Client Money Withdrawal Policy

1. Purpose

This Policy sets out the principles, controls and procedures governing the withdrawal of client money held by Grand Markets (“the Company”, “we”, “us”). Its purpose is to ensure that client funds are returned only to the entitled client, through compliant channels, in a manner consistent with the Company’s obligations relating to the segregation and safeguarding of client money, the prevention of money laundering and terrorist financing, and the fair treatment of clients.

2. Scope

This Policy applies to all withdrawal requests submitted by clients of the Company across all trading accounts and account types, to all Company personnel who receive, review, approve or process such requests, and to any third-party payment service providers, banks or introducers involved in the movement of client funds.

3. Regulatory framework

This Policy is designed to give effect to the Company’s obligations under, among others:

• the Securities Act 2005 and the Securities (Licensing) Rules 2007;

• the Financial Services Act 2007 and rules, codes and guidelines issued by the Financial Services Commission (the “FSC”);

• the conditions attaching to the Company’s Investment Dealer Licence;

• the Financial Intelligence and Anti-Money Laundering Act 2002 (FIAMLA), the FIAML Regulations 2018, and the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019; and

• the FSC’s Anti-Money Laundering and Countering the Financing of Terrorism Handbook, as amended from time to time.

Where any provision of this Policy conflicts with applicable law or the conditions of the Company’s licence, the applicable law and licence conditions prevail, and the Compliance Officer must be notified so the Policy can be corrected.

4. Definitions

Client money means money of any currency that the Company receives or holds for, or on behalf of, a client in the course of, or in connection with, its licensed activities.

Segregated account means a bank account, designated as a client account and held separately from the Company’s own funds, in which client money is deposited and from which client money is disbursed.

Same-source (return-to-source) principle means the requirement that withdrawals be remitted, so far as reasonably practicable, back to the same payment instrument and account from which the client originally funded the trading account.

Free (withdrawable) balance means account equity less any margin required to maintain open positions, unrealised losses, accrued charges, bonuses or credit subject to conditions, and any amount held under a lien, freeze or legal restriction.

Beneficial owner, MLRO, DMLRO and Compliance Officer have the meanings given in the Company’s AML/CFT Programme.

5. General principles

Client money is held in one or more segregated client accounts, separate from the Company’s own operational funds, and is not used to meet the Company’s own liabilities or made available to the Company’s creditors. Withdrawals reduce only the client’s own entitlement and are drawn from these segregated funds.

The Company processes withdrawal requests only where the requesting person is the verified account holder, the account has completed all applicable onboarding and due-diligence requirements, and the request meets the conditions in this Policy. The Company does not make payments to third parties: funds are returned to an account in the name of the client, and the Company will not remit client money to a person other than the client except where required by law or a valid court order.

The Company applies the same-source principle to every withdrawal, so that funds are returned through the same route by which they entered, in order to reduce money-laundering risk. The Company treats withdrawal activity as part of its ongoing transaction monitoring and will scrutinise patterns that are inconsistent with a genuine trading purpose.

6. Eligibility and conditions for withdrawal

A client may withdraw funds up to the free (withdrawable) balance of the account, subject to the following conditions:

1. Verified account. Onboarding, identity verification (KYC) and, where applicable, enhanced due diligence must be complete and current. Where verification is outstanding or documents have expired, the withdrawal is held pending completion.

2. Account holder only. The withdrawal must be requested by, and paid to an account belonging to, the verified client. No third-party or on-behalf-of payments are permitted.

3. Margin sufficiency. A withdrawal may not reduce account equity below the margin required to support open positions. Requests that would breach margin requirements are declined or partially fulfilled up to the free balance.

4. Cleared funds. Funds must have cleared and any chargeback or reversal risk window applicable to the original deposit method must have passed.

5. No restriction in force. No freeze, lien, dispute, suspected fraud, sanctions match or legal hold may be in effect on the account.

6. Bonus/credit conditions. Any promotional credit or bonus is withdrawable only where the applicable terms have been satisfied; unearned bonus amounts are excluded from the free balance and may be removed before payout.

7. Withdrawal request procedure

Clients submit withdrawal requests through the Company’s client portal (or another channel the Company designates in writing). A verbal instruction is not sufficient. Each request must identify the account, the amount and the destination instrument.

On receipt, the Company:

1. authenticates the requesting party against the account credentials and, where risk warrants, applies additional verification;

2. confirms the free (withdrawable) balance and margin position;

3. confirms that the destination instrument is in the client’s name and, under the same-source principle, matches a previously used and verified deposit route;

4. screens the request through transaction-monitoring and sanctions controls; and

5. approves, holds (pending information) or declines the request in accordance with this Policy, recording the decision and its basis.

