COMPLIANCE

EXANTE strictly adheres to international sanctions, particularly regarding the Russia-Ukraine conflict. We've formalised policies addressing AML/CTF and European sanctions, ceased onboarding new clients from Russia and Belarus, and made humanitarian donations. Stay updated on our website for changes to our stance and policies.

At EXANTE, we are committed to complying with all regulatory requirements, especially those related to sanctioned regions, to minimise the effects on our clients.

We monitor international sanctions irrespective of whether there is a direct impact on our operations. The following measures have been implemented in response to sanctions related to the conflict between Russia and Ukraine.

Formal Policies

On the 1st of February, 2021, according to the Central Bank of the Russian Federation, EXT Ltd (operating under the brand name EXANTE through the website exante.eu) was added to the list of companies with identified signs of illegal activities in the financial market due to the fact that it has signs of an illegal professional participant in the securities market, as per the local laws and regulations.

The inclusion of the Company to the Central Bank of Russia’s (hereinafter, the “CBR”) warning list was done in error, since the Company does not have any activity in the Russian Federation. The Company has been trying to contact CBR for almost two years now regarding its removal from this list. The attempts included multiple letters from EXT and EXT’s attorneys, explaining the EXT has never been present in Russia, advertising or targeting Russian Federation clients and providing supportive evidence. The War in the Ukraine and the subsequent Sanctions imposed on the CBR further complicated the attempts to resolve this issue and the CBR stopped responding to EXT all together.

 It is important to note that the inclusion of the Company on the CBR’s warning list does not imply any penalties or prohibitions of the business activities of companies included in the list.

The main aim of the list, as has been advised by the CBR, is of an informative nature addressed solely to the citizens of the Russian Federation for the purpose of informing them about possible risks involved in cooperation with companies that are not supervised directly by the CBR. In this respect, the purpose of the list is to alert Russian citizens that, if a Russian citizen engages with a foreign company, such citizen loses the protection granted to him/her by Russian regulatory authorities as foreign companies are subject to their local regulations. As a consequence, this also means that, in case of any dispute, the Russian citizen would be required to file a complaint with the foreign firm’s regulatory authority. Therefore, the warning list does not implicate any legal risks but it does have a reputational impact.

Our compliance department has formal policies to address sanctions, anti-money laundering and counter-terrorist financing (AML/CTF).

Additionally, we adhere to the latest sanctions packages implemented by the Council of Europe internally, swiftly adapting policies where necessary and based on (but not limited to) the following legal acts:

Council Regulation (EU) 2023/426; Council Regulation (EU) 2023/427; Council Implementing Regulation (EU) 2023/428; Council Implementing Regulation (EU) 2023/429; Council Implementing Regulation (EU) 2023/430; Council Decision (CFSP) 2023/431; Council Decision (CFSP) 2023/432; Council Decision (CFSP) 2023/433; and Council Decision (CFSP) 2023/434.

Policy Update: Russian & Belarussian Clients

As of 1 March 2022, EXANTE has ceased onboarding new clients residing in the Russian Federation or Belarus. Deposits and securities transfers from existing clients residing in these jurisdictions were simultaneously blocked.

Please see the formal disclaimer on our official website for more information.

UNICEF Donation

In April of 2022, EXANTE donated $1 million in support of UNICEF**’s emergency response efforts related to the ongoing war. The funds were given to support vulnerable families impacted by the war and those forced to flee to neighbouring countries. 

**Please note that UNICEF does not endorse any company, brand, product or service.

Disclaimer: EXANTE’s stance on Russian sanctions is subject to change based on adjustments initiated by regulatory authorities and the subsequent introduction of new legal acts. 

Please bookmark this page and return here for future updates on our stance and internal policies.

EXT LTD is licensed by CySEC (Cyprus). With regular audits, active regulatory engagements, and no proprietary trading, we prioritise client trust and transparency.

To deliver the best services to our clients, the EXANTE team is committed to compliance. We've implemented the following practices to set a standard for excellence in the financial sector.

Licence

EXT LTD is licensed by the CySEC, or Cyprus Securities and Exchange Commission, is Cyprus's lead financial services regulator. Established in 2001, it safeguards investor interests, ensures market transparency, and maintains the integrity of the local financial industry. CySEC enforces compliance with European Union financial regulations, making it a crucial entity in the region's financial ecosystem.

EXANTE is subject to regular checks by each of these regulatory authorities. We have passed all of these since entering the market in 2011. 

Audits

Like any other business, trading platform providers undergo regular audits to ensure long-term credibility and success in the market.

