This policy statement aims to inform you (the Client) about our (APX Capital) Privacy Policy. For a better understanding of how we conduct business with you, please also refer to our Terms & Business manual as well.
By opening an account on APX Prime, you understand that you will be providing us with personal information that we will use to open, administer and maintain your account with us.
• We undertake not to sell or pass on your personal information to any third parties except to those that we need to in relation to the normal operation of our business. These include credit card processing and verification centers, law enforcement agencies, any financial or other regulators, our auditors and your compliance officer (if you are, or your firm is, FCA regulated), and introducing brokers that we may have a business agreement with.
• We may provide personal details to other margin trading firms who are seeking a reference; however, this would not include details of any open positions.
• We obtain most of the information about our clients directly from them, but we reserve the right to obtain information from other sources such as credit reference agencies, the Electoral Register, or fraud prevention agencies.
• We may use the information we have to help us provide a better service or new products to you and our other clients via direct or indirect marketing.
• All staff at APX Capital are fully trained in the confidentiality of handling personal information.
• All personal information held by us is done so in secure computer-based storage facilities wherever possible. Otherwise, we hold the information in secure paper-based files. No unauthorized persons are able to gain access to these storage facilities.
• The APX Capital website uses Social Plugins which may be notified of the fact that your browser is viewing our website and this information may also include your IP address. This is an automated process. If you do not want this information shared, then you should ensure you are logged out of your social media accounts prior to viewing our website.
• Our website may install cookies on your computer so that we can better serve your requirements by knowing what areas of our website you have been looking at and speeding your navigation. You have the option of turning this function off via your browser settings if you wish, although this may affect your ability to view some parts of the website accurately.
• While we make every effort to ensure all information that we hold is correct and up-to date, it is your responsibility to notify us with any changes in your personal information. www.apxcg.com
• Users who wish to no longer receive our newsletter or promotional e-mails may click ‘Unsubscribe’ link any time at the bottom of the text which is embedded with every e-mail sent by APX Capital in order to not receive any new messages.
If a money transfer you ordered is delayed or fails, you may have a right to receive a refund or compensation under Money Transfer Regulations.
We fully honor your rights and will act responsibly and attentively to resolve any claims. Claims for refund or compensation must be supported by all available evidence.
In a case of a cancellation or refund of a returned payment the following procedures will apply: The sender must request a refund in writing stating the reason and customer number, signed by the sender and including a colored copy of his/her passport or driving license. All written refund requests will be reviewed under the discretion of APX Prime LLC. For all processed transfers, the sender shall only obtain the foremost amount minus the refund administration fee.
An administration fee of £25 will be charged for all refunds. The refund charge may differ due to bank charges or exchange rate changes that may been incurred by APX Prime Ltd at the time period of a refund.
It will take approximately 3 working days to affect a refund. Refunded money will be transferred only to the sender’s bank account.
Any changes in or modifications to the details will incur a charge of £10.Any complaints regarding a transaction should be reported within 14 working days.
The foregoing shall be without prejudice to your statutory rights.
Due to national and international regulations on the prevention of criminal activities and money laundering, and terrorism financing, APX Capital strictly implements KYC guideline and procedure. While we respect and honor the confidentiality of our clients, corporate and individuals, we are committed to undertaking thorough due diligence of both our clients' identities and the nature of their businesses. KYC policy of APX Capital is based on principles of partnership: if we know and understand our customers, they know and understand us.
It is our obligation not just to undertake a full and proper due diligence of our clients' and their current needs, but also to monitor and ensure that their business activities do not breach any national and international regulations with regards to money laundering and terrorism financing. Clients are therefore invited to provide below listed documents:
** A high-resolution copy of the photo page of passport and other relevant pages, indicating full name, nationality, place and date of birth, issue and expiry dates, passport number, country of issue and signature or a copy of national identity card/driver's license including mentioned information.
** Utility bill (e.g., electricity, telephone, etc.) or Bank Statement dated within the last three months, showing registered name, permanent residential and mailing address.
** A high-resolution copy of credit card’s front and reverse side in case client has used it to deposit the funds, six digits of card number and CVC2/CVV2 code must be covered.
All documents upon request special and directly addressed to you must be provided to APX Capital by uploading them at the Secured Client Area or sending to support@apxprime.com Clients are therefore invited to provide below listed documents:
** High-resolution copy of the Certificate of Incorporation.
** High-resolution copy of company's Memorandum and Articles of Association.
** Certificate of Incumbency (no older than 6 months), detailing names of directors and shareholders.
** Document detailing the address of the company's registered office.
** Passport copies of the company’s directors and shareholders.
** Addresses of all directors.
All documents upon request special and directly addressed to you must be provided to APX Capital by uploading them at the Secured Client Area or sending to support@apxprime.com To ensure that the KYC information that APX Capital holds on its customers is always accurate and up to date, APX Capital shall, upon its sole discretion, determine the periodicity at which each individual customers shall be, upon request, obliged to provide their KYC information anew to continue using APX Capital services.
APX Capital is entitled, upon its sole discretion and grounding upon this policy, at any time during the service provision to its clients demand them present the documents (list of which shall be constituted solely by APX Prime including the form of the documents to be presented) to reinstate account functionality or justify any other action (or operation) performed (or about to be performed) by the client. Such requests will be made via email.
