Drug Report.
      • Is there information from more than one credible and reliable source about the capacity of the country’s or the territory’s investigative judicial system effectively to investigate and prosecute these offences?

     

    PART III – CUSTOMER DUE DILIGENCE (CDD)

    1.    Identification and Verification

    A key element of the prevention of money laundering and combating the financing of terrorism the capability of the Company to identify its customers, and their beneficial owners, and then verify their identities.

     

    Aron Brokers Ltd undertakes the following CDD measures:

    • Identifying and verifying the identity of each applicant for business;
    • Identifying and verifying the identity of individuals connected to the account or transaction, such
    • as the customer’s beneficial owner(s);
    • Identify all natural persons who ultimately have a controlling ownership interest in the customer.
    • Where there is doubt as to whether the person with the controlling ownership interest is the beneficial owner or where no natural person exerts control through ownership interests, the identity of the natural person exercising control of the legal person through other means as may be specified by relevant regulatory body or supervisory authority; and
    • Where no natural person is identified, the identity of the natural person who holds the position of senior managing official;
    • Obtaining information on the purpose and intended nature of the business relationship (the inability for employees to understand the commercial rationale for business relationship may result in the failure to identity non-commercial and therefore potential money laundering and
    • financing of terrorism activity);
    • Conducting ongoing due diligence on the business relationship and scrutiny of transactions throughout the course of that relationship, to ensure that the transactions in which the client is engaged are consistent with Aron Brokers Ltd’ knowledge of the customer and its business and risk profile (including the source of funds);
    • Achieving each of the above measures by using reliable, independently sourced documents, data or information (this is intended through the use of commercial databases and public information); and
    • Ensuring that all material collected under the CDD process is kept relevant and up to date (for example undertaking reactive reviews in response to trigger events, and by undertaking regular planned reviews of existing records at intervals determined by risk rating, with higher risk customers warranting more frequent reviews);
    • Determining whether the applicant for the business is acting on behalf of a third-party. If that’s
    • the case, the it must keep a record setting out the following:
      • The identity of the third-party (and any beneficial owners or associated persons as required);
      • The proofs of identity required under Regulation 3 of the FIAML Regulations 2018; and
      • The relationship between the third-party and the applicant for business.
    • Where Aron Brokers Ltd is unable to determine whether the applicant is acting for a third-party or not, make a Suspicious Transaction Report (STR), pursuant to Section 14 of the FIAMLA to the Financial Intelligence Unit (FIU).

     

    Any person, who knowingly provides any false or misleading information to a reporting person in connection with CDD requirements or any guidelines issued under the FIAMLA, shall commit an offence and shall, on conviction, be liable to a fine not exceeding 500,000 rupees and to imprisonment for a term not exceeding 5 years.

    In order to start a business relationship and conduct a thorough and successful due diligence check on clients, the appropriate KYC complete documentation needs to be filed and kept up to date.

     

    Necessary KYC documentation / data for Natural Persons

    • Data
      • Legal Name (the full legal and any other names, including, marital name, former legal name or alias);
      • Sex;
      • Date of birth;
      • Place of birth;
      • Nationality;
      • Current residential address (PO Box addresses are not acceptable);
      • Permanent residential address (if different than above);
      • Any public position held and, where appropriate, nature of employment and name of employer;
      • Government issued personal identification number or other government issued unique identifier;
      • Tax Identification Number (if applicable/available).
    • Documentation
      • Current valid Passport / National Identity Card (the document must incorporate photographic evidence of identity); or
      • Current valid Driving Licence (where the financial Institute is satisfied that the driving licensing authority carries out a check on the holder’s identity before issuing the licence – the document must incorporate photographic evidence of identity);
      • A recent (within the last 3 months) utility bill issued to the individual by name – as Proof of current or permanent residential address; or
      • A recent bank / credit card statement; or
      • A recent bank Reference.

     

    Necessary KYB documentation / data for Private companies, Partnerships, Sociétés, Foundations, Trusts and other legal persons

    • Data
      • Legal status of body;
      • Legal name of body;
      • Any trading names;
      • Nature of business;
      • Date and country of incorporation / registration;
      • Official identification number (e.g. company number);
      • Registered office address;
      • Mailing address (if different);
      • Principal place of business / operations (if different);
      • Ownership and control structure;
      • The identity of all the natural persons who ultimately have an ownership interest;
      • For trusts, the identity of the settlor, the trustee, the beneficiaries or class of beneficiaries, and where applicable, the protector or the enforcer, and any other natural person exercising ultimate effective control over the trust, including through a chain of control or ownership;
      • Bank Account details;
      • Tax Identification Number (if applicable/available).
    • Documentation
      • Certificate of Incorporation (or other appropriate certificate of registration or licensing);
      • Memorandum and Articles of Association (or equivalent);
      • UBO & Shareholder registry (or equivalent);
      • Director Registry (or equivalent);
      • Latest Audited Financial Statements (if available);
      • Annual report or equivalent (if available);
      • Partnership deed or equivalent;
      • Trust Deed or equivalent instrument;
      • Charter of Foundation;
      • Acte de Société.

    Provision for actions to be taken in the event of incomplete CDD:

    • After verifying the identity of the client and if there is no adverse information regarding the same, additional KYC is requested from the client so that the registering process may be finalised.
    • The Registering process may not be completed before the full KYC is provided.
    • In the event the client does not provide all the necessary KYC there will not be a business relationship with the client, or the client account shall be disabled (for old / existing accounts) until the complete KYC set has been provided.

     

    Provisions for actions to be taken in the event the Beneficial Owner (BO) cannot be identified, where the client is a Private company, Partnership, Société, Foundation, Trust and other legal persons

    • In case the client is a legal person, Aron Brokers Ltd shall identify and take reasonable measures to verify the identity of the BOs by obtaining information on the following:
    • The identity of all the natural persons who ultimately have a controlling ownership interest in the legal person;
    • Where there is doubt under the above paragraph (a), as to whether the person with the controlling ownership interest is a BO or where no natural person exerts control through ownership interests, the identity of the natural person exercising control of the legal person through other means as maybe specified by relevant regulatory body or supervisory authority; and
    • Where no natural person is identified under subparagraph (a) and (b), the identity of the natural person who holds the position of Senior Managing Official;
    • In case none of the above can be determined, the on-boarding process shall not take place.

     

    1.1.  Procedures for Certification KYC Documentation

    Where Aron Brokers Ltd relies upon verification of identity documentation that is not in an original form, the documentation must be appropriately certified as true copies of the original

     

    Documentation

    Where an employee of Aron Brokers Ltd meets an applicant for business or the principals thereof face-to-face and has access to original verification of identity documentation, he or she may take copies of the verification of identity documentation and certify them personally as true copies of the original documentation. In other cases, copies of the verification of identity documentation can be certified by a suitable person, such as an attorney, a lawyer, a notary, an actuary, an accountant or any other person holding a recognised professional qualification, director or secretary of a regulated financial institution in Mauritius or meets the FATF’s standards, a member of the judiciary or a senior civil servant.

    The certifier should sign the copy document and clearly indicate the date of certification, his or her name, address and position or capacity on it together with contact details to facilitate tracing of the certifier and, where available, any registration number with any professional body.

    The above list of suitable certifiers is not intended to be exhaustive and Aron Brokers Ltd should exercise due caution when considering certified copy documents, especially where such documents originate from a country perceived to represent a high risk or from unregulated entities in any jurisdiction.

    Where certified copy documents are accepted, it is Aron Brokers Ltd’ responsibility to ensure that the certifier is appropriate. In all cases, Aron Brokers Ltd should also ensure that the clients’ signature on the identification document matches the signature on the application form,

    mandate or another document.

     

    1.2.  Procedures for Electronic Identification and Verification Reliance

    Where Aron Brokers Ltd adopts a system providing for the electronic verification of natural person identity, Aron Brokers Ltd shall test the reliance and effectiveness of the results provided by the system in place and report its results to the Board as part of the Annual BRA Report. The system shall be tested periodically as per stated on Aron Brokers Ltd’ BRA Policy.

    Aron Brokers Ltd shall take into consideration any additional risks posed by placing reliance on an electronic method or system.

     

    1.3.  Procedures for the Acquisition of a Block of Clients or a Business

    In the event that Aron Brokers Ltd takes on a business which has established business relationships or a block of clients, Aron Brokers Ltd shall undertake sufficient enquiries to determine:

    • Whether the business’s CDD policies, procedures, controls and systems are in line with

    current AML / CFT legislative requirements; and

    • The level and the appropriateness (having regard to risk) of identification data held in relation to the clients and business relationships which are to be acquired.

     

    In deciding whether to acquire the business, Aron Brokers Ltd may rely on the identification data held where:

    • The business relationships were established in jurisdictions that have equivalent AML / CFT legislation or meets the FATF Standards;
    • The business’ CDD policies, procedures and controls are in line with the AML / CFT legislative framework; and
    • Aron Brokers Ltd has obtained identification data for each client acquired.

     

    2.    Simplified CDD

    2.1.  Situations on which Simplified CDD can be applied

    • Where the risk of Money Laundering (ML) or Financing of Terrorism (TF) is lower;
    • Where information on the identity of the applicant for the business is publicly available; or
    • Where adequate checks and controls exist elsewhere in the national systems;
    • Where there is a low level of risk, it shall be ensured that the low risk identified is consistent with the findings of the national risk assessment or any risk assessment carried out, whichever is most recently issued.

     

    2.2.  Situations on which Simplified CDD must not be applied

    • Where the Company knows, suspects or has reasonable grounds for knowing or suspecting that a customer or applicant for a business is engaged in ML/TF; or
    • Where Transactions being conducted by the customer or applicant for business is being carried out on behalf of another person engaged in Money Laundering; or
    • Where there are other indicators of ML/TF risk.

     

    2.3.  Important Aspects

    • The Company must document the decision of adopting the Simplified measures inrespect of a customer or applicant for a business. This must be done in a manner which explains
    • the factors which it took into account and its reasons for adopting the measures in question; and
    • Keep the relationship with the customer or applicant under review, and operate appropriate policies, procedures and controls for doing so;
    • The Company must keep the client risk assessment up to date and review the appropriateness of CDD obtained even if Simplified CDD measures are adopted.

     

    3.    Enhanced Due Diligence (EDD)

    3.1.  Where to perform EDD

    • A higher risk of ML/TF has been identified;
    • Where through supervisory guidance a high risk of ML/TF financing has been identified;
    • Where a client or an applicant is from a high-risk third country;
    • Where business relations, and transactions and persons established in jurisdictions that do not have adequate systems in place to combat ML/TF;
    • Where the client or the applicant is a PEP (Political Exposed Person);
    • Where the individual or entity is named on a Sanctions List;
    • Where it has been determined that the client has provided false or stolen identification documentation or information, and the reporting person proposes to continue to deal with that customer;
    • In the event of unusual or suspicious activity.

     

    Aron Brokers Ltd implemented EDD procedures with respect to high-risk persons, business relations and transactions and persons established in jurisdictions that do not have adequate systems in place to combat ML and TF.

     

    3.2.  EDD measures that may apply for higher risk business relationships

    • Requesting additional information on the client (e.g. occupation, volume of assets, information available through public databases, internet, etc.), and updating on a frequent basis the identification data of the customer and or the beneficial owner;
    • Obtaining additional information on the intended nature of the business relationship and the source of funds / wealth;
    • Obtaining information on the intended or performed transactions;
    • Obtaining the approval of senior management to commence or continue the business relationship where the client or applicant is classified as high risk;
    • Conducting enhanced monitoring of the business relationship, by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination;
    • Requiring the first payment to be carried out through an account in the client’s name with a bank subject to similar CDD standards;
    • Any other measures a financial institution may undertake with relation to a high risk relationship.

     

    Important Aspects

    • In case the reporting person is unable to perform EDD where required under Section 12 of the FIAML Regulations 2018, the business relationship shall be terminated andan STR shall be filed according to Section 14 of the FIAMLA;
    • The reporting person shall include the beneficiary of a life insurance policy as a relevant risk factor when determining whether EDD measures are required;
    • Where a reporting person determines that the beneficiary who is a legal person or a legal arrangement presents a higher risk, the reporting person shall take EDD measures which shall include reasonable measures to identify and verify the identity of the BO of the beneficiary at the time of payout;
    • Aron Brokers Ltd must keep and maintain customer relationship information with respect to all its clients as detailed in the CDD measures listed above. This includes scrutinizing the source of funds and the source of wealth, as described below:
      • Source of Funds (SOF)
        • The source of funds refers to the origin of the particular funds or assets, which are the subject of the business relationship between the Company and its client and the transactions the Company is required to undertake on the client’s behalf. The Source of funds requirement refers to where the funds are coming from in order to fund the relationship or transaction. This does not refer to every payment going through the account; however, the Company must ensure it complies with the ongoing monitoring provisions.
          • The Source of Funds shall be required as follows:
            • When a Client (Natural Person) reaches / exceeds the total Transaction Amount of USD 10,000.00.
            • When a Client (Corporate / Entity / Trust / Legal Body) exceeds the total Transaction Amount of USD 25,000.00.
          • Source of Wealth
            • The source of wealth on the other hand, describes the origins of a customer’s financial standing or total net worth, i.e. activities which have generated a customer’s funds and property. A financial institution is required to hold sufficient information to establish the source of wealth and this information must be obtained for all higher risk customers (including higher risk domestic PEPs) and all foreign PEPs and all other relationships where the type of product or service being offered makes it appropriate to do so because of its risk profile.
              • The Source of Wealth shall be required as follows:
                • When a Client (Natural Person) reaches / exceeds the total Transaction Amount of USD 15,000.00;
                • When a Client (Corporate / Entity / Trust / Legal Body) exceeds the total Transaction Amount of USD 25,000.00.

     

    4.    Politically Exposed Persons (PEPs)

    PEPs are individuals who are or who have been entrusted with prominent public functions (e.g. Heads of State or of Government, Senior Politicians, Senior Government, Judicial or Military Officials, Senior Executive of State-owned Corporations and important Political Party Officials) in foreign, domestic and international organisation PEP, as well as family members and close associates of such person.

    Business relationships with PEPs pose a greater than normal money laundering risk to financial institutions, by virtue of the possibility for them to have benefitted from proceeds of corruption, as well as the potential for PEPs (due to their offices and connections) to conceal the proceeds of corruption or other crimes.