EXANTE is audited yearly by the world's largest international accounting and professional services firms, and undergoes compliance audits by local regulators.

This ensures financial transparency, accountability, regulation compliance, and investor and stakeholder confidence. 

Clients from US and compliance with SEC Regulation

The SEC, or the US Securities and Exchange Commission, is a regulatory agency maintaining the integrity of the securities industry in the United States. Established in 1934, it ensures fair and transparent markets nationwide.

The SEC regulates various entity types. Its primary jurisdiction covers publicly traded companies, including corporations and investment funds, whose securities are bought and sold by the general public. It also oversees brokers, dealers, and other market participants, ensuring they adhere to market fairness and transparency rules. 

Due to organisational structure variations, some companies are not subject to SEC regulation. Smaller businesses may, for instance, be exempt from SEC oversight if they do not meet specific size or reporting thresholds.

EXANTE is not regulated by the SEC, as it does not offer trading accounts to US-based professional traders and institutions. This is subject to change depending on market entry in the future or subject to potential updated requirements by the commission.

Additional Interactions with Regulators

At EXANTE, we go a few steps further to facilitate healthy interactions with regulatory bodies. These include:

• Participation in regulatory workshops and seminars: Our team is always open to attending these to remain abreast of compliance requirements, best practices, and notable changes.
• Regular Consultations: When regulators hold meetings with representatives from various financial companies, EXANTE insists on having a seat at the table to share industry challenges, emerging risks, and regulatory concerns. 
• Whistleblower Programs: EXANTE works with regulators to implement a robust whistleblower program for employees to report misconduct or regulatory violations. 
• Advisory Panels: Our team encourages the establishment of advisory panels composed of industry experts who provide input on regulatory proposals and reforms. This collaborative approach ensures balanced, well-informed regulations, factoring in multiple perspectives. 

Stance on Proprietary Trading

EXANTE does not engage in proprietary trading and does not manage client funds directly. We operate solely as an impartial platform for third-party traders to execute their strategies. 

We maintain a strict policy of non-interference in clients' trading positions, abstaining from offering advisory services on holdings. 

Coupled with the efforts mentioned earlier, this underscores our commitment to transparency, integrity, and adherence to regulatory standards in the financial industry.

EXANTE enforces strict financial crime policies, including KYC, CDD, and sanctions monitoring. We prioritise transparency, ensuring ethical trading and safeguarding against financial misconduct.

At EXANTE, we maintain high standards in financial crime compliance. We manage the risk, prevent potential regulatory breaches and ensure we never unwittingly support any relationships or transactions involved in financial crime. 

Transparency is paramount to our operations. We work closely with the regulatory authorities to align with applicable local guidelines and requirements. We understand our duty to prevent our trading platform from being used to launder illegal funds, finance terrorism, or violate any international sanctions.

EXANTE implements strict measures to mitigate exposure to these activities, applying AML/CTF and Sanctions compliance standards and procedures to prevent misuse of our services.

Formal Measures

To safeguard against illegal activities, we have adopted a robust policy, including the following protocols, being an integral part of our risk management system:

• Customer Due Diligence (CDD): We identify and verify our customers' identities by using reliable documents and information from trustworthy and independent sources.
• Know-Your-Customer (KYC) Practices: We strongly emphasise client relationships, thoroughly understand their financial activities, and are well-informed about the origin of the exchanged funds.
• Ownership and Control: We take steps to gain sufficient knowledge of the ownership and control structure of our clients.
• Politically Exposed Persons (PEPs) Authentication: We require authorisation from a designated decision-maker before initiating and continuing business relationships with politically exposed persons (PEPs). The same applies to their family members and related contacts, who are also at a greater risk of being targeted for financial crime.
• Daily Screening: We conduct daily screenings of our client base against financial sanctions, negative media information and PEP lists. All payments are screened in real time to ensure compliance with international sanctions.
• Suspicious Activity Reporting: We have an established process for reporting suspicious transactions, including a direct reporting line to an in-house Money Laundering Reporting Compliance Officer (MLRO).
• Sanctions Monitoring: We use technology to monitor transactions that may infringe upon the US OFAC, UK, UN, and EU Sanctions Regimes, as well as stay on top of the local and international sanctions updates. We also screen for sanctioned instruments to act promptly and remove them from the platform.

EXANTE takes its commitment to financial crime compliance seriously. Our policies and practices aim to protect the interests of our client, our business, and the global financial system.

Thank you for being a part of our mission to ensure ethical and responsible financial practices.