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Terms & Conditions

These Terms & Conditions (hereinafter referred to as the “Agreement”) shall regulate the relations between Glass Cube Ltd., under registration number 23840 IBC2017, registered at Suite 305, Griffith Corporate Centre, Kingstown, 1510, SAINT VINCENT AND THE GRENADINES, hereinafter referred to as the “Company”, and the User (a physical entity) (hereinafter referred to as the “Client”) of www.bnroptions.com (hereinafter referred to as the “Website”).

1.Terms
  1. Service – services described in section 3 of this Agreement.
  2. Operation – action performed at the Client’s Account, connected with but not limited to crediting of funds, return of funds, opening and closing of trade transaction.
  3. Account – unique personified register of accounting of transactions/operations on the trade platform of the Company.
2.Subject of the Agreement
  1. The subject of the Agreement herein shall be provision of services to the Client by the Company based on the Agreement herein. For avoidance of any doubt, the Agreement herein is not concluded in any country other than Saint Vincent and Grenadines. The present Agreement is concluded in the Saint Vincent and Grenadines.
  2. The Client shall unambiguously admit terms and conditions of the Agreement herein by making an advance payment to the Account. Each operation performed by the Client on the trade platform shall become the subject of the Agreement herein and other documentation/information on the Website since the Client’s acceptance of conditions of the Agreement.
  3. Notes for Clients from the Russian Federation.
  1. For avoidance of any doubt, the Agreement herein is not concluded in the Russian Federation. The present Agreement is concluded in the Saint Vincent and Grenadines.
  2. Notwithstanding that provisions of the Agreement herein shall be subject to laws of the Saint Vincent and Grenadines regulation and for avoidance of any doubt, the Service provided to the Client by the Company shall not be the forex-dealer activity, how it is defined in clause 4.1 of the Federal law of the Russian Federation “About the security market” No. 39-FZ dated 22.04.1996. In accordance with the terms of the Agreement herein, within the fulfillment of the Agreement herein by the Client, the Client under no circumstances could undertake the obligations the amount of which is more than the amount of furnish collateral provided by the Client to the Company (the Client’s money on the account of the Client). The parties affirm that the Agreement herein is not set up in the legislation of the Russian Federation without prejudice to the right of conclusion of the Agreement herein by the parties in accordance with the clause 2 of article 421 of Russian Federation Civil code and provisions of the Agreement herein shall be regulated by section 8 of the Agreement herein.
  3. Notwithstanding that provisions of the Agreement herein shall be subject to laws of the Saint Vincent and Grenadines regulation and for avoidance of any doubt, the Service provided to the Client by the Company shall not be considered as gambling and not be considered as wagering according to the definitions given in the Federal law dated 29.12.2006 No. 244-FZ “About state regulation of activity regarding organization and fulfillment of gambling and implementation of changes in some legal acts of the Russian Federation”.
3. Services of the Company
  1. Services of the Company – services provided by means of trade platform of the Company.
  2. Services of the Company comprise use of trading platform of the Company, customer support, analytics, the news and marketing information.
  3. The Company shall fulfill trade operations of the Client and the Company does not provide trust services and consultations on trading. The Company can conduct trading operations of the Client even in case such trading operation may be unprofitable for the Client.
  4. The Client guarantees that all provisions of the Agreement herein, as well as conditions of the Privacy Policy and Anti-Money Laundering Policy (and any other additions and annexes herein) published on the Website were carefully read and accepted by the Client, for these terms define all conditions of Client-Company interaction.
  5. The Company shall not be financially liable for the results of the Operations conducted by the Client.
  6. The Client is the only authorized user of the Company’s services. The Client is irreplaceable subject of legal relations emerging from the provisions of the Agreement herein. Client's rights cannot be delegated, and obligations cannot be imposed on another person.
  7. In case the Client is a private person, the Client personally fulfilled the registration form and is an adult, legally capable citizen, not resident or citizen of the following countries: USA, Israel, Palestine, Japan, Sudan, Syria, Iran, North Korea. No person but the Client has rights of claim or obligations regarding Operations conducted by the Client on the Website. If the Client acts on behalf of somebody’s name, the Company shall not accept this person as a Client and shall not be liable before this person regardless if such person was identified or not.
  8. It is understood and agreed by the Client that the Company may from time to time and at its discretion, utilize a third party to hold its client funds, for the purpose of offering additional PSPs. These funds will be held in segregated accounts from the Third Party’s own funds and will not affect the rights of the Client to their funds.