     

    4.1.  Procedures Applicable to Foreign PEPs 27

    • Put in place and maintain appropriate risk management systems to determine whether the client or beneficial owner is a PEP;
    • Obtain Senior Management / Board of Directors approval before establishing or continuing, for existing clients, such business relationships;
    • In the event of existing clients, Board of Directors / Senior Management shall decide whether the existing business relationship has to be terminated or not, according to the risk classification and all different aspects surrounding the risk classification of the PEP Client;
    • Obtain similar approval from senior management in cases of family members or close associates of PEPs;
    • Take reasonable measures to establish the source of wealth and the source of funds of clients and beneficial owners identified as PEPs; and Conduct enhanced ongoing monitoring on that relationship.

     

    4.2.  Procedures Applicable to Domestic PEPs or an International Organisation PEP

    • Take reasonable measures to determine whether a client or the beneficial owner is such a person; and
    • In cases when there is higher risk business relationship with a domestic PEP, adopt the measures in paragraphs on Point “4.1.”.

     

    Important Aspects

    • A reporting person shall apply the relevant requirements of paragraphs “4.1 and 4.2” to family members or close associates of all types of PEP, as may be specified by a supervisory authority or regulatory body after consultation with the National Committee.
    • A reporting Person shall, in relation to life insurance policies, at any time but before the time of payout, take reasonable measures to determine whether the beneficiaries or the beneficial owner of the beneficiary, are PEPs, provided that where higher risks are identified, the reporting person shall:
      • Inform senior management before the payout processed;
      • Conduct enhanced scrutiny on the whole business relationship with the policyholder; and
      • Consider making a suspicious transaction report.

     

    4.3.  Defining “Family Members”

    • It means an individual who is related to a PEP either directly through consanguinity, or through marriage or similar civil forms of partnership; and
    • It includes any other person as may be specified by a supervisory authority or regulatory body after consultation with the National Committee.

     

    4.4.  Defining “Close Associates”

    • It means an individual who is closely connected to a PEP, either socially or professionally; and
    • It includes any other person as may be specified by a supervisory authority or regulatory body after consultation with the National Committee.

     

    5.    Third-Party Reliance

    5.1.  Risk Assessment on third-parties

    • When reliance is placed on a third party to introduce business or to perform CDD measures, the following may be considered:
      • Consider how reliance on third parties is prompted and agreed on;
      • Consider who these third parties are, including any reputational issues, the quality ofrelationships with such third parties and previous experiences;
      • Consider the extent and type of any reliance placed or to be placed on third parties;
      • Consider the extent of the information being provided by the third party and who hasactually met the same face-to-face (chains of information);
      • Consider any jurisdictional issues in connection with reliance placed on third parties;
      • Consider the results of any testing undertaken on the third party’s procedures and theresponses to any previous requests for documentation;
      • Consider the extent of any outsourcing undertaken;
      • Consider the quality of the provider for any outsourced functions including any reputational issues, previous experiences with the provider, the results of any audits, assessments or inspections where the material generated as a result of outsourcing has been reviewed.

     

    5.2.  Procedures to be satisfied regarding reliance on third-parties

    • There must have a signed agreement between the fund or its administrator and the relevant third party, in which the third party consents to being relied upon for these purposes and undertakes;
    • Where reliance is placed on a third party for elements of CDD, the Company must ensure that the identification information sought from the third party is adequate andaccurate;
    • The CDD information has to be submitted immediately upon onboarding, although the

     

    documents can be provided upon request at a later date;

    • The third party will provide, immediately upon request, relevant copies of identification data in accordance with Regulation 21(2)(b) of the FIAML Regulations 2018; and
    • The quality of the third party’s CDD measures is such that it can be relied upon;
    • Where such reliance is permitted, the ultimate responsibility for CDD measures will remain with the financial institutions relying on the third party;
    • Reliance may only be placed on third parties to carry out CDD measures in relation to the identification and verification of a client’s identity and the establishment of the purpose and intended nature of the business relationship;
    • Reliance may be placed on a third party that is part of the same financial group, where:
      • The group applies CDD and record keeping requirements and programs against ML/TF;
      • The implementation of those CDD and record-keeping requirements and program against money laundering and terrorism financing is supervised at a group level by a competent authority; and
      • Any higher country risk is adequately mitigated by the group’s policies to combat money laundering and terrorism financing.
    • Third parties may not be relied upon to carry out the ongoing monitoring of dealings with a client, including identifying the source of wealth or source of funds;
    • A financial institution may not rely on a third party based in a high risk country.

     

    The FSC recommends that regular assurance testing is carried out in respect of the third party arrangements, to ensure that the CDD documents can be retrieved without undue delay and

    that the documentation received is sufficient pursuant to section 17(2)(v) of the FIAMLA.

     

    5.3.  Third-Party Introducers

    • Financial institution should subject third-party introducers to the full identification and verification CDD measures for identification and verification as provided under the FIAML Regulations 2018.
    • In line with the third-party reliance obligations, when individual applicants, or applicants which are body corporate, are introduced to a financial institution by an introducer, the Company should:
      • Obtain and maintain documentary evidence that the introducer is regulated for the purposes of preventing money laundering and terrorist financing; and
      • Be satisfied that the procedures laid down by the introducer meet the requirements specified in the FIAMLA and FIAML Regulations 2018.

     

    The Company’s Board of Directors or equivalent Senior Management will ensure that periodic testing of the above arrangements is conducted, in order to ensure compliance with the current legislative framework with respect to the above provision.

    6.    Targeted Financial Sanctions (TFS)

    6.1.  Screening

    • Clients and transactions are screened against the required sanctions lists in 2 different ways:
      • Using an automated screening tool;
      • Manually – this is done by accessing the publicly available lists, which can be downloaded from the UN, FIU or the NSSEC websites.
    • Documentation to evidence that clients and transactions have been screened has to be kept;
    • The focus should not only be on the names of persons and entities listed on UN sanctions lists, but also identify the persons and entities linked to them;
    • Each incoming and outgoing transaction should similarly be screened for a potential match with sanctions lists. Screening should be focused at a point in the transaction where detection of sanctions risk is actionable – where a transaction can be stopped and funds frozen if required – and before a potential violation occurs.

     

    6.2.  Matches and Escalation

    • An alert that is generated by a potential match might not, on its own, be an indication of sanctions risk. It should act as a trigger which can be confirmed or discounted with additional information gained through further investigation. Adequate records of these investigations have to be maintained.
    • Senior management should be alerted before action taken when identifying a true match and or freezing assets, where it is appropriate.
    • In the event that a true match is identified, the match and any associated asset freezing should be reported immediately to the NSSEC and the FSC. (The reporting template on Positive Match needs to be filed as an Appendix)
    • An STR should be also filed to the FIU.

     

    6.3.  Freezing and Prohibition on dealing with funds and Assets

    • It is required to immediately and without delay freeze the assets of designated persons. In other words, this means ceasing any dealings and securing the funds and other assets, including financial assets and economic resources, that are owned or controlled, directly or indirectly, by the persons or entities designated by the UNSC or the NSSEC. This also encompasses the freezing of funds, other financial assets and economic resources of persons or entities acting on behalf of, or at the direction of, those designated by the UNSC or NSSEC.
    • New freezes are required to be implemented immediately, and without prior notice to the person.
    • The account of any designated person identified as an existing client must not be closed, as this could result in funds or economic resources being made available to the designated person.
    • The obligation to report and freeze extends to attempted as well as future transactions. Where a transaction is attempted and monies or other assets have been passed to a Licensee with a view to completing the transaction, these monies or assets must not be handed back to the entity if the transaction is aborted following a match; and
    • The obligation to freeze covers funds and other assets e.g. non-cash assets such as wills, real estate deeds, boats, jewellery, corporate licenses etc. However, where assets are frozen, there is a requirement to maintain the value of such an asset.

     

    6.4.  Unfreezing

    Aron Brokers Ltd will be informed of a designation removal or unfreezing order in the same manner that they are informed of a new designation.

     

    Important Aspects

    • Financial sanctions apply to all clients and all transactions; there is no minimum financial limit.
    • Politically Exposed Persons (PEPs) can be, but are not necessarily designated persons under targeted financial sanction regimes. The requirement to identify clients that are PEPs and the requirement to identify clients that are designated persons for targeted financial sanctions are separate obligations.
    • The targeted financial sanctions regime is not the same as the FSC’s enforcement regime, which sanctions Licensee’s for non-compliance with their AML/CFT and targeted financial sanctions obligations.
    • Freezing and unfreezing assets of designated persons shall take place within 24 Hours of identifying and verifying the related Sanctions, in line with Section 3 & 4 of the United Nations (Financial Prohibition, Arms Embargo and Travel Ban).

     

    7.    Ongoing Monitoring

    An existing business relationship is required to be monitored so that money laundering or terrorist financing may be identified and prevented, and to ensure that it is consistent with the nature of business stated at the establishment of the relationship.

     

    There are two types of ongoing monitoring:

    • The first relates to the transactions and activity which occur on a day-to-day basis within business relationship and which need to be monitored to ensure they remain consistent with the Company’s understanding of the client and the product or service it is providing to the client.
      • Scrutiny of transactions undertaken throughout the course of the relationship, including, where necessary, the source of funds, to ensure that the transactions are consistent with his knowledge of the client, and the business and risk profile of the client.
    • The second relates to the clients themselves and the requirement for the Company to ensure that it continues to have a good understanding of its clients and their beneficial owners. This is achieved through maintaining relevant and appropriate CDD and applying appropriate ongoing screening.
      • Ensuring that documents data or information collected under the Customer Due Diligence (CDD) process are kept up to date and relevant by undertaking reviews of existing records, in particular for higher risk categories of clients.

     

    Examples of the additional monitoring arrangements for high-risk relationships could include:

    • Undertaking more frequent reviews of high risk relationships and updating CDD;
    • Information on a more regular basis;
    • Undertaking more regular reviews of transactions and activity against the profile and expected activity of the business relationship;
    • Applying lower monetary thresholds for the monitoring of transactions and activity;
    • Reviews being conducted by persons not directly involved in managing the relationship, for example, the CO;
    • Ensuring that the Company has adequate MI systems to provide the board and CO with the timely information needed to identify, analyze and effectively monitor high-risk relationships and accounts;
    • Appropriate approval procedures for high value transactions in respect of high risk relationships; and/or a greater understanding of the personal circumstances of high risk relationships, including an awareness of sources of third party information.

     

    8.    Transactions

    Transactions include opening of an account, issuing an account number, renting safe deposit boxes or entering into a fiduciary relationship electronically or otherwise and it also includes a Proposed Transaction.

     

    8.1.  Transaction Verification

    In order to verify a Transaction, the following data is required:

    • Name of the Client / Entity;
    • Address of Client / Entity;
    • Name of Invoicing party;
    • Company / Entity registration number;
    • Bank Name;
    • Bank Address;
    • Bank account details.

     

    The Principals of the Contracting parties

    • Online searches using AML Manual specified websites, Consolidated United Nations Security Council Sanctions List (UN), European Union Consolidated List(EU), Higher Risk countries identified by FATF; Internet Explorer and Google website search.

     

    8.2.  Suspicious Transactions

    • A suspicious transaction is a transaction where the laundering of money or the proceeds of any crime or funds linked to or related to or being used for terrorism or acts of terrorism by prescribed organizations, whether or not the funds represent the proceeds of a crime itself; and or
    • The transaction is made in circumstances which are unusual or unjustifiably complex; have no economic justification or lawful objective; and or
    • The Transactions are made by or on behalf of a person whose identify cannot be established to the satisfaction of the parties carrying out the instruction; and or gives rise to suspicion for any reason.

     

    8.3.  Suspicion

    The transacting party may believe that a transaction is suspicious if the transaction involves:

    • Laundering of money or proceeds of any crime; funds linked or related to terrorism or terrorist activities; unjustifiable complexity; unjustifiable economic or lawful objective; identity cannot be established or any other valid and justifiable reason;
    • The Guidance Note 4 on Suspicious Transaction Report on 21 January 2014 (updated November 2020) to be read in conjunction with this document for relevance of specific examples of indicators of Suspicious Transactions;

     

    Examples of Red Flag indicators of a Suspicious Transaction:

    • Same day abnormal amount of deposits and withdrawals;
    • Transaction does not match usual activity patterns or lacks economic substance;
    • The Client is secretive or evasive about who they are, the reason for the Transaction or the source of funds.

     

    9.    Suspicious Transactions Report (STR)

    • All staff members are required to submit an STR to the MLRO, when coming across a transaction, client or activity that they consider suspicious and after further examination of the same;
    • The STR shall be passed from the CO to the MLRO, or from the staff member directly to the MLRO;
    • The MLRO shall assess the information contained within the report to determine whether there are reasonable grounds for knowing or suspecting that the activity is related to ML/TF or Proliferation Financing;
    • The MLRO shall forthwith make a report to the FIU where there is reason to believe that an internal disclosure may be suspicious;
    • An internal registry should be kept for STRs that have not been submitted to the FIU; and
    • The internal registry should be updated in a monthly basis, regardless of any suspicious transactions, clients or activities have been flagged or a STR being submitted;
    • An external registry should be kept for STRs that have been submitted to the FIU;
    • A maximum delay of 5 working days is required for the reporting of the STR to the FIU, after the MLRO becomes aware of a suspicious transaction or activity;
    • Where the reporting person becomes aware of a suspicious transaction, or ought reasonably to have become aware of a suspicious transaction, and he/she fails to make a report to FIU of such transaction not later than 5 working days after the suspicion arose he shall commit an offence and shall, on conviction, be liable to fine not exceeding one million rupees and to imprisonment for a term not exceeding 5 years;
    • A STR can be submitted to the FIU electronically only from Banks as they are registered with the FIU. MC’s are required to submit STR’s manually;
    • The STR Form is found under the Manual’s Annexures. It needs to be completed manually and submitted by hand delivery at the reception of the FIU building at 7th Floor, Ebène Heights, 34, Ebène Cybercity, Ebène, Republic of Mauritius, or by facsimile at fax number +230 466 2431;
    • The form proposed by the FIU is very complete and reporting parties are therefore required to complete the form as prescribed, both completely and with sufficient information so that the necessary follow-up and action can take place. The information should include WHO, WHAT, WHEN, WHERE, WHY. (Details thereto are found on the Guidance Notes from the FIU.) Late filings or incomplete filings negate the effectiveness of the law enforcement ability to determine what has transpired and what action is to be taken. To note the Entity Reference Number is key and will be referred to on all investigation and documentation relating to said STR. This ERN will be allocated by the FIU upon receipt and acceptance of the filed STR. The Indicator prompting the filing of the STR; the Description of the STR and the Material impact are all part of this form which needs to be filled out prior to filing the STR. Transaction details for advice/guidance, please refer to the FIU Guidance Note 4.

