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Authorised and Regulated

Caxton FX Ltd is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 ('FSMA') as well as the Payment Services Regulations 2017 ('PSR'). Read below for details on what this means for you.

Financial regulations; security of your funds

As part of our permissions, we offer clients who use our services the protection of the FCA's client money rules. Click here to view our permissions.

How does it work?

Caxton FX offers "Client Money protection" on all currencies that we exchange. If you send money to us prior to a transaction taking place and if we hold money for you after an FX transaction has been completed or if we are holding money for you with respect to designated investment business as defined by the rules of the FCA, then we hold your funds under "Client Money protection".

Is my money safe?

Caxton FX holds all "Client Money" to the standard set out in the Financial Conduct Authority's Client Money rules. This means we segregate "Client Money" from the company's money and hold it separately in an EEA-regulated credit institution. The credit institution has specifically acknowledged that the money in these accounts belongs to our clients and they have no right of set-off with any of the firm's balances. This arrangement is designed to ensure that "Client Money" is not at risk in the unlikely event of Caxton FX getting into financial difficulties. These arrangements are checked and verified by our auditors.

Client Money has the specific definition of "money of any currency which, in the course of carrying on designated investment business, a firm holds in respect of any investment agreement entered into, with or for a client, or which a firm treats as client money in accordance with the client money rules." It is important to note that spot and forward foreign exchange transactions are not regulated activities. This means that, during the actual settlement process for your FX transaction, your funds are not held in segregated Client Money accounts and is not deemed to be Client Money at that time.

Financial Services Compensation Scheme

In respect of designated investment business only (see above), client money held by Caxton FX is also covered by the Financial Services Compensation Scheme (FSCS). For clarity, designated investment business does not include spot or forward FX transactions but does include currency options. Private investors, as defined by the FCA (which includes small companies), are covered by the scheme up to a limit of £50,000 per person per firm. For clarification, neither Foreign Exchange nor Payment Services are regulated investment products and so do not fall under the FSCS. Further details of the compensation scheme are available from the FSCS website www.fscs.org.uk.

If you need further clarification on this matter, please refer to our account management team on 0207 042 7629 or e-mail them on [email protected]

Money laundering

Caxton FX is fully committed to protecting the integrity of its transfer system - find here our strict Anti-Money Laundering policy.

What am I asked to do?

When you apply for any Caxton FX product, you will be asked to confirm your identity and other personal details. Caxton FX has established special verification systems to confirm your identity.

When?

You will be asked to confirm your identity whether you are applying to be a new customer. If you have been a customer for some time we may also ask you to confirm your identity on a periodic basis. While our identity verification systems are designed to minimise any inconvenience for you, the verification process may take a day or two to complete.

Why?

Crime and terrorism need cash. Criminals turn the 'dirty' money made from drug smuggling, trafficking and other organised crime into apparently clean money by using false identities or taking the names of innocent people - like you. Making sure that people are who they say they are is essential in the fight against crime and terrorism. This does not mean in any way that suspicion is falling on you. Any information about your identity is held confidentially and will help stop your identity being used falsely.

Who is involved?

HM Government and all organisations involved in financial services - all are united in their determination to stop the spread of financial crime as part of the international effort to protect us all against crime and terrorism.

Your co-operation is vital to the successful fight against crime and terrorism.

What the UK law requires

  • We are required to verify your identity and address.
  • We are required to keep full records of all transactions together with the identification provided.
  • We are required to monitor your account for any unusual or suspicious transactions.
  • We have a legal obligation to report to the UK National Crime Agency (NCA) any suspicious or potentially suspicious transaction.

Payment Services and E-Money Regulations

The new Payment Services Regulations ('PSRs') came into effect on 13th January 2018. These regulations build on an earlier version and are part of a Europe-wide directive that aims to harmonise the way that payments are made across the EEA, making them faster, easier and more transparent for the customer.

The regulating body in the UK is the Financial Conduct Authority (FCA). The PSRs require companies that offer "payment services" (ie transfer money for you) be either registered or authorised by the FCA.

All firms authorised under these regulations are required to abide by the Conduct of Business rules (COBs) which determine how companies may conduct their business with customers.

Authorised Payment Institutions and E-money Institutions must meet initial and ongoing requirements for maintaining certain levels of capital within their business and must comply with arrangements to safeguard their customer funds. They will also have to meet stringent criteria set by the FCA in terms of corporate governance, solvency and risk identification and management.

Caxton FX Ltd is regulated and authorised for the provision of payment services and E-money under number 900663. For a full list of our permissions please visit the FCA's website here: www.fca.gov.uk

Caxton FX Ltd is registered with HM Revenue and Customs as a Money Service Business registration number 12149429.

In addition to the above Caxton FX Limited is also authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000. The FCA authorisation number is 431844.

Caxton FX Ltd - Authorised and Regulated by the Financial Conduct Authority. Registered in England and Wales. Registered Office: Portland House, Bressenden Place, London SW1E 5BH.

The information below sets out the classes of business that Caxton FX is authorised to undertake.

Client Money

  • This firm must protect the money it holds and/or controls on behalf of customers. It cannot lend this money or use it to finance its own business.