4.Rights, Obligations and Guarantees of the Parties
  1. The Client shall be entitled to:
  1. Give the Company an order to conduct trading Operations on the Website, provided by the Agreement herein;
  2. In case of absence of debt to the Company, to demand the Company to fulfill its financial obligations to the extent of free amount of funds at the Company’s Account;
  3. In case a disputable situation occurs, to make a claim properly in official letter or via e-mail to account specified by the Company;
  4. Unilaterally Terminate the Agreement herein in case no debt to the Company exists.
  1. The Client shall be obliged to:
  1. Fulfill provisions of the Agreement herein conducting Operations on the Website;
  2. To be exclusively responsible for all actions resulted from usage of usernames and/or passwords;
  3. To be exclusively responsible for all his/her actions, including giving orders to conduct Operations on the Website;
  4. To be exclusively responsible for correct trading strategy choice and consideration of all possible risks;
  5. To be completely responsible for preserving confidentiality of information received from the Company and to accept risk of financial loss that may result from unauthorized access to his/her own Account by the third parties.
  6. To notify the Company of any changes of contact details and any other changes of the provided personal data within 7 (seven) calendar days since such changes come into effect.
  7. To register only 1 (one) Account in the Company. In case that the Client owns multiple accounts, the transaction and the financial results of such transactions in these accounts can be canceled. All such accounts can be blocked, and funds contained therein will not be considered as financial obligation of the Company before the Client.
  8. To indemnify and hold harmless of the Company due to any claims and legal actions regarding the Company as a result of disclosure of personal data of the Client.
  9. The Client shall be agree to accept the complete responsibility for his actions according to current tax legislation valid at the place of residence/living of the Client regarding any performed operations, including but not limited to revenue tax.
  1. The Client shall guarantee:
  1. To comply with legal rules of the jurisdiction where the Client lives;
  2. To be legally capable and a person of majority age;
  3. That the Client is not a US citizen, citizen of Israel, Palestine, Japan, Sudan, Syria, Iran, North Korea;
  4. That the Client is solely responsible for the technical deficiencies in Client’s connection to the trading platform, deficiencies in Client's equipment used for receiving the services (including, but not limited to, personal computer, laptop, mobile phone, etc.) and hold harmless and indemnifies the Company against any Client’s loss and damages derived from such deficiencies.
  1. The Company shall be entitled to:
  1. Modify the amount of the Company’s financial obligations to the Client with changes of the appropriate entry of the trade operations register in case of violation of one or several provisions of the Agreement herein by the Client;
  2. Terminate the Client’s service at any time with any reasonable grounds (preliminary notification of the Client regarding this shall not be obligatory);
  3. Unilaterally in the extrajudicial procedure terminate the Agreement herein without reimbursement of any loss suffered by the Client. In such case the Company shall notify the Client within 3 (three) working days after such termination in any possible way;
  4. Сhange, add or set as default the option payments rate, return rate, the possibility of adjustment the return rate, the possibility of acquiring the option type, the minimum and/or the maximum option amount, possible expiration periods for one, several or all of assets. The company shall be entitled to limit the maximum amount of purchased options for 1 (one) minute, 1 (one) hour, 1 (one) calendar day;
  5. Contact the Client with any question concerning the Agreement herein, in order to make certain the Client's intentions regarding his/her actions on the Account;
  6. Modify, to add, to rename or to leave unchanged any sections, paragraphs and sub-paragraphs of the Agreement herein without preliminary notification of the Client regarding such changes;
  7. Modify the amount of the Company’s financial obligations to the Client, if fulfillment of Operations on the trading platform does not comply with conditions of the Agreement herein;
  8. Engage the third parties with contractual relations for Service provision in accordance with the Agreement herein;
  9. Unilaterally terminate the Agreement herein with preliminary notification of the Client regarding such termination and fulfillment of financial obligations before the Client to the extent of the amount of free funds available at the Account;
  10. In regards to any obligations and situations not covered by the Agreement provisions herein the Company has a right to act at its own discretion in accordance to business customs and existing practice.
  1. Obligations of the Company:
  1. In accordance to the Agreement provisions herein, provide Services on the Company’s Website;
  2. In accordance to the Agreement provisions herein, in case of no debt on the part of the Client exist, fulfill the Company’s financial obligations on the Client's request by transferring the free funds from Trading Account to Client’s banking account or other financial account;
  3. Fulfill provisions of the Agreement herein.
  1. Deposit requirements