     

    9.1.  Action to be taken

    • Inform a law enforcement agency, or your supervisory body/ regulatory authority;
    • Discontinue the business relationship with the client e.g. closed his/her account;
    • Continue to monitor the clients account;
    • Commence an internal investigation on the client’s accounts/business;
    • Any other steps taken in addition to reporting the suspicion to the FIU.

     

    9.2.  Further action to be taken or information to be supplied

    • The Director of the FIU may ask for additional information and to note that no action can be taken against the party making the report. However, non-reporting incurs fines and criminal charges;
    • The FIU operates in compliance with the Data Protection Act of 2004 but this Act has been superseded by the DPA of 2018. The Guidance notes should be updated shortly by the FIU and as such the STR procedures will be updated.

     

    10. Tipping Off

    Section 16(1) of the FIAMLA states that no person directly or indirectly involved in the reporting of a suspicious transaction shall inform any person involved in the transaction or an unauthorized third party that the transaction has been reported or that information has been supplied to the FIU pursuant to a request made under section 13(2) or (3) of the FIAMLA.

    The MLRO should acknowledge receipt of the internal disclosure and at the same time, provide a reminder of the obligation to do nothing that might prejudice enquiries, such as tipping off the customer or any other third party. The MLRO should provide guidance on how to avoid tipping off the customer if any disclosure is made. If the Company reasonably believes that performing the CDD process will tip off the customer or potential customer, it should stop the CDD process and will need to file a STR with the FIU in such circumstances.

     

    In the event that the Company (Board of Directors/Senior Management) determine and decide that the Business Relationship with a Client whose STR has been filed should be terminated, the Company shall take into consideration the following points when interacting with the same client:

    • It will become apparent to criminals that elements of their criminal activity is known to the Company, if it begins to ask probing questions regarding certain activities or if it seeks to terminate the relationship or decline entering into a business relationship without a meaningful pretext. The Company is therefore encouraged to carefully consider the wording of any statements made to customers explaining their decision; and
    • The more information is included in the STR, the more valuable it will be to the FIU.

     

    11. Loss of Contact with Client (PEP) or otherwise

    There could be a situation when there are assets on a client’s account but the contact with such client has been lost. The loss of contact with the client may occur when the client has either deceased and not left any alternate contacts; has moved physical address for personal or business reasons and purposely does leave either forwarding contact details or any means of further contact or simply has been negligent in keeping up to date on his affairs. The Client should have already been classified one of low, medium or high risk.

    In the event the Client is of low or medium risk it is possible that there is no contact with the client within an 11-month period.

     

    In the event the Client is of High risk or a Politically Exposed Person, there should be regular contact throughout the year and review of the file because of the nature of the client. If the Client is not responding to regular contact methods, the following steps should be taken by the Compliance Officer.

    • The client shall be contacted via telephone and email. The documentation advising the client of the proceedings of the Company, including fees and other responsibilities may be delivered by the local office to the physical address of the client if known;
    • Although the client may persist in not responding to any of the contact made, a continued annual contact is to be made until such stage as the Company itself is wound up or the Board takes alternative action;
    • Should the client be unreachable within a period of one year, the FSC will be informed accordingly;

     

    The Board is to review on an annual basis all Client files where the client is no longer responding to any contact and may take further action on the Client as is deemed appropriate taking into account the Business Risk to the Company.

     

    12. Examples of Documentary Evidence to be collected to evidence Source of Wealth

    12.1.      Sales of Securities or other Investment

    • Investment/savings certificates, contract notes or statements;
    • Written confirmation from the relevant investment company on letter headed paper
    • Bank statement showing receipt of funds from investment company name; or 35
    • Signed letter detailing funds from a warranted accountant on letter headed paper.

     

    12.2.      Sale of Property

    • Signed letter from a lawyer or a notary on a letter headed paper; or
    • Contract of Sale.

     

    12.3.      Maturing Investment or Policy Claim

    • Letter from previous investment company on letter headed paper notifying proceeds of claim;
    • Chargeable Event Certificate; or
    • Closing statement.

     

    12.4.      Individual owns policy/company pays premium

    • A copy of trading details or an annual report from the company’s website (if applicable)
    • Hard copy of the latest annual report; or
    • Copy of the company’s certificate of incorporation (or equivalent); and
    • Policy statement; or
    • Bank statement showing credit.

     

    12.5.      Dividends or profits from private company

    • Dividend contract note;
    • Letter showing dividend details signed by a warranted accountant on letter headed paper
    • Set of company accounts showing the dividends details; or
    • Bank statement clearly showing receipt of funds and the name of the company paying dividend; and
    • A document providing proof of shareholding such as a copy of the Memo & Arts, Certificate of Incumbency or a dated print-out of a company registry search.

     

    12.6.      Company Sale

    • Signed letter from a lawyer on a letter headed paper;
    • Signed letter from a warranted accountant on a letter headed paper;
    • Copy of contract of sale and bank statement showing credit to account consequent to the sale; or
    • Copies of media coverage (where applicable) as supporting evidence.

     

    12.7.      Inheritance

    • A copy of the will that must include the value of the estate; or
    • A lawyer or notary’s letter on letter headed paper or a letter from the trustees of an estate that includes the type of asset and respective value.

     

    12.8.      Maturity or redemption or a shareholder’s loan

    • Loan agreement;
    • Recent loan statements.

     

    12.9.      Gift

    Document (e.g. letter from the donor) showing who gave the gift, when, the relationship

    between the donor and done and (if possible and applicable) why the donation was made, together with the verification of identity of the donor, and information about the source

    of the donor’s wealth.

     

    12.10.   Lottery/betting/casino win

    • Letter from relevant organization (lottery, headquarters/betting shop/casino);
    • A certificate of winnings issued by the relevant company or casino;
    • In the case of lottery winnings, a bank statement showing funds deposited by company name; or
    • Copies of media coverage (if applicable) as supporting evidence.

     

    12.11.   Compensation payment (this could be a decision or award by a court, Tribunal or arbiter or else and out-of-court settlement)

    • A letter/court order from a compensating body clearly showing the amount of compensation; or
    • Lawyer’s letter on letter headed paper clearly establishing the amount.

     

    12.12.   Savings and investment

    • Bank Statement/s demonstrating deposit/gifted monies; or
    • Documentation evidencing an inward transfer from portfolio.

     

    12.13.   Insurance claims

    • A letter from the insurance provider on a letter headed paper.

     

    12.14.   Divorce or separation settlement

    • A copy of the court order or judicial separation agreement and verification that funds have originated from the account of the former spouse.

     

    12.15.   Income from employment (including bonus)

    • An original or certified copy of a recent pay slip;
    • Written confirmation of annual salary/bonus amounts signed by employer; or
    • Bank statement clearly showing receipt for most recent regular salary payment from named employer.

     

    12.16.   Retirement Income

    • Pension Statement;
    • Letter from a warranted accountant on letter headed paper;
    • Letter from annuity provider; or
    • Bank statement showing receipt of latest pension income and name of provider.

     

    12.17.   Other Monies:

    • Appropriate supporting documentation; or
    • Signed letter detailing funds from warranted accountant/lawyer/entity licensed to provide investment services on letter headed paper.

     

     

    ADDITIONAL MANUALS THAT FORM PART OF THE COMPANY’S POLICY DOCUMENTS

    The following manuals, Policies and appendices should be read in conjunction with this AML / CFT / GRC Operations Manual:

    • Business Risk Assessment Policy;
    • Cleversoft KYC User Guide;
    • Internal Policy;
    • Disaster Recovery Plan Policy and Procedure;
    • Human Resources Manual;
    • Privacy Policy;
    • Compliant Handling Policy & Processing;
    • PEP Register.

     

• • Download

    Client Agreement-Aron Brokers Ltd (Mauritius)-Effective Date: July 2024

    

  •  

    1.    Agreement

    This agreement is concluded with all the terms and conditions between the client and Aron Brokers Ltd. and includes all the trades that the client does through the trading platform server of Aron Brokers Ltd or any downloadable trading software.

     

    Aron Broker cooperation with the client is based on the following terms:

    • Mentioned terms and conditions
    • Risk declaration
    • Registration request form completed by the customer
    • Trading rules of Aron Broker
    • Any relevant software licenses
    • All the additional terms and conditions set by Aron Brokers Ltd, including the rules related to trading accounts or other ones and conditions that will be set in relation to trades and about these terms and conditions, here and after all, are called “Agreement.”

     

    Clients should be aware that the trading account and symbols details contain essential information regarding the trading assets, and more information is included in Clause 9.

     

    By agreeing to this agreement, the client allows Aron Broker to communicate with him at any time through email or any other means and discuss any aspect of the customer’s trading account of Aron Broker or any related part of the company’s activities.

     

    Based on this agreement, the client accepts all the offered prices by the Aron Broker are acceptable to him in all markets, symbols, and charts.

     

    The client’s orders are sent to the Liquidity provider (LP); Therefore, the execution price of traders’ orders is determined by the broker’s LPs. Liquidity in all Aron Broker trading symbols is created by LP, which all of them are contracting parties of the broker; Therefore, it is not a criterion to compare prices in other financial companies with different liquidity providers than Aron Group’s broker.

     

    The client acknowledges and agrees every time that makes a trade that all declarations related to personal guarantees are repeated as follows:

    • All the information that the client provides us via the registration request form is accurate and can be verified.
    • The client agrees to follow this agreement in all respects.
    • The client has carefully read and fully understood this agreement and the account specifications, trading symbols, and risk declaration. The subject of this agreement is obvious to them.
    • If you are a natural person, your age must be over 18.
    • The client manages all the trades on his behalf and not as a third-party representative.

     

    If Aron Broker suffers from the obligations contained in this agreement due to mistakes and errors or any justified objections of the client, the customer is personally responsible for the total amount of the loss and must take action to compensate for the loss.

     

    Authentication with third-party documents is considered a violation. If it is determined that the user has received services from Aron Broker by using multiple trading accounts, the company has the right to exempt them from continuing to cooperate and receive services based on the policies.

     

    If a third party manages the customer’s account, the company has the right to refuse to provide any service to the client.

     

    If the company notices any fraudulent activity and suffers losses, in that case, Aron Broker has the right to block all client’s trading accounts without any warning or explanation and refuse to provide services to them.

     

    If the user is informed about a bug in prices, the service performance of the broker (transactions, exchange, etc.), or the implementation of trades and incentive schemes must immediately raise these issues with the broker’s support department. Using the mentioned issues is against the law, and the user will be condemned for abuse. All the trades and activities done using the bug will be canceled, and the broker has the right to deal with the user.

     

    All the activities using the bug have been declared invalid, and the broker reserved the right to deal with it. The broker will be obliged to fix the bugs as soon as possible. All the activities done during the bug’s occurrence must be removed, which will also be the broker’s responsibility. Delays, price differences of trading symbols, software problems, etc., are some of the bugs that are expected to occur; the broker service functions are not an exception. Broker’s service function includes exchange, incentive schemes, trade, etc.

     

    The client agrees to have the specified minimum deposit amount in his trading account to open the trading account. If the balance is less than this amount, the trades will be in Close Only mode, in which case the trader will only be able to close “open trades” if the trader can reach the set amount balance by transferring money or managing “open trades”, the trading account will be taken out of Close Only mode.

     

    2.    General terms and conditions

    • All actions taken by Aron Broker in good faith are binding on the client, and these actions do not put any liability on Aron Broker shoulder.

     

    • The customer agrees to protect Aron Broker Company against all liabilities, obligations, damages, actions, judgments, legal or criminal claims, and costs of any kind that Aron Broker may incur as a result of actions taken on the client’s advice and keep the company safe from harm by paying fine.

     

     

    3.    Trading account

    Before making any trades, the customer must first open an account with the broker; Therefore, he must send the form related to the registration request and authentication procedures to the broker on Aron Broker Ltd’ website. All the required fields in the registration form must be completed, and all the information provided must be as accurate and correct as possible. Any incorrect or unclear information will either lead to the immediate rejection of the customer’s request or at least cause a delay in opening an account.

     

    Aron Broker may periodically check the client’s information to verify that the provided information has stayed the same. However, if there is any significant change in the customer’s financial conditions or the information provided in the application form, including the address, contact information, and email, the customer will be required to inform Aron Broker in writing.

    Aron Broker is not required to create an account for any client and may reject any request without being required to explain the reason to the client for such a decision.

     

    Aron Broker has the right to block or suspend the client’s account at any time. In this case, all the trading positions will be closed immediately at the current quotation price of the broker and no new trades will be accepted. Any unquoted opened trading positions that client has in the market will be closed on the next business day at the first acceptable existing price for the broker, or these positions will be closed in case of market suspension for any reason based on the terms and conditions contained in this agreement.

     

    Aron Broker has the right to provide information related to the clients or the trading accounts to all the authorities responsible for supervising the business activities of Aron Broker without any reference and prior notice of the customer.

     

    Every client is obliged to read all the rules and follows them. In case of any rule violation, the broker has no responsibility to support the client. These rules include the top opened trading position, the maximum trades value, etc., and any consequences arising from non-compliance with the rules will be the client’s responsibility.

     

     

    4.    Services

    Aron Broker cooperation with clients is limited to trading and related business fields. Aron Broker does not provide any consultation regarding benefits, conducting this agreement, any trading based on this agreement, and investment to the clients. When the client wants to decide on any trade based on this agreement, he should only rely on the information and proper understanding of the market.

     

    Aron Broker provides all the details about trading symbols, trading accounts, all the offered services, and descriptions of various matters related to this agreement online through the website. Before taking action, clients must read the terms carefully and thoroughly. If there is anything vague regarding the details, the clients should contact the support.