Advising on investments (except on Pension Transfers and Pension Opt Outs)

  • Customer Type
    • Retail (Non-Investment Insurance)
  • Investment Type
    • Non-investment insurance contracts

Advising on investments (except on Pension Transfers and Pension Opt Outs)

  • Customer Type
    • Professional
    • Retail (Investment)
  • Investment Type
    • Future (excluding a commodity future and a rolling spot forex contract)
    • Option (excluding a commodity option and an option on a commodity future)
    • Rolling spot forex contract
  • Limitation
    • Rights to or interests in (both).

Advising on P2P agreements

  • Customer Type
    • Professional
    • Retail (Investment)

Agreeing to carry on a regulated activity

  • Limitation
    • Limited to carry on regulated activity.

Arranging (bringing about) deals in investments

  • Customer Type

Retail (Non-Investment Insurance)

  • Investment Type
    • Non-investment insurance contracts

Dealing in investments as agent

  • Customer Type
    • Retail (Non-Investment Insurance)
  • Investment Type
    • Non-investment insurance contracts

Dealing in investments as agent

  • Customer Type
    • Professional
    • Retail (Investment)
  • Investment Type
    • Future (excluding a commodity future and a rolling spot forex contract)
    • Option (excluding a commodity option and an option on a commodity future)
    • Rolling spot forex contract
  • Limitation
    • Rights to or interests in (both).

Dealing in investments as agent

  • Customer Type
    • Professional
    • Retail (Investment)
  • Investment Type
    • Future (excluding a commodity future and a rolling spot forex contract)
    • Option (excluding a commodity option and an option on a commodity future)
    • Rolling spot forex contract
  • Limitation
    • Rights to or interests in (both).

Making arrangements with a view to transactions in investments

  • Customer Type
    • Retail (Non-Investment Insurance)
  • Investment Type
    • Non-investment insurance contracts

Making arrangements with a view to transactions in investments

  • Customer Type
    • Professional
    • Retail (Investment)
  • Investment Type
    • Future (excluding a commodity future and a rolling spot forex contract)
    • Option (excluding a commodity option and an option on a commodity future)
    • Rolling spot forex contract
  • Limitation
    • Rights to or interests in (both).

Safeguarding and administration of assets (without arranging)

  • Customer Type
    • Professional
    • Retail (Investment)
  • Investment Type
    • Future (excluding a commodity future and a rolling spot forex contract)
    • Option (excluding a commodity option and an option on a commodity future)
    • Rolling spot forex contract
  • Limitation
    • Rights to or interests in (both).

Introduction

Caxton FX Limited (Caxton FX) is authorized and regulated by the Financial Conduct Authority.

This policy statement is issued in accordance with section 54 (1) of the UK Modern Slavery Act 2015 and relates to our financial year ending 28th February 2017

This policy document sets out Caxton FX approach to the prevention and detection of slavery and human trafficking and the controls that are applied across the business.

Company structure

For over 16 years Caxton FX has provided innovative FX services for both corporate and private clients in the UK and overseas from its offices in London and Swindon. The current product suite consists of prepaid currency cards, international payments and more complex FX products including forwards and options. All of our services are provided directly to the client. Caxton FX does not operate through an agent network.

Policy

Caxton FX maintains a zero-tolerance approach to slavery, human trafficking, forced labour and exploitation. We recognize the human costs of these offences and we are committed to ensuring that our business does not in any way support or encourage such activities, by acting ethically, at all times. 

Caxton’s approach to the prevention and detection of slavery and human trafficking has been integrated within our current policies and business procedures, listed below:

  • Our procurement approach
  • Anti-Money Laundering Policy
  • Anti-bribery and Corruption Policy
  • Staff code of conduct

Caxton FX promotes a culture of transparency, whilst acting ethically and upholding the rules and regulations relevant to the business. All staff receive training in the areas outlined above including, where appropriate, training in how to identify potentially suspicious activity that may be indicative of modern slavery. Caxton FX has a relatively limited risk appetite and chooses not to do business with a number of higher risk sectors and countries.

Our staff are recruited on salaries that are above the national minimum wage in what is a highly competitive market for the best talent. All recruitment is undertaken by our in-house recruitment team. All candidates offered a role have to prove they are eligible to work in the UK.

Caxton FX undertakes due diligence on key suppliers. In the majority of cases, for reasons of location, industry sector and the nature of our business, the modern slavery risks within our supply chain are felt to be relatively low.

All staff have access to a Whistleblowing procedure where they can raise any concerns about internal conduct in a confidential manner where they will be thoroughly investigated. All employees have unrestricted access to the People Team at all times and will be treated fairly and impartially.

All staff, including temporary contractors, must complete the Caxton AML training which provides indicators of how to identify Modern Slavery. The training must be repeated for all employees on an annual basis and updated when the legislation or processes change. This training requires all staff to report any suspicions to the Money Laundering Reporting Officer who will investigate the matter and report to the most suitable regulatory authority as appropriate. 

Our Future Plans

Whilst we believe that we have suitable policies and procedures in place to mitigate the risk that Caxton FX may inadvertently be linked to modern slavery, we will keep them under constant review. Our plans for the next financial year include:

  • Undertaking a review of training materials to ensure there is appropriate coverage of modern slavery and how to identify it.
  • Updating the procurement process to ensure that all suppliers are made aware of our commitment to preventing modern slavery and are able to confirm that their business is not linked to modern slavery in any way.
  • Considering the modern slavery risks as a key factor when undertaking our assessment of the countries where we will permit payments to be made.

This policy and our plans will be reviewed at least annually. Any amendments required will be signed off by the Caxton FX Board of Directors prior to publication.

Any queries should be addressed to [email protected]

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