On every deposits we will ask our traders to send us for the following documents in order to validate your account, within fourteen days.

  1. Proof of Identification. A color copy of a valid passport, driver's license or identity card. The document must be valid and contain customer’s full name. (This action is done only after the first account top up)
  2. Utility bill: A recent utility bill (electricity, landline phone, water, gas) or bank statement dated within the last 3 months, confirming your registered address. Ensure that your name, address, issue date and the name of the company issuing the bill/statement is clearly visible and in full page scan. *Make sure with every deposit, previously uploaded UB is still valid (not older than 3 months).
  3. A copy of the back & front sides of each credit card used to make deposits in the trading account(s). The name, expire date, last 4 digits and signature on the back must be clearly visible.
  4. Declaration of deposit has to include the exact name of the client (as in his ID), the details of the card used for a deposit (name of the cardholder, last 4 digits, expiration date, ), the amount of deposit with curency, exact date of deposit, and signature.
  5. You will need to send us this information for every card you use to make deposit

Payment cards per user: сardholder must always be the same as the person on the registered ID

5.Personal Data
  1. Accepting provisions of the Agreement herein, the Client grants his/her consent to process the personal data provided by the Client, both without use of automatic controls, and with its use. Under the personal data for the purposes of this Agreement the parties mean: Name, Surname and Patronymic, gender, address, phone number, e-mail, IP address of the Client and the information which concern the provision of services to the client (the trade story).
  2. The Client shall be obliged to provide truthful, exact and complete information according to the personal data about the Client requested by the Company.
  3. The purpose of processing the personal data shall be fulfillment of the regulating legislation requirements as well as obligations before the Client and other subjects of the personal data within the fulfillment of the Agreement herein.
  4. During processing of the personal data the Company shall be entitled to collect, record, systematize, accumulate, store, adjust (update, change), extract, use, transfer (disseminate, provide, access), anonymize, block, delete, destroy and perform any other actions according to the current regulating legislation.
  5. Storage and processing of the personal data of the Client can be fulfilled by the Company during the term of the Agreement, as well as within 5 years after termination of the Agreement herein.
  6. The Client shall admit and confirm that in case the need to provide the Personal data to fulfill the purposes of the Agreement to the third party as well as in case of engaging of the third parties to render services for the specified purposes, the Company shall be entitled to disclose the information about the Client in the necessary amount to fulfill the actions mentioned above, including the Personal data to such third parties, their authorized representatives as well as to provide documents for such persons which contain such information.
  7. The Company shall not be entitled to include the Personal data of the Client in the public information sources with the exception of cases provided by the regulating legislation.
  8. During processing of the Personal data of the Client the Company shall take necessary legal, organizational and technical measures to protect the Personal data from unauthorized or accidental access, destruction, change, blocking, copying, provision, and dissemination as well as from other illegal actions regarding the Personal data of the Client.
6.Risk Statement
  1. The Client has read, understood and accepted the risk statement due to use of Service on the Website, which is published on the Website of the Company.
7.Charges and Fees
  1. In case if none of the Operations (hereinafter referred to as “Inactive Account”) are fulfilled on the trade platform of the Company by the Client for 90 (ninety) calendar days in a row, the Company shall be entitled to apply the service fee for Inactive Account in the amount of 50 Euro to unused balance of the Client’s account. Such annual fee shall be not more than the total balance of the Client’s Account.
8.Regulating legislation
  1. The provisions of the Agreement herein shall be regulated by the legislation of the Saint Vincent and Grenadines.
  2. Regarding the provisions of the Agreement herein the Client shall agree with the jurisdiction of courts of the Saint Vincent and Grenadines.
  3. All disputable situations shall be resolved according to the laws of the Saint Vincent and Grenadines.
  4. The Company shall be entitled to use the interpreters’ services during the court trial in case of dealing with disputable situation according to the legislation of the Saint Vincent and Grenadines.
9.Term and Termination of the Agreement
  1. The Agreement herein shall be concluded for the uncertain term.
  2. The Agreement herein shall come into force when the Client makes an advanced payment to the Company. In case of any discrepancies between the text of the Agreement herein in Russian, German or English, the text of Agreement in English shall prevail in comparison with version of the Agreement herein and appropriate documents in other languages.
  3. The Agreement herein shall be terminated when the Client’s Account is blocked.
  4. The Company has a right to terminate the Agreement immediately without prior notice if it becomes known that the Client: а) is not of legal age according to the legislation of the country where the Client is the citizen or the resident; b) or the Client is the citizen or the resident of the following countries: USA, Israel, Palestine, Japan, Sudan, Syria, Iran, North Korea; 
  5. In case of termination of the Agreement herein due to reasons specified in section 9.4, the Company shall not be financially obliged to the Client.