     

    Every trade via the Aron Broker platform must be made according to the allowed volume, and trades can be handled during the time of the price announcement of the broker for the related market. The details related to this section are described in full in the trading symbols specification section. The minimum and maximum limits are determined by the Aron Broker and, according to the market size and which all the trading prices are available and provided price information. Aron Broker offers the minimum and maximum limits according to the client’s request, and these limits are described in full in the trading symbols specification section. Aron Broker has the right to change the minimum and maximum limits, and awareness of these limits before making any trade is the client’s responsibility. Also, the broker has the right to waive the limits of the trades without informing the client.

     

    Aron Broker Ltd cooperation based on this agreement with the client includes margin trading. Margin trading is described in full in clause 7.

     

    Despite the other provisions of this agreement regarding the providing services, the Aron Broker has the right to take any action necessary to ensure the customers’ compliance with the relevant laws. The client agrees to follow all the rules and if the broker concludes that the client has not followed the rules, the broker has the right to terminate the agreement.

     

    Aron Broker has no responsibility regarding any losses caused by power outages or any related issue that prevents pricing provision in one or more specific markets.

     

     

    5.    Trading

    Trading in the Aron Broker Ltd platform is only available via MetaTrader5, which the broker provides. This software is updated regularly, and we strongly suggest downloading the updated version to use the software effectively.

    Trades can be made in two ways, and the trader can choose one according to his needs:

     

    5.1.  Netting

    The trader will have an «open trade» on one trading symbol, and averaging will be done if trading volume increases. If the trader takes a trading position against the trend of trades, the client’s volume of «open trade» will be reduced.

     

    5.2.  Hedge

    A new invoice is created for each buy and sell, and the trader can have multi buy and sell «open trade» on one trading symbol.

    • Aron Broker, according to supply and demand quotes a two-way quote in acceptable volumes, which includes the spread between buy and sale price. The client can buy the asset at a higher price or sell it at a lower price.
    • The username and password of the client are extremely sensitive information. Making every trade via the client’s trading account and his details will be considered valid. The client must not provide his username or password to anyone, and all responsibilities arising from disclosing this information are the customer’s responsibility. If someone else has access to the client’s trading account or someone other than the owner makes trades by using their trading account, they should immediately inform the support department of Aron Broker; all the responsibility resulting from that is the client’s responsibility.
    • Aron Broker will only accept traders such as opening and closing trading positions via Metatrader 5. Aron Broker is under no circumstances obliged to accept trading requests or exchanges via email or instructions given during a personal conversation.
    • A trade request can only be about a valid, current quote. A price may change at any time after the order is submitted till it is executed.
    • In case of submitting a request for trade via the trading platform server, you can only request exchanges with prices that are announced at the moment of the trading on the platform server. Due to the nature of Internet trading systems and the potential unreliability of market price news, Aron Broker, at its sole discretion, can eliminate every related trade that is made through the trading platform’s server and does not reflect the actual market prices at the time. Aron Broker will not bear any responsibility for such losses.

     

    5.3.  Orders

    Generally, there are two types of order:

    • Pending order
    • Stop loss and take profit.

     

    Pending orders are orders that are not related to the current open position. All the orders that the Aron Broker accepts will be considered “Good-Til-Cancelled.”

     

    The term “Good-Til-Cancelled” means that the order will remain valid until canceled by the client.

     

    Any trading orders executed for an opened trading position by a client to stop loss and take profit or until the position is closed are considered “Good-Til-Cancelled.”

     

    It is the client’s responsibility to cancel any trading order that is no longer necessary.

     

    An order will be executed when the quote reaches the specified price in the client’s order or the trades made through the set price.

     

    There is no obligation for the Aron Broker to inform the client of the execution or non-execution of an order. The client’s responsibility is to know all timeframes related to whether an order has been executed or still is active. In case of any doubts about making a trade, the client must contact the support department and obtain the necessary explanations regarding the validity of the trade.

     

    6.    Call Margin Level

    Aron Broker trading platform has an automatic stop loss feature called call margin level and auction level. If the margin call level and auction level are reached, they will be calculated as follows:

    • When the margin level (the ratio of the current balance to the margin *100) reaches below 100%, the client cannot open any new trading position. If the amount of loss reaches the auction level, according to the number of opened trading positions he has, the system starts to close them. It starts from the one with more losses; by taking this action, the margin call level will return to the top of the auction level. If the margin level is still under the auction level, every time that trading positions get closed, this process will be repeated. If the back trend and margin level reach the margin call level, the client can submit the new orders according to the margin he has. Kindly note that all these steps are instantaneous and are done in a fraction of a second. These numbers can be changed according to market conditions and fluctuations.

     

    Aron Broker may change the call margin level and auction level for any market from time to time without prior notice, in situations like during unstable market conditions or the low level of liquidity of the market. This new call margin level and auction level will include all the current trading positions and new trades of the client. The trading symbols and trading account sector mention the minimum margin level requirements, which are valid at the time of these papers. The broker’s website will announce those margin level requirements that are not mentioned or changed. The customer should ensure that they are using the latest margin level requirements.

     

    Monitoring opened trading positions, and other related factors for calculating margin level is the client’s responsibility. Aron Broker is not obligated to ask the client to increase the margin at any time.

     

    Aron Broker may take the delay in payment related to margin level as the client’s risk and change the margin call level and auction level or close the trading account at its sole discretion.

     

    If the client’s trading account is closed by the broker, they are no longer allowed to make any trade.

     

    The client should rely on something other than the broker’s right about requesting to increase the margin level to monitor the trading positions because it is the client’s responsibility. In addition to Aron Broker Ltd takes no responsibility in this case and is not obligated to issue a request for an increase in the margin level. Every request or announcement given in one particular case by the Aron Broker should not be considered as an obligation to give such request in other cases.

     

    7.    Commission

    When you act for buy or sell, the commission is instantly deducted from the balance according to the trade volume.

     

    By “close by” order, you can simultaneously close a buy or sell position about a trading symbol. It should be noted that the commission is not deducted when using this order for closing trading positions.

     

    8.    Trading account and trading symbols details

    Details of trading accounts and symbols represent essential information regarding each of the markets offered by Aron Broker. Therefore, we strongly suggest that all the clients read them carefully. The provided information includes:

    • Spread, commission, and swap for each trading symbol
    • Minimum margin requirements (margin call level and stop-out) and leverage for each instrument.
    • Beginning and end of each trade
    • Details related to the trading volume
    • Other related topics to the market

     

    Aron Broker tries its best to guarantee that all the provided details about trading accounts and trading symbols are accurate and correct and reserves the right to modify any part of these details at any time.

     

    Spreads or commissions related to trading symbols will be disclosed to the client upon request. Aron Broker reserves the right to change swaps, spreads, commissions, or trading volume without prior notice, especially when the market is highly volatile or lacks liquidity.

     

    If any trader’s trading accounts are inactive for 90 days due to this inactivity, a $2 monthly fee will be charged.

    • Deducting fee at first applied after passing 90 days; after that, it changes to 30 days.
    • The deducted fee is $2 or its equivalent, which is deducted until the user’s account has sufficient balance in the mentioned periods. The process continues until the account is automatically archived.
    • If the account balance is less than $2, the total account balance will be deducted, and the account will be archived.
    • If the account balance is zero, the account will be archived automatically.
    • Traders who do not intend to make any trade suggest transferring the balance of their account to one of the wallets and archiving their account, so they are not charged this fee.

     

    9.    Trading bot

    Using a trading bot is possible only according to the rules of the broker, and in some trading accounts, the trader does not have the right to use a trading bot (for more information visit the official website of the Aron Broker the trading accounts section); Therefore, in case of any suspicious activity or violating rules the company has the right to block all client’s accounts and refuse to provide services to them without any warning or explanation.

     

    Trading bots, scripts, or other related tools must not be malicious, like arbitrage, misuse of supply and demand delays, sudden price changes, etc. If such cases are observed, the Aron Broker has the right to investigate and make decisions based on the laws.

     

    Experts and related assets must be used within the framework of the broker’s trading platform, not in an unspecified manner. Therefore, the broker has the right to block all the client’s accounts without any warning and take appropriate measures, including considering monetary and non-monetary fines, in case of any suspicious activity, such as using bots/experts and related assets Intentionally or unintentionally and refrain from providing services to them.

     

    10. Swap

    There is a possibility for instant trading of currency pairs, precious metals, global indices, energies, stocks, etc. each market has its special condition, spread, and swap, which may change at the discretion of Aron Broker. Such trades are automatically renewed and carried over to the next trading session. Every day a credit/debit adjustment related to the swap is made in the client’s account. Details about the swap are listed on the website of Aron Broker in the trading assets section.

     

    Trading positions will remain open until the client has sufficient funds to provide the required margin level for each market. If applying a swap causes the financial resources in the client’s account to submit a negative record (the debtor), in this case, the Aron Broker reserves the right to close all open positions at its sole discretion. If, due to the applying swap and margin requirement limitations, the trader cannot provide the needed fund for assets like currency pairs, precious metals, global indices, energies, stocks, etc. Aron Broker reserves the right to close the whole trade or part of it to put the client in a positive financial record of available funds. In this case, the company will decide close which position and keep which one open. The broker is not responsible for the following market trend related to closed or opened positions.

     

    All the trading positions that remain open before 01:59:59 (according to server time) are included swap. The client should refer to the trading symbol section in MetaTrader for the swap details.

     

     

     

    11. Termination of the agreement

    The client can terminate this agreement immediately upon written or oral notice to the Aron Broker.

     

    The client can contact the broker’s support department via email at any time and request to close their account. Aron Broker closes the client’s account only if the client has no open trading position or any debt to the broker, including all material and moral losses and potential losses of the client to Aron broker.

     

    The client unconditionally agrees that the Aron Broker has the right to immediately close or suspend their account in case of the following terms:

    • In case of violation of terms and conditions.
    • In case of submitting incorrect information during the registration.
    • In case of rudeness or insulting behavior with the company workers.
    • If The company decides to terminate the client’s account for any other reason.

     

    If any parties to this agreement terminate it, all the open positions will be closed immediately based on the current quote announced by the Aron Broker or the best current market depth price. If a market is closed for any reason, all open positions will be closed based on the next available quote, which will be announced as soon as the market reopens, or the best current price of the market depth, and no new trades will be accepted.

     

    None of the parties will be subject to a fine due to terminating the agreement, and the termination of this agreement will not affect the rights. As soon as each party terminates the agreement, the Aron Broker can merge all or any of the accounts, transfer any credit related to the client’s account to them, and deduct all amounts owed by the customer to the broker.

     

    The broker has the right to close all positions at any time after the termination of the agreement without prior notification to the client.

     

    12. Force majeure

    Force majeure includes exceptional market conditions that may not be allowed the company to fulfill obligations. These exceptional conditions include:

    • According to the broker’s analysis, markets are in an emergency or exceptional situation.
    • Suspending or closing any market for which we quote or imposing unique or unusual restrictions or conditions on trading in such markets.
    • The occurrence of any changes in the venture capital that, based on our analysis would distort the price level in any of the markets for which we have quoted.
    • Any unusual decreasing level of liquidity in any of the quoted markets or the reasonable anticipation of such a decrease or extreme volatility in the analysis of the Aron Broker in any market for which the company typically quotes or the company’s prediction for such happening.
    • Any other events like power outages prevent the company from providing its services.

     

    If the company concludes that there is a force majeure event coming up, then we can, at our sole discretion:

    • Suspend the trade or modify the quotation hours for all or any of the markets;
    • Increasing the deposit requirements or margin levels.
    • Closing one or all the open trading positions (emergency expiration).
    • Stop accepting new trades, even if these trades are for closing trading positions.
    • Reducing the maximum allowed trading volume.
    • Changing all announced spreads.
    • Taking all the action to protect the clients and the company.

     

    Aron Broker is not responsible for any losses the client may incur due to taking action of this clause.

     

    13. Confirmations and questions related to the trades report.

    As soon as making a trade or executing an order, edit the order or canceling the order regarding a trade the details will be displayed on the trading platform.

     

    The client must be fully aware of all trades and trading positions.

     

    The client’s account report details will always be available unless the Aron Broker has suspended their account, or the server is unavailable.

     

    The client must immediately inform Aron Broker Ltd support department if he receives a report about a trade or order not made by him or on his behalf. If the client still needs to receive the report related to the trades that have been made, he should immediately inform the support unit.

     

    If you think that any report contains errors or mistakes in any part, you must immediately notify the support department.

     

    Any questions or disagreements about any trade, along with the details in terms of the time and date of the trade, should be reported to Aron Broker Ltd support department as soon as the client is informed about it.

     

    14. Negative balance protection

    CFD contracts and forex trading are leveraged assets; trading with leverage can increase your profit and losses. In some cases, losses are more than the client’s initial capital; it may lead to a negative balance. In this situation, Aron Broker supports its clients to continue their trades with no concern. The negative balance protection scheme aims to prevent clients from losing more than their initial capital. This action is carried out based on each trading account.

     

    This protection scheme is implemented to support the clients and clients committed to continuously monitoring their open and active trading positions and managing them. Also, the client agrees not to abuse the negative balance protection plan and acknowledges that the company has the right to refrain from providing this plan if any abuse is observed and immediately terminate the customer’s access to trades at its discretion.

    The broker may consider the following actions, whether intentional or unintentional, as attempts to abuse the rules:

    • Withdrawal from the trading account reduces the level of the client’s margin.
    • Hedge trading uses multiple trading accounts in the client’s or others’ names.
    • Using arbitrage to take advantage of price gaps and delays in the data feed that lead to costs for the broker.
    • Not to take reasonable and responsible actions to manage opened trading positions to reduce the risk of loss.

     

    If the client has several trading accounts, the negative balance will be covered first by using the balance of other trading accounts. The company reserves the right not to cover the negative balance caused by the broker’s fees and costs.

     

    If the broker notices fraudulent activity in several trading accounts, the account balance of some people related to that person has become negative. In that case, the company reserves the right to deduct the other client’s negative balance from that related person.

     

    According to the mentioned rules, if no violations are observed, Aron Broker will cover the cost of the negative balance of the clients due to stop-out or severe market volatility; the company will make the client’s trading account zero.