Approved requests are released to the finance/payments function for execution from the segregated account. Segregation of duties is maintained so that the person approving a withdrawal is not the sole person executing the payment.

8. Same-source (return-to-source) rule

Withdrawals are returned to the original funding instrument in the following order of preference: (a) to the same card or bank account used to deposit; (b) where the original method cannot receive funds (for example, a card that has expired or a one-way instrument), to an alternative account verified as belonging to the client, with the reason documented; and (c) only in exceptional, documented circumstances and with Compliance approval, by another compliant method in the client’s name.

Where a client funded the account by more than one method, refunds are generally returned to each source up to the amount deposited by that source, with any profit typically remitted to the client’s verified bank account. The Company does not permit deposits and withdrawals to be used as a means of transferring value between instruments or persons.

9. Source of funds and enhanced due diligence

The Company may request evidence of source of funds and apply enhanced due diligence before releasing payment. The Company may hold the withdrawal for the period reasonably needed to complete these checks and will keep the client informed of the status to the extent permitted by law.

10. Anti-money laundering, sanctions and suspicious activity

All withdrawal activity is subject to the Company’s AML/CFT Programme. Every request is screened against applicable sanctions lists. Where a withdrawal gives rise to a suspicion of money laundering or terrorist financing, staff must escalate internally to the MLRO/DMLRO and must not proceed with, delay, or “tip off” the client about, the transaction other than as directed by the MLRO. The MLRO determines whether a Suspicious Transaction Report is required and whether the transaction may proceed. Nothing in this Policy requires or permits the Company to make a payment that would breach FIAMLA, applicable sanctions, or a lawful direction of a competent authority.

11. Processing times

The Company aims to review and approve compliant withdrawal requests within 1 business day(s) of receipt of a complete request with the cutting off time is 12pm of the day (Mauritius local time). This means withdrawal requests that are submitted after the 12 pm will be processed in the following business day Once approved and released, settlement to the client depends on the method, subject to correspondent-bank and intermediary timeframes outside the Company’s control. Requests received outside business hours, on weekends or on Mauritius public holidays are processed on the next business day. Timeframes are extended where a request is incomplete, requires further due diligence, or is subject to a hold under this Policy.

12. Withdrawal methods, currency and fees

Withdrawals are made only by the methods the Company supports and publishes from time to time, and only to instruments in the client’s name. Where the account currency differs from the destination currency, conversion is applied at the prevailing rate, and the client bears any conversion cost and any third-party or correspondent-bank charge. Any Company withdrawal fees are as set out in the Company’s published fee schedule and are disclosed before the client confirms the request. The Company does not profit from imposing withdrawal restrictions and applies charges only on a cost-recovery and disclosed basis.

13. Minimum amounts, partial withdrawals and negative balances

The Company may set a minimum withdrawal amount, published in client portal. A client may make a partial withdrawal up to the free balance. Where an account carries a negative or debit balance, no withdrawal is available until the balance is regularised in accordance with the client agreement.

14. Grounds for refusal, delay or suspension

The Company may refuse, delay, partially fulfil or suspend a withdrawal where: the client is not verified or verification has lapsed; the destination instrument is not in the client’s name or cannot be reconciled to a verified source; the free balance is insufficient or margin would be breached; a sanctions match, fraud indicator, chargeback, or suspicion of money laundering arises; a legal hold, court order or regulatory direction applies; the request appears to relate to market abuse, prohibited trading, or abuse of Company promotions; or applicable law otherwise requires. Where the Company refuses or delays a withdrawal, it records the reason and, unless prohibited (for example, by tipping-off restrictions), informs the client of the outcome and of the Company’s complaints procedure.

15. Dormant and inactive accounts

Where an account becomes dormant, the client money remains segregated and the client’s entitlement is preserved. The Company will make reasonable efforts to contact the client to return the balance and will deal with dormant client money in accordance with applicable law and FSC requirements. Reactivation and withdrawal from a dormant account require re-verification of the client’s identity and instrument.

16. Records and reconciliation

The Company keeps records of each withdrawal request and the supporting decision, verification and payment evidence for at least the period required by law (and in any event not less than seven years from the end of the relationship or the transaction, as applicable under FIAMLA). Client money accounts are reconciled to internal records on a regular basis, and any discrepancy is investigated and, where material, escalated to the Compliance Officer and reported to the FSC where required.

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