Annex 1 to Terms and Conditions


Technical Regulation

1.Processing of Trade Requests and Orders
  1. Processing of Client requests and orders has the following structure:
  1. After any Client makes a request or an order, the request is tested for its correctness in the trading platform;
  2. The trading platform sends the request or order to the server;
  3. After the request or order is received by the server it is tested for correctness;
  4. The server, after processing of the order or the request, sends the results to the trading platform;
  5. In case that the connection between the trading platform and the server is correct, the trading platform will receive the results of processing of the request or the order by the Company.
  1. The time of the process may vary and depends on the quality of the communication between the trading platform and the server of the Company, as well as on the market conditions. In normal market conditions the time of the process usually varies between 0-4 seconds. In market conditions that differ from normal, the time of Client request and order processing can be higher than that.
  1. The server of the Company may refuse to the Client request in the following cases:
  1. If the client sends the request before the first quote in the trading platform on the market opening;
  2. If there is not enough funds on the Client’s account for opening a new position;
  3. If the Client sends the request before the opening of the trading session;
  4. When market conditions differ from normal.
  5. When using the trading platform, it is allowed to use only one tab of the browser. In case of using several tabs of the browser, the results of trade can be corrected and/or cancelled.
2.Quotes
  1. The client acknowledges that the only reliable source of quote flow information is the main server for Customer requests. The quotes on the trading platform cannot serve as a reliable source of information about the real quotes flow, as in the case of unstable connection between the trading platform and the server part of the quotes from the flow may not reach the trading platform.
  2. The graphs displayed on the trading platform are indicative. Thus, the Company does not guarantee that the transaction will be made at the same prices specified on the graph in the trading platform at the time of submission of the other Customer transactions.
  3. The price displayed on the trading platform is formed by the formula (Bid+Ask)/2
  4. Non-market quote – the price in the trading platform which does not correspond to the price on the market at this moment of time (hereinafter referred to as the “Non-market price”).
  5. In case if the Company fulfilled the Client’s request for Non-market quote, the following shall be imposed on the Company’s duty:
  1. In case of position closing – correction of the financial result between incorrect closing of the position and closing according to real market price corresponding to the closing moment of transaction according to Non-market price;
  2. In case of position opening – the Company reserves the right to cancel the financial result regarding such position.
3.Processing of Client Orders to Open Positions
  1. If the amount of available funds is sufficient to open a position - the position will be opened.
  2. If the size of the available funds is insufficient to open a position - the position will not be opened.
  3. The Client’s order to open a position is proceed, and the position is opened only after the corresponding entry in the server log file. Each new position is assigned with a serial number.
4.Processing of Client Orders to Close Positions
  1. Closing of trading position occurs at the current price at the trading server at the moment of closing of the trading operation.
5.OTC Assets
  1. OTC Asset or “over the counter” is an asset that traded out of the regular market (hereinafter referred to as the “Asset”).
  2. The Asset’s price is formed from data for trade requests and orders of the Clients, received by the Company.
  3. The Client acknowledges that by making trade requests and orders on such Asset, he/she understands the essence of the work of such an Asset and the pricing algorithm of the Asset.
  4. The Client acknowledges that by making trade requests and orders on such Asset, he/she admits that the only reliable source of quoting information is the main server for the trade orders of the Clients.
6.Fraud
  1. If the Company discovers fraud schemes such as:
  1. Fraud associated with credit card transactions and other ways to fill a balance that does not belong to the Client;
  2. Fraud associated with the use of software for false trading results;
  3. Fraud associated with errors and system failures for false trading results;
  • and in case of reasonable suspicion of the Company regarding the fraud schemes, mentioned above, the Company shall be entitled to block the Client's account without prior notice and without the possibility of further money withdrawal and/or entitled to unilaterally terminate the Agreement in the extrajudicial procedure.