     

    15. Changing terms and Conditions

    These terms and conditions may change at any time after prior notice to the clients. Any changes will be effective immediately upon announcement, and it will include all open positions and unexecuted orders on and during the applying changes and after the date

• • Download

    Conflict Of Interest Policy-Aron Brokers Ltd (Mauritius)-Effective Date: July 2024

    

  • 1.    INTRODUCTION

     

    Aron Brokers Ltd is entrusted with the stewardship of our client’s assets and this is a responsibility that we take very seriously. Our reputation as responsible, considered investment professionals is important to us and we seek to be above reproach when investing for our clients. A conflict of interest prejudices or can be seen to prejudice an individual’s objectivity and ability to act in the best interests of the company or our clients.

    Aron Brokers Ltd seeks to comply with all relevant legislative obligations but aims to set higher standards when it comes to protecting our reputation.

    This policy sets out the standards set by Aron Brokers Ltd in respect to avoiding or, where this is not possible, mitigating potential and actual conflicts of interest. It encompasses conflicts that can manifest as a result of the staff member’s personal interests and relationships as well as businesses interests and associations.

    This policy has been approved and adopted by the Board of Directors. Our Obligation

    We are obliged to manage fairly conflicts of interest, both those that arise between ourselves and any of our clients and those that arise between two or more of our clients.

    Consequently, we maintain and operate effective organizational and administrative arrangements to take all reasonable steps to identify conflicts of interest and to prevent such conflicts from constituting or giving rise to a material risk of damage to the interests of our clients. We also maintain a written conflicts of interest policy appropriate to the size of our firm and the nature, scale and complexity of our business.

    Scope

    This policy applies to all staff of Aron Brokers Ltd Oversight

    This policy is subject to monitoring and oversight by the Aron Brokers Ltd Compliance function.

    Accountability

    1. Staff are accountable for reading, understanding and complying with the standards and processes contained in this policy. Staff are encouraged to bring any situations where significant conflicts of interest exist and which are not covered by this policy to the attention of the Heads of
    2. Management is accountable for ensuring that the processes and controls in their departments are designed to avoid and manage conflicts of interest for their
    • Compliance is accountable for ensuring that this policy is aligned with regulation, as they may change from time to time; for monitoring processes and controls to ensure compliance with this policy and for reporting any breaches of this policy according to the Aron Brokers Ltd compliance escalation framework.
    1. Executive Management are accountable for resolving any agreed breaches of this policy and for maintaining business structures and functions that enhance Aron Brokers Ltd’s

    Breaches and Enforcement

    Non-Compliance with this policy may be handled in terms of Aron Brokers Ltd’s disciplinary procedures.

    2.    LEGISLATION AND REGULATION

     

    Definitions

    A conflict of interest is:

    1. Any actual or potential conflict;
    2. That may manifest while rendering a financial service (i.e. either advice OR brokerage service)
    3. To a client (or potential client)
    4. That may influence the objectivity of the obligations to that client
    5. Or prevent an unbiased and fair financial service to that client
    6. Or prevent Aron Brokers Ltd from acting in the best interests of that client

    A conflict of interest includes a financial interest; an ownership interest or a relationship (personal or business) with a third party.

    A financial interest is:

    1. Cash, Cash equivalent or Voucher
    2. Gift
    3. Service
    4. Advantage
    5. Benefit
    6. Discount
    7. Travel
    8. Hospitality
    9. Accommodation
    10. Sponsorship
    11. Incentive

    A Supplier includes but is not limited to:

    1. suppliers of equipment, products, services, market and economic data, research, banking, custody, administration, legal, accounting, marketing, office or
    2. other consulting services
    3. regardless of whether a fee is paid directly or indirectly or
    4. whether the fee is for Aron Brokers ’s account or for the client account. Advice is:
    5. Any recommendation, guidance or proposal
    6. On a financial product (i.e. insurance policy; unit trust; cash or financial instrument)
    7. In respect of the purchase, sale or variation of that product

    It excludes factual, legal or administrative information. It is accepted that Aron Brokers Ltd does not generally provide advice.

    Guiding Principles of the Policy:

    All employees and Associated Person/s with the Company covered under this Policy shall adhere to following principles and practices to avoid conflict of interest at all points:

    1. To maintain high standards of integrity in the conduct of business at all
    2. To ensure to communicate policies, procedures and code to all
    3. To ensure fair treatment of clients and not to discriminate amongst them;
    4. To ensure that Company’s personal interest does not, at any time conflict with our duty towards our clients and clients’ interest shall always takes primacy in our advice, investment decisions and transactions;

    To make appropriate disclosure to the clients of possible source or potential areas of conflict of interest which would impair our ability to render fair, objective and unbiased services;

    1. Endeavor to reduce opportunities for conflicts through prescriptive measures such as through information barriers to block or hinder the flow of information from one department/ unit to another, ;
    2. To place appropriate restrictions on transactions in securities while handling a mandate of issuer or client in respect of such security so as to avoid any conflict;
    3. Not to deal in securities while in possession of material nonpublished information;
    4. Not to communicate the material nonpublished information while dealing in securities on behalf of others;
    5. Not to contribute in manipulating the demand for or supply of securities in the market or to influence prices of securities;
    6. Not to provide incentive structure that encourages sale of products not suiting the risk profile of clients;
    7. Not to share information received from clients or pertaining to them, obtained as a result of our dealings, for our personal interest.

    Effective Mechanism:

    All are advised to adhere to various principles stated hereinabove to avoid any conflict of interest situation. Further, Board of directors of the Company will endeavor from time to time to put in place effective system in place for proper implementation of this circular.

    Board from time to time will also provide necessary guidance enabling identification, elimination or management of conflict of interest situations and shall review the compliance of this circular periodically.

     

    3.    PERSONAL CONFLICTS OF INTEREST

     

    We have identified the below particular personal conflicts of interest as the most important.

    1. Anti-Bribery Policy
    2. Personal Account Dealing Policy
    3. Disclosure of Director Interests
    4. Disclosure of Staff Interests
    5. Second Jobs
    6. Remuneration

     

    3.1  ANTI-BRIBERY POLICY

    Aron Brokers Ltd prohibits:

    the offering, the giving, the solicitation or the acceptance of any bribe, whether in the form of cash or other inducement, to or from any person or company, wherever they are situation and whether they are a public official or body or private person or company by any individual employee, agent or other person or body acting on Aron Brokers Ltd.’s behalf in order to gain any commercial, contractual or regulatory advantage for Aron Brokers Ltd in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

     

    3.2  PERSONAL ACCOUNT DEALING POLICY

    It is Aron Brokers Ltd.’s policy to permit personal account dealing by staff members in a managed and controlled process.

    Personal Account dealing by staff members of an investment manager can and does result in conflicts of interest. There are also advantages for clients when their own investment interests and those of their managers are appropriately aligned and when personal dealing is managed and controlled.

    In brief, Aron Brokers Ltd.’s staff are not permitted to trade in any instrument while client portfolios are in the market with respect to those instruments, regardless of the direction. Nor are they permitted to trade while an instrument is under consideration for inclusion, exclusion or variation in client portfolios.

    All personal dealing performed or influenced by a staff member, including dealing by an associate of the staff member, must be disclosed and pre-approved in terms of a defined process.

    The policy and process is available at: Personal Account Dealing Policy.

    3.3  DISCLOSURE OF STAFF INTERESTS

    Staff members with interpersonal relationships with suppliers or counterparties and who have any decision-making influence over the commencement, continuation or termination of the business relationship, or are involved in the provision of services or products by that supplier or counterparty, must:

    1. disclose such relationship in email to their direct line manager and
    2. ensure independent oversight by someone with knowledge of the interpersonal relationship over processes such as tenders, appointments, reviews, benchmarking or contractual

     

    3.4  SECOND JOBS

    A second job may create a conflict of interest for staff members. The conflict can be direct (eg a potential competitor) or indirect (e.g. impacting work performance or Prudential’s reputation). Depending on the nature of the second job, it can also attract legal liability to Prudential. All staff members with second jobs must have their direct line manager’s express permission to accept any second job regardless of whether or not it is short term, temporary, does not involve work during normal office hours or is unrelated to financial services.

     

    3.5  REMUNERATION

    All staff are remunerated with a mix of guaranteed pay and variable compensation.

    All staff, including Compliance staff, also participates in a short-term variable compensation pool that is driven exclusively by business profits. New business consultants are partly incentivised by means of commission driven business targets. These targets include achieving new business targets as well as servicing and supporting existing business.

    4.    BUSINESS CONFLICT OF INTEREST

     

    1. Sponsorships and Reciprocal Agreements
    2. Investment Independence
    • Commission Sharing
    1. Fair treatment of Clients following are the key business conflicts of interest as determined by the board

     

    4.1  SPONSORSHIPS AND RECIPROCAL AGREEMENTS

     

    Aron Brokers Ltd does not enter into agreements to supply investment services to a fiduciary client that includes reciprocal commercial provisions involving the client, its sponsoring employer or organization or its consultants and advisors.

    Aron Brokers Ltd may make donations or sponsorships to clients or their sponsoring employer or body, intermediaries; not-for profit organizations and social development organizations subject to:

    1. Prior approval by Executive Management
    2. The recipient organization not being directly or indirectly associated with a political party, government body or religious organization
    • The purpose for the donation or sponsorship is defined and is not likely to negatively impact Aron Brokers Ltd or the Prudential Group’s brand and

    Aron Brokers Ltd does not make political donations of any kind.

    4.2  INVESTMENT INDEPENDENCE

    Aron Brokers Ltd is not associated with any Mauritius financial service company, banking institution or stockbroker or any issuer company into which we can invest or deal on behalf of clients.

    4.3  COMMISSION SHARING

    Aron Brokers Ltd does not engage in the practice commonly known as “softing”. Aron Brokers Ltd does however negotiate, on behalf of its clients, bundled brokerage fees that include research and execution services. The execution services may include trading platforms and the research services include investee company research, market and bespoke research and recommendations. These services may be provided by way of software, platforms or electronic research feeds.

    4.4  FAIR TREATMENT OF CLIENTS

    Aron Brokers Ltd is committed to treating clients fairly and ensuring that no client receives preferential treatment that may prejudice another client.

    The following specific processes exist in order to achieve and demonstrate the fair treatment of clients:

    1. The fair and automated allocation of trades to client portfolios
    2. Consolidation of orders to avoid unintended impacts of order priority
    • Limited discretion to investment decision makers to exclude orders where trading costs cannot be justified
    1. Cross trading between client portfolios, while permitted and encouraged as a means of minimizing client trading costs and maximizing exposure
    2. to desired illiquid assets, is subject to the trade being performed at an established and fair market price and the group decision making
    3. The remuneration structures for investment professionals support performance without preferring specific clients
    • The remuneration structures for client sales and services support new business and servicing without preferring specific clients within various products

     

    5.    IMPLEMENTATION AND DISTRIBUTION

     

    This policy is not subject in its entirety to an initial or annual acknowledgement by all staff as the primary control for the avoidance and management of conflicts of interests is internal business processes and controls. Certain aspects of the policy impose personal obligations on staff members and these sections will be subject to active acknowledgement by all staff members.

    Examples of potential situations of conflict and relevant measures.

     

    Examples of potential situations of conflict		General arrangements or ad hoc measures
    Aron Brokers Ltd or a Relevant Person may have an interest in executing its/his personal orders or orders of a client in more favorable conditions than the orders of another client, or in maximizing the client’s losses (e.g. if the client is a competitor of Aron Brokers Ltd or of the Relevant Person)		Aron Brokers Ltd has implemented policies and procedures for the monitoring and (when necessary) restriction of personal transactions of the Relevant Persons. Transactions are processed through automated means, based on the time priority of the reception of such order, thus ensuring that the relevant employees will not be allowed to intervene in your transactions. Conflicts related to the personal capacity of the Client are reported to the compliance function as soon as they are identified.
    A Relevant Person may have an interest in recommending to a client a particular transaction, in respect of which Aron Brokers Ltd or the said Relevant Person may receive a benefit from a third party or taking into account the interests of another client.		Aron Brokers Ltd does not provide investment advice with respect to FX and CFDs transactions and thus cannot recommend you any particular transactions.

    A Relevant Person may recommend to the client a transaction based exclusively on the remunerations to be received by Aron Brokers Ltd or by the employee.		The remuneration that Aron Brokers Ltd receives for the execution of your transactions, may depend either on the volume of your transactions (when a Liquidity Provider remunerates H International Ltd by providing a percentage of the spread of your trades) or on the amount of your losses (when a Liquidity Provider trading on its own account against your positions remunerates Aron Brokers Ltd based on the profits generated by the Liquidity Provider from your trades and therefore from the amounts that you lose when trading through Aron Brokers Ltd).
    		However: – Aron Brokers Ltd does not provide investment advice to you with respect to your trades on the financial products available in our platforms and, thus, cannot recommend you any particular transactions.
    Aron Brokers Ltd may be regarded as having an interest in maximizing your trading volumes or in maximizing your losses in order to achieve higher remunerations.		–   Transactions are processed through automated means, based on the time priority of the reception of such order, thus ensuring that the relevant employees will not be allowed to intervene in your transactions –    Aron Brokers Ltd does not have a way to influence the outcome of your transactions and the persons in charge of the supervision of the processing of your orders (Dealing Desk) are always remunerated with fix amounts and not based on your trading volumes or losses.
    		– Aron Brokers Ltd monitors regularly the operation of the systems used for the processing of clients’ orders in a way to exclude any human intervention that is not necessary for the normal operation of such systems.
    		– In all cases, when Aron Brokers Ltd’s remuneration depends on the revenue of a Liquidity Provider, the relevant arrangements are made in a way that such remuneration is not calculated on a client-by-client basis, but based on the total PNL of our clients’ positions with the relevant Liquidity Provider, which means that the outcome of your transactions is not directly linked to our remuneration. It is noted as well that Aron Brokers Ltd is not part of any group of companies in which could be part any of our Liquidity Providers, which means that Aron Brokers Ltd

    does not have any further interests in the profits realized by the relevant Liquidity Provider. – In accordance with the applicable best execution policy, Aron Brokers Ltd is prohibited from directing your transactions to an Execution Venue based on the remunerations to be received by Aron Brokers Ltd.

• • Download

    Order Execution Policies-Aron Brokers Ltd (Mauritius)-Effective Date: July 2024

    

  •  

    1.    Introduction

    This condition controls the trade of all actions related to clients’ orders and requests.

    Trade conditions consist of the following:

    • Open rules/closing deals & record/ modify /delete orders execution under the conditions of the normal market and abnormal market conditions
    • Company actions related to client’s open positions in a condition that trading account margin level isn’t enough for supporting of open positions
    • Procedures related to solving debates and contact methods between clients and the company

     

    In this contract, trade conditions and client agreement control all client’s transactions, and clients must study them carefully.

    If the trade condition has a different definition, it will be shown by capital initial letters and must be synonym with similar conditions in the client’s contract, also, definitions that have been described in item 10 (condition interpretation) must be executed.

     

    2.    General Condition

    2.1.  Executing client’s requests and orders

    Mechanisms related to the quote (that is used for doing the deal) have been specified in the section of contract specifications.

    The procedure for handling to client’s requests and orders offered at the client’s terminal is as follows:

    • The client provides an order or request, and the client’s terminal inspects its credit.
    • The client’s terminal sends the order or request to the server.
    • If the connection between the client’s terminal and the server hasn’t been disturbed, the server receives the order or request and starts the confirmation process.
    • The client’s valid order or request is placed in queue and is organized based on the time (exit in the order of entry) and in the client’s terminal order window ” the order accepted” appears. Also, in the market’s abnormal conditions, the company has no responsibility for any delay in the execution of orders.
    • When the mediator or dealer has sufficient preparation to handle a request or a new order, take the first request or order from the queue and process it and the condition of “the order is processing” appears at the order window of the client’s terminal.
    • The server receives the results of the client’s order or request execution process from the dealer.
    • The server sends the results of the client’s order or request execution process to the client’s terminal.
    • If the connection between the server and the client’s terminal hasn’t been disturbed, the results of the client’s order or request execution process are received by the client’s client.

     

    The client has the right to cancel an order or request only if the request or order has the “order is accepted” condition. To cancel it, the client must press the cancel order button.

    If an order or a request is being processed by a dealer and its condition is in the “order in process” mode, the client has no right to cancel it.

    In tools with quotes, the quotes that the client receives in the mood of request execution through its terminal only have the index role. In response to the request, the trader can recommend a price that is different from these Index quotes. The company with its exclusive authority can determine the current market price. The amount of time that a dealer needs to execute a request, or an order depends on the connection quality between the client’s terminal and server and also on the normal market conditions.

    The standby time for each order or request that is in queue, at the time of publishing of these trade conditions, has a three-minute limitation to execute.  If in this period, the request or order hasn’t been received by the dealer, the order or request will be known as unrelated and will be deleted automatically. In abnormal market conditions, the company has this right for itself, based on its exclusive authority, to reject any order for execution.

    Under the following conditions, the company may not accept an order or a request ( in this case the message “quotes canceled” will appear on the client’s terminal):

    • If the order or request is ahead of the initial quote in the trading platform when the market opens.
    • If the current condition is different from the normal market conditions.
    • If the client compared to his/her transportation amount, has placed an unreasonable number of requests.
    • If the client’s free margin is lower than the initial margin.
    • Any other logical item that belongs to the company’s exclusive authority.
    • If exceeds the related limit to the client’s total position volumes and/or number of orders in these accounts

     

    2.2.  Deals

    From the buy price (the maximum suggested buy price) is used for doing the “buy” transaction.

     

    • The buying price is used for making buy open deals and from the sell word is used for making sell open deals.
    • From the sell word is used for a buy position (meaning sell). From the buy word is used for closing a sell position (meaning buy).

     

    2.3.  Open deals commission

    All the positions that remain open till the server time 01:59:59 are subject to swap. The client must refer to the symbol’s characteristics at the MetaTrader to be aware of the swap value.

     

    2.4.  Modifications before market closing

    Please remember that on holidays and in volatile market conditions, if any position closes or is modified in the micro account one hour before trades end, the company based on its exclusive options may change the leverage for all the symbols. However, before the start of the next trading period, leverage adjusts again based on the volume of all the account’s open positions.

    The company based on an exclusive option, may with previous notification to the client, extend these modifications till any time after market opening that recognizes it is essential.

     

    2.5.  Spreads

    The company with its option can provide quotes with a fixed or variable spread for all or part of its tools.

     

    2.6.  Synchronization of quotes reference

    In the conditions of hardware or software failure, an unpredictable stop in the quotes circulation occurs, and the company has this right to synchronize the quotes reference on the live server from other reputable resources.

    When any difference related to the quoted circulation occurs, all the decisions are made in compliance with the synchronized quotes reference.

     

    2.7.  Leverage

    The amount of leverage when the client opens an account must be fixed in the value adjusted by the client and/or at the modified value by the client based on the company’s policies. The company has the right to change the trading account leverage instantly and without any previous notification.

     

    The leverage may change in the following conditions:

    • In the abnormal market conditions
    • In the emergency conditions
    • In the happening of the unexpected events

     

    The company has this right to apply a new essential margin that has been modified based on the above-mentioned 2.15. clause to new positions and the positions that are open beforehand.

    The company for any loss or warnings related to the margin call (capital deficit) that the client may experience, doesn’t owe and doesn’t have any responsibility, and doesn’t accept any responsibility. Items such as loss due to auction level (stop out level ), in the result of any changes in floating leverage based on a stock

     

    3.    Opening a Deal

    For issuing a command to open a position, the client must specify the following items.

    • Tool
    • Transaction amount

     

    3.1.  Tools with the quote in the mood of instant execution

    To open a position through the client’s terminal without using an automated trading robot, the client must press the sell/buy button when he/she sees the offered quotes satisfiable.

    To open a position through the client’s terminal by using an automated trading robot, the close position command must be made at the current quotes.

    To open a position through the client’s terminal without using an automated trading robot, the client must send a request, the client may press the buy/sell button to open a position at the offered quotes.

    If the client doesn’t send the command within three seconds after receiving the quote or if market moves make the quote unrelated, the company has the right to cancel the quote.

    As soon as the server receives the client’s order for making a position, the server automatically inspects that the free margin is sufficient for opening this position.

     

    The free margin is calculated as the following:

     

    Free margin = financial balance – new margin + floating profit – floating loss

     

    All floating loss /profits calculated for all open deals and the new deal is calculated at the current quotes. If the above-mentioned calculations have been done for the new position and:

    • If the free margin is higher or equal to zero, the position opens. Making the positioning process accompanied by placing related records at the server event file and the opened position due to this order will have the same conditional order ticket.
    • If the free margin is lower than zero, then the company has the right not to accept the command for making position and delete the condition order and the “No Money” message will be recorded in the server event file.

     

    If the current quote changes when the mediator is processing the client’s order or request, the company has the right to quote again.

    If in the order window the option “maximum difference from the announced quote” has been ticked and the value of the “maximum difference” field equals zero, the requote window will become active again.

    If the client doesn’t press the “ok” button within three seconds, the quote becomes invalid and it will be realized that the client has refused to open the position.

    When the related records appear in the server event file, it must be considered that a command for opening a position has been executed and the position has been opened. In the trading platform, each opened position has a ticket.

    If, when the market opens, one opening position command sooner than the first quotes refers to the trading platform, this command will not be accepted by the company. In this case, an ff-quotes message will appear on the client’s terminal window.

     

    4.    Closing a Deal

    For issuing a command to close a position, the client must specify the following items:

    • Deal operating number (Ticker )
    • Transaction amount
    • Tools with quotes in the condition of instant transactions

     

    To close a position through the client’s terminal without using an automated trading robot, the client must press the close button when he/she sees the offered quotes satisfiable.

    To close a position through the client’s terminal by using an automated trading robot, the close position command must be made at the current quotes.

     

    4.1.  Tools with the quote in the mood of request execution

    To close a position through the client’s terminal without using an automated trading robot, the client must press the request button when he/she receives the quote and is satisfied, the client must press the close button within three seconds till the time the quote is still valid.

    If the client doesn’t command in this period or if market moves make the quote unrelated, the company has the right to cancel the quote.

     

    4.2.  Orders process and execution for closing a position

    • If the current quote changes when the mediator is processing the client’s order or request, the company has the right to quote again.
    • If in the order window the option “maximum difference from the announced quote” has been ticked and the value of the “maximum difference” field equals zero, the requote window will become active again.
    • If the client doesn’t press the “ok” button within three seconds, the quote becomes invalid and it will be realized that the client has refused to close the position.
    • If among clients’ open positions, there is a position that the client wants to close to by open position, the client can do this by using the option “close by” from the type drop-down menu.
    • According to the deal’s protection amount, with compliance/closing the client’s optional position, the client must have a zero or net sell / buy position.
    • The client must be aware that to the general net position a new ticket devotes.
    • By using the option “close by”, the client closes the positions locked in the same volume and partially closes two locked positions in different volumes.
    • In the bigger position, the equal or smaller position is closed, and a new open position is made that is in the trajectory of the bigger position, and a new ticket is devoted to it.
    • When the related records appear in the server event file, it must be considered that a command for closing a position has been executed and the position has been closed.
    • If, when the market opens, one closing position command sooner than the first quote refers to the trading platform, this command will not be accepted by the company. In this case, an ff-quotes message will appear on the client’s terminal window.
    • If the command of the closing position occurs at a time when the take profit or stop loss for this position is in the queue for execution, the order of closing will not be accepted by the company. In this case, an off-quotes message will appear on the client’s terminal window.

     

    5.    Ordering

    5.1.  Different types of orders on the trading platform

    For opening a position, it may be to use conditional orders

    • Up limit buy; an order for making a buy position in a price upper than placing an order price
    • Down limit sell; an order for making a sell position at a price lower than placing the order price
    • Down limit buy; an order for making a buy position at a price lower than placing an order price
    • Up limit sell; an order for making a sell position in a price upper than placing an order price

     

    To close a position, it may be to use the following orders:

    • Stop loss; an order to close a previously open position at a price with lower profit ( for the client ) compared to placing an order price
    • take profit; an order to close a previously open position at a price with higher profit ( for the client ) compared to placing an order price
    • Two-Steps orders; stop loss or take profit that becomes active immediately after executions of the initial conditional orders related to them

     

    5.2.  When and at which time orders can be placed?

    • The client may place/modify / or remove the orders in the trading hours for the related tool.
    • Expiration condition for conditional orders has been specified on the tools at contract specifications
    • Stop loss and take profit has the GTC “active till cancellation time” condition for all the tools

     

    5.3.  The procedure of placing an order

    To submit a command for placing a conditional order, the client must determine the following mandatory parameters.

    • Tool
    • Transaction amount
    • Type of order (Buy Stop, Buy Limit, Sell Stop, or Sell Limit)
    • Order level

    Also, the client may determine the optional following parameters:

    • Stop loss level. “0.0000” means the stop loss has not been placed. (or if placed previously, now has been deleted)
    • take profit level. “0.0000” means the profit has not been placed. (or if placed previously, now has been deleted )
    • Date and time of the conditional orders

     

    The command will be canceled under the following conditions.

    • If any of the mandatory parameters haven’t been determined or are not correct.
    • If any of the optional parameters are not correct.

     

    In this condition, the error message ” Invalid S/L or T/P” will appear. Of course, if the order has been placed from the client terminal without using an automated trade robot.

    If a client wants to submit an order for placing take profit or stop loss, the following information must be determined.

    • Open position ticket
    • Stop loss level. “0.0000” means the stop loss has not been placed. ( or if placed previously now has been deleted )
    • take profit level. “0.0000” means the profit has not been placed. ( or if placed previously, now has been deleted )

    If any of this information isn’t correct and orders have been placed by the client’s terminal without using an automated trading robot, the command will not be accepted and the modify button will remain inactive.

    If the client wants to put a command at two-step orders (If-Done) on a conditional order, the following items must be determined.

    • Ticker (operating number) for the condition that the client wants to place an order on it.
    • Stop loss level. “0.0000” means the stop loss has not been placed. ( or if placed previously, now has been deleted )
    • take profit level. “0.0000” means the take profit has not been placed. ( or if placed previously, now has been deleted )

     

    If any of this information isn’t correct and orders have been placed by the client’s terminal without using an automated trading robot, the command will not be accepted and the modify button will remain inactive.

    When placing the order, the difference between stop loss or conditional order and the current price of the market must not be lower than the number of points that have been determined for each tool and the following condition must be fulfilled:

    • About stop loss on sell position, the current market price will be buy word and the order must not be lower than buy word plus these points when being placed.
    • About taking profit on a short position, the current market price will be buy word and the order must not be lower than buy word minus these points when being placed.
    • Regarding stop loss on buy position, the current market price will be the selling word and the order must not be placed higher than the selling word minus these points.
    • taking the take profit on the buy position, the current market price sell word and the order must not be placed lower than the selling word plus these points.
    • About the buy limit, the current market price will be buy word and the order must not be placed higher than buy word minus these points.
    • About buy stop, the current market price will be buying word and the order must not be placed lower than buy word plus these points.
    • About the sell limit, the current market price will be the selling word and the order must not be placed lower than the selling word plus these points.
    • About the sell stop, the current market price will be the selling word and the order must not be placed higher than the selling word minus these points.

     

    When placing an order, the difference between the two-step order level and conditional order must not be closer than the number of points that have been determined for each tool in the contract specifications and the following conditions must be fulfilled:

    • Stop loss on Buy Limit or Buy Stop must not be more than conditional order level minus these number of points.
    • Stop loss on Sell Limit or Sell Stop must not be lower than conditional order level plus these number of points.
    • Loss profit on Buy Limit or Buy Stop must not be lower than conditional order level plus these number of points.
    • Loss profit on Sell Limit or Sell Stop must not be more than conditional order level minus these number of points.

     

    When the related records appear in the server event file, it should be considered that the command has been executed and the order is placed.

    Any conditional order has a ticket.

    If, when opening the market, the placing command of an order refers sooner than the first quote, this order will not be accepted by the company. In this case, an off-quote message appears on the client’s terminal window.

    If, when processing an order by a mediator, the current quotes achieve a level that violates 5.9. and 5.10. clauses, the company has the right not to accept the order.

     

    5.4.  Modifying / Deleting an order procedure

    If a client wants to submit an order for modifying conditional order parameters. (Conditional order levels/two-step orders), the following information must be determined:

    • Ticket
    • Conditional Order Ticket
    • Stop loss level. “0.0000” means the stop loss has not been placed. ( or if placed previously, now has been deleted )
    • take profit level. “0.0000” means the take profit has not been placed. ( or if placed previously, now has been deleted )

     

    If any of this information isn’t correct and orders have been placed/modified/deleted by the client’s terminal without using an automated trading robot, the command will not be accepted and the modify button will remain inactive.