Risk Disclosure

Privacy Policy

  • In order to get registered at www.bnroptions.com, the Client shall provide certain identifying details, including, inter alia, to prevent Money Laundering.
  • The Client shall provide true, accurate and updated information on his identity and shall not misrepresent himself to be another individual or legal entity. Any changes in the Client's identifying details shall be notified to the Company immediately and in any case no later than the 7th day from the date of such changes.
    • The Client's details that are provided and/or will be provided by the Client during his/her activity at www.bnroptions.com may be used by the Company for sending the Company's advertising content to the Client, unless the Client removes the mark approving the Company to do so. Such removal can be done when (i) opening an account or (ii) when receiving such advertising content or (iii) by logging in and going to My Account > Personal Details. The Client may also send to the Company, at any time, an e-mail to support@bnroptions.com asking the Company to cease from sending such advertising content. The aforesaid mark removal and/or e-mail receipt by the Company will oblige the Company to cease sending advertisement content to the Client within seven business days.
    • The Client's details that are provided and/or will be provided by the Client during his/her activity on the site may be disclosed by the Company to official authorities. The Company will make such disclosure only if required to be disclosed by the Company by applicable law, regulation or court order and to the minimum required extent.
    • Non-confidential information on the Client may be used by the Company in any advertising materials.
  • As a precondition for performing online transactions, the Client may be asked to provide certain identifying documents and any other documents required by the Company. If such documents are not provided, the Company can, at its sole discretion, freeze the Client's Account for any period of time as well as to permanently close the Account. Without prejudice to the above, the Company may, at its sole discretion, refuse to open an Account for any person or entity and for any reason, or for no reason.
  • The Company shall not divulge any private information of its Clients and former Clients unless the Client approved in writing such disclosure or unless such disclosure is required under applicable law or is required in order to verify the Client's identity. The Clients' information is passed only to employees of the Company dealing with Client's Accounts. All such information shall be stored on electronic and physical storage media according to applicable law.
  • The Client confirms and agrees that all or part of the information concerning the Client's Account and Transactions will be stored by the Company and may be used by the Company in case of dispute between the Client and the Company.
  • At its sole discretion, the Company may, but is not obliged, to review and inspect any information provided by the Client, for any purpose. It is manifestly stated, and by its signature hereunder the Client also agrees, that the Company holds neither commitment nor responsibility to the Client due to any aforesaid review or inspection of information.
  • The Company will take measures to implement advanced data protection procedures and to update them from time to time for purpose of safeguarding the Client's private information and Accounts.
  • Upon registration to www.bnroptions.com, the Client will be asked to choose a username and password to be used by the Client on each future login and for the performance of Transactions and use of the Company's Services. In order to protect the Client's privacy and operation with www.bnroptions.com, sharing registration details (including without limitation, username and password) by the Client with other persons or business entities is strictly prohibited. The Company shall not be held responsible for any damage or loss caused to the Client due to improper use (including prohibited and unprotected use) or storage of such username and password, including any such use made by a third party, and whether or not known to or authorized by the Client.
  • Any use of www.bnroptions.com with the Client's username and password is Client's sole responsibility. The Company shall not be held responsible for any such use, including for validation that Client is actually operating in his/her Account.
  • Client is obliged to forthwith notify the Company's client service of any suspicion for unauthorized use of the Account.
  • The Company does not store or collect any Credit Card data.
  • In accordance with the recommendations of Payment Card Industry Security Standards Council, customer card details are protected using Transport Layer encryption — TLS 1.2 and application layer with algorithm AES and key length 256 bit.
  • Cookies:

Definition: A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a “device”) browser from a website's computer and is stored on your device's hard drive for tracking site usage. A website may send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows. A Client may choose to configure their browser to reject cookies by modifying their browser settings or preferences.


Our cookies policy: During the course of any visit to www.bnroptions.com website, the pages viewed, along with a cookie are downloaded to the Client’s device. Cookies stored may determine the path the Client took on our site and used to anonymously identify repeat users of the website and what pages were most popular for Clients. However, the Company protects the Client’s privacy by not storing the Client’s names, personal details, emails, etc. Using cookies is an industry standard and is currently used by most major Websites. Stored cookies allow www.bnroptions.com’s website to be more user-friendly and efficient for Clients by allowing the Company to learn what information is more valued by Clients versus what isn’t.

Withdrawal & Refund Policy

  • To withdraw funds from his/her account, the Client shall submit a withdrawal request from his/her personal profile. In order to fill in the withdrawal request properly, the Client shall choose one of the withdrawal methods shown in the list and specify all the necessary details.
  • After the Client submits a withdrawal request, such request will be assigned a "Requested" status. When the request is being processed, it has an "In Process" status. After the "In Process" status is assigned, the requested funds will be debited from the Client's account balance. After the withdrawal request is assigned a "Processed" status, the requested funds will be transferred to the payment system.
  • Withdrawal requests are processed by the financial department of the Company one-at-a-time. The processing time may vary from 1 business day up to 3 business days. The Company reserves the right to increase the processing time; in such case, the Company shall notify the Client via any contact method specified by the Client in his/her profile.
  • The Client has the right to withdraw funds only to the payment system that was used to deposit funds to his/her account. In case where it is technically impossible to withdraw funds to the payment system that was used to deposit funds, the payment method shall be chosen by the Company according to the Client's wishes. In such case, the payment details shall meet the conditions specified by the Client in his/her personal info.
  • The Client is fully responsible for the information he/she provides to the Company through the withdrawal request.
  • If the Client uses a bank card for making deposits, withdrawals shall be made to this bank card in the amounts not exceeding the amount deposited within 90 (ninety) calendar days from the last deposit. Withdrawals to bank cards have greater priority than other types of withdrawals.

Anti Money-Laundering (AML) and Know Your Customer (KYC) Policy
  • It is the policy of www.bnroptions.com and its affiliates, (hereinafter “The Company”) to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. The Company requires its officers, employees and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.
  • For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.
  • Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.
  • Each employee of The Company, whose duties are associated with the provision of products and services of The Company and who directly or indirectly deals with the clientele of The Company, is expected to know the requirements of the applicable laws and regulations which affect his or her job responsibilities, and it shall be the affirmative duty of such employee to carry out these responsibilities at all times in a manner that complies with the requirements of the relevant laws and regulations.
  • To ensure that this general policy is carried out, management of The Company has established and maintains an ongoing program for the purpose of assuring compliance with the relevant laws and regulations and the prevention of money laundering. This program seeks to coordinate the specific regulatory requirements throughout the group within a consolidated framework in order to effectively manage the group’s risk of exposure to money laundering and terrorist financing across all business units, functions, and legal entities.
  • Each of the affiliates of The Company is required to comply with AML and KYC policies.
  • All identification documentation and services records shall be kept for the minimum period of time required by local law.
  • All new employees shall receive anti-money laundering training as part of the mandatory new-hire training program. All applicable employees are also required to complete AML and KYC training annually. Participation in additional targeted training programs is required for all employees with day to day AML and KYC responsibilities.

 

Bonus Policy