     

    If a client wants to submit an order for modifying take profit or stop loss, the following information must be determined.

    • Ticket
    • Stop loss level. “0.0000” means the stop loss has not been placed. ( or if placed previously, now has been deleted )
    • take profit level. “0.0000” means the take profit has not been placed. ( or if placed previously, now has been deleted )

     

    If any of this information isn’t correct and orders have been placed/modified/deleted by the client’s terminal without using an automated trading robot, the command will not be accepted and the modify button will remain inactive.

    When a client issues a command for deleting a conditional order, he/she must specify the ticket.

    When the related records appear in the server event file, it should be considered that the command has been executed and an order has been modified or deleted.

    If, when opening the market, the modifying or deleting command of order refers sooner than the first quote, this order will not be accepted by the company. In this case, an off-quote message appears on the client’s terminal window.

    If while the process of command for modifying or deleting an order is done, the order is placed in the execution queue, based on the 5.22 clause of this document, the company has this right to not accept the modifying or deleting command.

    When a client issues a command for modifying or deleting an order level, if the process of that order ends at the time that the order is placed in the execution queue based on the 5.22 clause, the company has the right to reject the modifying order level or order deletion.

     

    5.5.  Command execution procedure

    Under the following conditions, the order places in queue for execution:

    • If the selling word is in quotes circulation becomes equal to or higher than the order level. take profit on the buy position placed in queue for execution.
    • If the selling word is in quotes circulation becomes equal to or lower than the order level. Stop loss on the buy position placed in queue for execution.
    • If the buy word is in quotes circulation becomes equal or lower than the order level. take profit on the sell position placed in queue for execution.
    • If the buy word is in quotes circulation becomes equal to or higher than the order level. Stop loss on the sell position placed in queue for execution.
    • If the buy word is in quotes circulation becomes equal or lower than the order level. Buy Limit is placed in queue for execution.
    • If the selling word is in quotes circulation becomes equal to or higher than the order level. The sell Limit is placed in queue for execution.
    • If the selling word is in quotes circulation becomes equal to or higher than the order level. Buy Stop is placed in queue for execution.
    • If the selling word is in quotes circulation becomes equal to or lower than the order level. The sell Stop is placed in queue for execution.
    • If any of the commands including Buy Limit, Sell Limit, Buy Stop, or Sell Stop consists of a profit/stop loss, also at the time when buying word or sell word in quotes circulation exceeds the take profit or stop loss there is a gap price, based on the condition, the order must be opened and closed with a price near to the new quotes.

     

    As soon as the conditional order is placed in the execution queue, the server automatically inspects that the free margin is sufficient for making this position.

    • Accumulated client’s positions and new margin for matched positions calculated based on the essential margin amounts for hedged margins.
    • For other positions, this factor depends on the initial margin that calculates a weighted average (by volume) of all positions except matched positions.
    • If the level of conditional order is at the price gap, floating loss/profits for all open positions and new positions by current words are calculated at the time of order placement in the execution queue.
    • The free margin is calculated as the following:
      • Free margin = financial balance – new margin + floating profit – floating loss
      • If the above-mentioned calculations have been done for the new position and:
      • If the free margin is higher or equal to zero, the position opens. Making the positioning process accompanied by placing related records at the server event file and the opened position due to this order will have the same conditional order ticket.
      • If the free margin is lower than zero, then the company has the right to not accept the command for making position and delete the condition order and the “No Money” message will be recorded in the server event file.

     

    When the related records appear in the server event file, it should be considered that the other has been executed.

    At the time of conditional order execution, making the positioning process is accompanied by placing records in the server event file. And the open position due to this order will have the same ticket as the conditional order.

    At the order level adjusted by the hedging expenses, if there isn’t enough liquidity for hedging trade with market builders, the company executes orders including Stop Loss, Buy Stop, and Sell Stop at the order level.

    At the order level adjusted by the hedging expenses, if there isn’t enough liquidity for hedging trade with market builders, the company executes orders including Stop Loss, Buy Stop, and Sell Stop at a price that the company has covered the trade.

     

    The company has the right to adjust this price to reflect the risk coverage expense (hedging expense). The client acknowledges that the execution expenses may differ from the order level.

    At the order level, if there isn’t enough liquidity for hedging the trade with market builders (LPs), the conditional order can be executed fractional.

    In the condition of lack of liquidity by the market builder, for executing the full order, the other must be executed fractional and the unfilled values of the new conditional order must be issued by the previously determined parameters.

    Under the abnormal market condition, there is this right for the company to reject any of the conditional orders.

    If there is more than one mediator, depending on the time the mediator needs to process a request or a command, there is this probability that at the server event file, the execution time of the first recorded request or command in queue will be after the execution time of the next request or command.

    Please pay attention that the orders Sell Stop, Buy Stop, Sell Limit, Buy Limit, Take Profit, and Stop Loss are market orders, so the execution is based on the market condition and the result executes at the current market price.

     

    6.    Auction

    If the client’s net balance is lower than the auction level, on the company’s website the trading conditions have been specified, the company has this right to close the client’s open positions without the client’s permission or any previous notification.

    Auction levels have been specified on the company website and in the ” trading account comparison” section.

    Margin level is monitored by the server and based on the 6.1. clause, the server makes an auction order to close a position without previous notification.

    The auction executes quotes according to the queue priority. The client agrees that the price at which the order is being executed may differ from the quotes that the auction has executed.

    As soon as the position closes, the related record will be shown by the “stop out” auction sign in the server event file (server history).

    If a client has multiple open positions, the first position that must be in queue to close is the position that has the highest floating loss.

    When the last open position closes based on the 6.1. clause and there will be no price gap or price gap in the market opening, the company guarantees that the auction execution for the last position will not result in negative stock net value in the client’s trading account according to the 6.2. and 6.3. clauses.

    If caution execution is made to negative balance creation in the client’s trading account, the client is responsible for this loss and must pay the full amount immediately.

    The company has this right to compensate the loss from the client’s capital in other accounts owned by the client.

     

    About CFDs on future trading contracts that are approaching the basic asset expiration date, transactions are done by the “close only” method.  The company uses the notification email inside the trading platform or shows the information on the company website to the client just notifying them about the date of starting the “close only” mood. The company forcefully close these open positions on the future contracts expiration date as for the last quotes from the last trading period for this contract that difference is made:

    • Buy positions with sell word
    • Sell positions with buy word

     

    The company has this right to close all client’s open positions without warning if this matter should be a dispute process.

     

    7.    Company Actions Related to The CFDs on balances / Indexes

    When trading CFDs on liquid indexes or stocks, consider that the company may apply logical actions in basic assets to reflect company activities. Items such as stock analysis / reverse stock analysis, stock dividend payment, advance right stock, merge, or ownership.

    Also consider that this is the unique responsibility of the client to be aware of the imminent company event that may influence basic securities.

    The company may take all its expenses related to the basic company actions without any notification depending on the client’s position (buy/sell). Of course, when this is applied to us directly by the liquidity provider of the company.

     

    8.    Communications

    For contacting the client, the company may use the following.

    • Trading platform internal post
    • Electronic post
    • Phone
    • Company website

     

    The company uses the contact methods that are offered by the client when opening a trading account or the information that is being updated in compliance with 8.4 clauses to contact the client and in this way, the client announces his/her agreement for acceptance of any message or notification at any time by the company. All correspondents sent to the client (documents, notifications, confirmations, status updates, and so on) are considered received:

    • If received by electronic mail, in a time frame of one hour after sending
    • If received by the trading platform internal post, immediately after sending
    • If received by phone, at the end of the phone conversation
    • If placed on the website’s company news, in a time frame of one hour after placing

     

    For items using clause 8. “Business time” means between morning 9 till 5 of the afternoons, the local time of the company. The client must immediately make the company aware of any changes in his / her contact methods. Transactions by electronic mail must be confirmed on the next business day. If a client has a reason that confirmations are incompatible or the client doesn’t receive any confirmation (while transactions are done), the client must contact client support according to the 8 clauses. All phone contacts between the client and the company may be recorded. All the orders and requests that have been received by phone are mandatory as if they are received written. All the recorded data are in the company’s exclusive ownership and will remain in this way and the client must accept it as conclusive evidence of orders, requests, or recorded conversations. The client accepts that the company may send copies of transcripts of these recorded records to any court, government officials, or regulatory authorities.

     

    9.    Freezing or Account Blocking

    If a company considers receiving documents insufficient and the client can’t provide the essential documents before the determined time recommended by the company, the company may use its option of blocking the client’s account or accounts. In this case, till the time a client provides missing documents for the company, all the client’s accounts are eligible for payment of a handling fee of $5 per month or the account balance, whichever is lower.

     

    If Aron Broker Ltd’ broker realizes malicious activities, client violence, or abuse from the conditions, the company has the right to block all client’s accounts without any warning or definition and avoid offering services to the client.

    10. Expressions Interpretation

    In this document, trade conditions:

    • “Abnormal market” will mean the condition that is opposite of the normal market conditions. For example, when there is low liquidity in the market, there are fast price movements in the market, or there are price gaps.
    • “Bar/candle” are elements of a graph that show the opening, ending, maximum, and minimum prices for a specific period ( For example, one minute, five minutes, one day, one week ).
    • Stop out: auction
    • Freezing of account: account blocking
    • Margin level: shows the level of margin
    • quotes mechanisms: quotes
    • The client terminal: shows the client’s or client’s terminal
    • Standby time: shows the succession time
    • Free margin: the free margins free
    • Initial margin: shows the primary or beginning margin
    • Pending orders: conditional orders
    • Buy Stop: This is an order for making a buy position at a price that is upper that n placing an order price
    • Sell Stop: This is an order for making a sell position at a price that is lower than the placing order price

     

    • Buy Limit: This is an order for making a buy position at a price that is lower than placing the order price
    • Sell Limit: This is an order for making a sell position that is upper than the placing order price
    • Stop Loss: An order for a closing previous open position in a price with lower profit for the client compared to the price while placing an order
    • Take Profit: An order for a closing previous open position in a price with more profit for the client compared to the price while placing an order

     

• • Download

    Privacy Policy-Aron Brokers Ltd. (Mauritius)-Effective Date: July 2024

    

  • 1. Introduction

    Aron Brokers Ltd (hereinafter referred to as “the Company”) takes the security and privacy of clients’ personal data very seriously. This Privacy Policy (hereinafter, “Policy”) outlines how we collect, use, disclose, retain, and protect your personal information in compliance with the Data Protection Act 2017 (DPA) of Mauritius, which aligns with international standards such as the GDPR. By using our services, you consent to the practices described in this Policy.

     

    2. Collection of Your Personal Information

    The Company collects and processes various types of personal information depending on the nature of the services provided. This includes:

    • Personally Identifiable Information (PII): Information submitted during registration for a Real/Demo Account such as name, email and postal addresses, telephone number, country of residence, employment status, financial background, login credentials, and password details.
    • Identity and Residence Verification: Information such as legal name, business name, Tax ID for business entities, date of birth, and supporting documents like identity proof and proof of residence.
    • Service Utilization Data: Information regarding requests or transactions made through our services, payment information, subscription details, user-generated content, and communications with the Company.
    • Website Usage Data: Information about your activity on our website, including IP address, geographic location, operating system, browser type, domain names, access times, and referring website addresses. This may be collected automatically and includes tracking and aggregation of user activity for analysis.

     

    3. Use of Cookies

    Our website uses cookies and similar technologies to enhance your experience. These include:

    • Essential Cookies: Necessary for core functionality such as accessing secure areas or maintaining your login status.
    • Analytical Cookies: Collect data on website usage to optimize and improve the user experience.
    • Performance Cookies: Track website performance metrics to identify and resolve issues.
    • Advertising Cookies: Deliver relevant advertisements based on your interests and measure ad campaign effectiveness.

    You can manage cookie preferences in your browser settings. Disabling cookies may impact some website features.

     

    4. Use of Your Personal Data

    Aron Brokers Ltd uses your personal data to:

    • Operate and Secure Accounts: Facilitate account creation, secure your account, and manage your platform experience.
    • Enhance Services: Improve and promote services, verify identities, prevent fraud, and personalize your experience.
    • Communication: Provide information about products and services, conduct surveys, and gather insights for potential new offerings.
    • Legal and Regulatory Compliance: Fulfill legal obligations, including compliance with anti-money laundering (AML) and know-your-client (KYC) requirements.

     

    5. Disclosure of Personal Information

    The Company may disclose your personal information to:

    • Group Companies and Service Providers: For data processing services, customer support, statistical analysis, and other purposes outlined in this Policy.
    • Law Enforcement and Regulatory Bodies: When required by law or to protect our rights.
    • Third Parties with Consent: When you provide explicit consent for such disclosures.

     

    6. Data Protection and Security Measures

    We implement comprehensive physical, electronic, and procedural measures to protect your personal information against unauthorized access, use, or disclosure. These include:

    • Secure Servers: Storing personal data on secure servers.
    • Encryption: Using encrypted transmission links where possible.
    • Access Controls: Employing firewalls, authentication systems, and access control mechanisms to prevent unauthorized access.
    • Regular Reviews: Regularly reviewing information collection, storage, and processing practices.

     

    7. User Rights

    You have the following rights concerning your personal information:

    • Access and Correction: Request access to and correction of inaccurate or incomplete information.
    • Opt-Out: Opt out of receiving marketing materials.
    • Data Processing: Request the cessation of personal data processing. Withdrawing consent may impact your ability to access certain services.
    • Data Portability: Obtain a copy of your personal data.

    To exercise these rights, contact Customer Support via email, telephone, or postal mail. Note that some information may persist in our records for legal compliance purposes.

     

    8. International Data Transfers

    We may transfer your personal information to third parties in other countries for processing. When doing so, we ensure that your privacy rights are adequately protected in compliance with applicable laws, including putting in place data transfer agreements.

     

    9. Data Retention

    Your personal information is retained only as long as necessary to fulfill the purposes outlined in this Policy unless further retention is required by law.

     

    10. Automated Decision Making

    Our use of your personal information may result in automated decisions, including profiling. You have the right to contest such decisions and request human oversight.

     

    11. Ongoing Updates

    We may update this Privacy Policy periodically. The latest version will always be available on our website. Significant changes will be communicated via the website or email. Continued use of our services after updates signifies acceptance of the revised Policy.

     

    12. Legal Disclaimer

    We may disclose your personal information to comply with legal requirements or protect our rights. We are not liable for misuse of personal information resulting from third-party cookies or unauthorized access due to your negligence.

     

    13. Consent

    By using our services, you agree to this Privacy Policy. If you disagree with any part of this Policy, please cease using our services. Contact us for any questions or concerns about this Policy.

     

    Contact Information

    For any questions or concerns regarding this Privacy Policy, please contact us at:

    • [email protected]

     

     

• • Download

    Risk Disclosure-Aron Brokers Ltd (Mauritius)-Effective Date: July 2024

    

  • 1.    OVERVIEW

    Aron Brokers Ltd, hereinafter referred to as “the Company,” “us,” “our,” or “we,” holds a Full -service Dealer Investment Dealer License (excluding underwriting) under License Number GB24203202. This license is granted in accordance with Section 29 of the Securities Act 2005, Rule 4 of the Securities (Licensing) Rules 2007, and the Financial Services (Consolidated Licensing and Fees) Rules 2008.

    Before establishing any relationship or engaging in trading activities with our Company, both existing and potential clients are urged to carefully read and acknowledge this notice.

    This General Risk Disclosure is designed to provide an overview of the risks associated with trading in Financial Instruments. While it may not encompass every conceivable risk, it aims to outline the general risks inherent in trading Contracts for Difference (CFDs). We strongly advise clients to seek guidance from independent financial advisors if they have any uncertainties. It is crucial to fully comprehend all the risks associated with CFD trading, and if a client is uncertain, they should exercise caution and consider refraining from trading.

    CFDs represent a contractual agreement between two parties to exchange the difference between the opening and closing prices of a contract. These contracts may cover a range of assets, including shares, currencies, commodities, and indices. Investors participating in CFD trading are exposed to both the benefits and risks associated with owning securities, all without possessing any rights to the underlying asset.

     

    2.    RISK ON CFD

    Please be aware that Contract for Difference (CFDs) are intricate financial instruments that carry a substantial risk of rapid capital loss due to the application of leverage. In fact, data from this provider indicates that over 80% of retail investors trading CFDs with them incur financial losses. Prior to commencing CFD trading, it is of utmost importance to thoroughly evaluate whether you have a comprehensive understanding of their mechanics and whether you possess the financial capacity to withstand the elevated risk of potential investment losses.

     

    CFDs represent a category of high-risk investments that may not be suitable for every investor. It is crucial to grasp the risks and characteristics of CFDs before engaging in trading activities. One of the principal risks associated with CFDs involves the potential for amplified losses due to the application of leverage. Leverage enables you to initiate trades with a nominal value substantially larger than your available equity. If you harbor any doubts or uncertainties regarding CFD trading, we strongly recommend seeking independent financial advice beforehand.

     

    While the company is obligated to assess whether CFDs are suitable for you based on your knowledge, experience, and financial resources, the ultimate decision to trade CFDs rests with you.

     

    CFDs are not conducive to long-term investors and necessitate vigilant monitoring over short time frames. Keeping a CFD position open overnight exposes you to heightened risk and additional costs. The combination

    of financial market volatility and increased leverage can lead to rapid shifts in your overall investment position.

     

    It is crucial to recognize that CFDs are not suitable for investors seeking a stable income, as the returns from such investments can fluctuate significantly. CFDs are speculative  products  that enable  investors to capitalize on price movements, both upward (long positions) and downward (short positions), in underlying financial instruments.

     

    It is imperative to understand that you hold no rights or obligations concerning the underlying instruments or assets associated with CFDs. Moreover, there is no physical delivery of the underlying instruments. Therefore, it is essential to invest only funds that you can afford to lose. Given their nature as leveraged products, CFD trading carries the inherent risk of losing your entire invested capital.

     

    Price volatility represents a notable risk in CFD trading, which can be triggered by unexpected economic events or market announcements. Close monitoring of your positions is imperative, as the company may encounter challenges in executing your instructions at the requested price, exposing you to execution risk.

    Prior to opening a CFD position, you will be required to deposit funds with the company as margin. This margin requirement is typically a percentage of the overall contract value, contingent on the leverage associated with the specific underlying instrument. Trading with leverage has the potential to work both in your favor and against it to an equal extent. Throughout the duration of open positions, it is incumbent upon you to ensure that the balance in your trading account exceeds the maintenance margin to keep the transaction active. Failure to do so, especially when market prices move unfavorably, may prompt the company to partially or fully close your trades, leaving you accountable for any resultant losses.

     

    It is essential to note that CFDs are not traded on any exchange, and the company sets the prices, with obligations toward the client. Consequently, prices may deviate from those reported elsewhere and may not directly align with real-time market levels now of options sale.

     

    3.    CHARGES OVERVIEW

    Prior to investing in CFDs, it is essential for the client to be aware of the associated costs, which include Spread(s), Commission(s), and Swap(s). In this context, a swap refers to the interest added or deducted for holding a position open overnight. Notably, the swap for a position opened on Wednesday and held overnight is three times that of other days. This is due to the value date of a trade held open overnight on a Wednesday, which would typically be Saturday. However, since banks are closed on Saturdays, the value date becomes Monday, resulting in the client incurring an extra two (2) days of interest. Conversely, from Friday to Monday, the swap is charged only once. For further details on Commission, Fees, and Charges, please refer to our comprehensive Terms & Conditions.

     

    Furthermore, a spread in the context of CFD trading denotes the difference between the bid price and the ask price of a financial instrument, such as a stock, commodity, or currency. The bid price represents the highest price that a buyer is willing to pay for the instrument, while the asking price is the lowest price that a seller is willing to accept. The spread essentially signifies the cost of trading the instrument, as it is the amount that the buyer must pay above the market price and the amount that the seller receives below the

    market price. The size o. the spread may vary depending on several factors, including the liquidity of the instrument, the trading volume, and the prevailing market conditions.

     

    4.    LEVERAGE WARNING

    Trading in financial markets carries a substantial level of risk, and there is a potential for the complete loss of your invested capital. It is important to understand that when engaging in margin trading or utilizing leverage, your losses can surpass your initial investment, and you may be required to deposit additional funds to maintain your position. Leverage has the capacity to magnify both profits and losses, and as such, it may not be suitable for all investors.

     

    Leverage, or margin trading, involves borrowing funds for trading, which can significantly amplify potential gains and losses. Swift and substantial losses that exceed your original investment are conceivable, and it is crucial to carefully evaluate your investment objectives, risk tolerance, and financial situation before venturing into leveraged products or margin trading.

    Leverage is typically represented as a ratio (e.g., 10:1 or 100:1), indicating how much of the underlying asset you can control with each dollar you deposit. While leverage can enhance the potential for profits, it also heightens the potential for losses. Even a minor market fluctuation can lead to significant gains or losses when leverage is employed. Leverage allows you to initiate trades with a larger nominal value than the funds at your disposal, utilizing a smaller margin to commence the trade. However, lower margin requirements are also associated with a heightened potential for losses should the market move unfavorably. Nonetheless, we provide negative balance protection to ensure that clients cannot lose more than their initial investment.

    In addition to leverage-related risks, it is crucial to consider the risks associated with the underlying asset or security being traded. These may include market risks, credit risks, and liquidity risks, which can vary depending on the specific asset or security under consideration.

    Our trading platform offers access to leveraged products and margin trading, and we furnish educational resources and tools to augment your comprehension of the associated risks. However, it is imperative to acknowledge that trading in financial markets inherently entails risks, and you should only invest funds that you can afford to lose.

    By utilizing our trading platform, you acknowledge that you have read and comprehend this risk statement, and you willingly assume the risks linked to trading in financial markets. Should you have any inquiries or concerns about the risks associated with our products or services, please do not hesitate to contact us using the provided contact information in this policy.

     

    5.    IT RISK DISCLOSURE

    Our company heavily relies on cutting-edge technology to facilitate access to financial markets and execute trades efficiently. However, we are acutely aware of the inherent technical risks that come with utilizing any online system. These risks encompass a spectrum of possibilities, including system failures that could lead to delays or failed trade executions, technical glitches potentially causing pricing inaccuracies and other errors, cyber-attacks or security breaches, and interruptions in our trading activities, among others.

    To proactively address these technical risks, we have instituted a comprehensive array of measures. These initiatives encompass  substantial  investments  in  robust  and  redundant  technology  systems, the implementation  of  stringent  cybersecurity  protocols, regular  testing  and  vigilant  monitoring  of  our technology infrastructure, and the development of contingency plans geared towards ensuring business continuity and disaster recovery. We are committed to keeping our software and hardware up -to-date and ensuring our staff is well-trained in using our technology systems while adhering to cybersecurity best practices. Additionally, we collaborate with reputable technology vendors and service providers to enhance the security and reliability of our operations.

     

    While we take these technical risks with the utmost seriousness and have established measures to mitigate them, it is important to recognize that complete elimination of these risks is unattainable. By choosing to use our  platform, you acknowledge  and consent  to  the  presence  of these  inherent  technical  risks, understanding that we cannot guarantee uninterrupted or entirely error-free operation of our platform and services.

    Should you have any inquiries or concerns regarding the technical risks associated with our platform or services, we invite you to reach out to us using the contact information provided in this policy. Your satisfaction and safety remain our foremost priorities, and we remain steadfast in our commitment to providing you with exceptional trading experience while effectively managing potential technical risks.

     

    6.    COMMUNICATION RISK

    Communication with our company, whether through emails or telephone conversations, may be susceptible to interception, loss, or delays. Despite our best efforts to implement reasonable safeguards, we cannot provide an absolute guarantee of the security or confidentiality of such communications. Consequently, our firm will  not  assume  liability  for  any  damages  resulting  from  the  interception, loss, or  delay  of communications.

    It is important to be aware that any electronic communication sent to our firm, including emails and their attachments, may be subject to monitoring and retention for regulatory compliance purposes. In the interest of your own security, we kindly request that you avoid sharing sensitive personal or financial information in any correspondence with us. If you suspect any unauthorized access to your communications with our firm, please notify us promptly.

    We prioritize  your  privacy  and  security  and  are  committed  to  fostering  a  secure  communication environment. Should you have any questions or concerns regarding the risks associated with communicating with our firm, please do not hesitate to contact us using the information provided in this disclosure. We are readily available to address your inquiries and offer the necessary support.

     

    7.    LIQUIDITY RISK

    Liquidity risk is a significant concern for our company, as it refers to the potential inability to meet our financial commitments to clients or counterparties due to a lack of available funds or easily convertible assets.

    We are aware that liquidity risk can emerge from various factors, including sudden shifts in demand for specific currencies or financial instruments, a reduced number of market participants willing to provide liquidity, or unexpected market events causing price fluctuations and increased volatility.

     

    To address liquidity risk, we adopt several key measures, including:

    • Maintaining Adequate Liquidity Buffers: We ensure that we have sufficient funds set aside as liquidity buffers to meet our financial obligations promptly. These reserves serve as a safeguard against unforeseen liquidity demands.
    • Diversifying Client and Counterparty Base: We strategically diversify our client and counterparty base to minimize concentration risk. By doing so, we reduce the impact of potential defaults from any single entity.
    • Monitoring and Regular Review: Our risk management policies are continually monitored and reviewed to ensure their effectiveness. This proactive approach enables us to adapt swiftly to changing market conditions.
    • Establishing Credit Lines: We establish credit lines with reputable financial institutions, allowing us to access additional funding when needed. These credit facilities act as an added layer of security.

     

    By implementing these measures, we aim to mitigate liquidity risk and uphold our commitment to fulfilling our financial obligations to clients and counterparties with utmost reliability and stability. We are dedicated to safeguarding the interests of our clients and maintaining the trust they place in us.

     

    8.    TRADING PLATFORM / TERMINAL RISK

    Trading in financial markets using our trading platform/terminal introduces you to a range of inherent risks that require your careful consideration. These risks encompass market volatility, execution uncertainties, technical vulnerabilities, and more. By choosing to utilize our trading platform/terminal, you acknowledge and embrace these risks, recognizing that we cannot guarantee uninterrupted or entirely error-free service.

    Understanding that financial market trading inherently carries risks, it is imperative that you conduct a thorough evaluation of your investment objectives, risk tolerance, and financial situation before engaging in trading activities. Equally crucial is acquiring a sound comprehension of the specific markets you intend to trade in and becoming familiar with the functionality and operation of our trading platform/terminal.

    We strongly advocate for a cautious approach and recommend seeking professional guidance when necessary, before making any trading decisions. Our dedicated team is here to offer support and address any questions or concerns you may have regarding the risks associated with trading on our platform/terminal. Please feel free to reach out to us using the contact information provided in this disclosure.

    Your safety and prosperity as a trader are paramount to us, and our commitment is unwavering when it comes to equipping you with the essential information and assistance to navigate the challenges inherent in trading financial markets via our platform/terminal.

     

    9.    COMMISION & TAX RISK

    Before you begin trading, it is essential to have a comprehensive understanding of all the commissions and charges associated with your trades. Some fees may be presented as a percentage of the contract value, rather than a specific monetary value, so it is crucial to grasp the actual cost in monetary terms.

    Additionally, be aware  that  your  trades, including  those  involving  derivatives  and  other  financial instruments, may be subject to taxes or duties due to changes in legislation or your individual circumstances. While our Company cannot guarantee that no taxes or duties will be owed, we want to emphasize that it is your responsibility to fulfill any tax or duty obligations that may arise from your trades.

    Furthermore, it is your responsibility to manage your own tax and legal obligations, which may include making regulatory filings and payments, as well as adhering to relevant laws and regulations. Please be advised that our company does not provide tax, legal, or regulatory advice. For your peace of mind, we strongly recommend that you seek independent advice from qualified professionals if you have any doubts or concerns about the tax treatment or liabilities associated with any investment products offered by us.

    At our Company, we prioritize transparency and believe that informed traders are more equipped to make sound decisions. Therefore, we encourage you to familiarize yourself with all the costs, taxes, and legal responsibilities related to your trading activities. If you have any questions or uncertainties, do not hesitate to seek advice from professionals who can guide you based on your specific circumstances