Simultaneously, APX Capital reserves the exclusive right to unilaterally decline any clients' application and/or terminate further provision of services without any statements or explanations to the client.
The objectives of this Policy are to:
** Ensure that the products and services of APX Capital are not used to launder the proceeds of crime and that all employees of APX Capital are aware of their obligations and the need to remain vigilant in the fight against money laundering/terrorist financing.
** Provide a consistent approach across the firm to the deterrence and detection of those suspected of laundering the proceeds of crime or those involved in the funding or execution of terrorism, and the disclosure to the relevant authorities
** Explain clearly the responsibility of the Board of Directors, Senior Management team, the Money Laundering Reporting Officer (MLRO) and other key colleagues
** Establish requirements for effective implementation and monitoring of compliance with this Policy.
Money laundering is the generic term used to describe the process by which criminals disguise the original ownership and control of the proceeds of criminal conduct by making such proceeds appear to have derived from a legitimate source through a series of transactions, so that they appear to be the proceeds from legal activities.
Terrorism financing refers to the use of funds, or the making of available funds for the purposes of terrorism; or the acquisition, possession, concealment, conversion, or transfer of funds (directly or indirectly) that will in turn be used or made available for such purposes. It can be defined as the financial support, in any form, to terrorism or of those who encourage, plan, or engage in terrorism. A terrorist group, like any other criminal organization, builds and maintains an infrastructure to develop sources of funds and channel them to those who provide materials and or services to the terrorist organization.
The AML Policy and Procedures adopted by APX Capital are established in compliance with the AML Regulations 2008. The Firm aims to prevent and take measures to guard against being used as a medium for money laundering and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities. The AML/CTF Policy sets out the following minimum standards which must be complied with by the Firm:
** The Firm will establish and maintain risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs).
** A Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks will be established and maintained.
** Risk based systems and procedures will be established to monitor ongoing customer activity.
** All staff and any individual/corporation engaged under a contract of service by the Firm shall fully comply with both the letter and the spirit of regulatory requirements and act as required by the highest standard of market conduct.
** The Firm will appoint a Money Laundering Reporting Officer (MLRO) with a responsibility for the oversight of the Firm’s compliance with relevant legislation, regulations, and rules.
** The Firm will implement effective communication of all policies and procedures to raise awareness for all employees on AML/CTF issues.
** The Firm will retain the appropriate records of customer transactions for a period of at least five years, as required under AMLR 2008.
** The Firm will not continue its established relationships with customers whose conduct gives rise to suspicion of or involvement with illegal activities.
** The Firm will fully cooperate with law enforcement and regulatory authorities as required.
An entity shall carry out money laundering and terrorist financing risk assessments in relation to each customer, business relationship or one-off transaction in order:
** to determine the existence of any risks.
** to determine how best to manage and mitigate any identified risks.
** to develop, establish and maintain appropriate anti-money laundering and terrorist financing systems and controls to effectively respond to the identified risks; and
** to always ensure that there is full compliance with the requirements of the AMLR (2008) and other enactments, policies, codes, practice directions and directives mentioned above in relation to anti-money laundering and terrorist financing activities. A risk assessment should be proportionate to:
** the nature, size and complexity of the business, taking into account agent relationships and the range of financial products and services being offered.
** the type of products and services offered, and the extent to which the products and services offered are consistently below a given threshold.
** customers’ characteristics based on developed risk profiles, including the level of customer diversity across different geographical locations.
** the conditions of the proposed transactions.
** the distribution channels A risk-based approach assists the measurement of risks for potential laundering of illegally gained funds, identification of the risks and the appropriate means and methods for mitigating and controlling those risks. With the aim of preventing any transactions to laundering of proceeds of crime and financing of terrorism, APX Capital sets and develops adequate procedures in relation to monitoring the customers’ transactions, related reporting, retention of records, organization of the training and internal auditing activities.
The Customer Due Diligence information, as stated by the International Compliance Association (ICA), contains the facts about the prospective customer enabling the Firm to assess the extent to which the customer exposes it to a range of risks. Thus, the Firm needs to:
** Identify their customers and their beneficial owners and verify their IDs via independent and reliable resources.
** Understand and document the ownership and control structures of customers and UBO’s
** Obtain information on the source of wealth and funds, size and volume of business and expect nature level of transactions.
Under AMLR (2008) Regulation 19, the Firm is required to conduct ongoing monitoring of the business relationships with clients on a risk-sensitive and appropriate basis. The requirement is to maintain scrutiny of transactions undertaken by the clients to ensure that the transactions are consistent with what we know of the client and the client’s business and resources Thus, the Firm shall consider the following while conducting ongoing monitoring of a business relationship which includes but not limited to:
** The knowledge of the individual (e.g., the source of the client’s funds, type of business, source of wealth)
** The customer’s risk profile (e.g., geography risk, product risk, etc.) Whenever ongoing monitoring gives rise to any suspicions of money laundering, promptly report them to the MLRO. Under AMLR (2008) Regulation 19, the Firm is required to conduct ongoing monitoring of the business relationships with clients on a risk-sensitive and appropriate basis. The requirement is to maintain scrutiny of transactions undertaken by the clients to ensure that the transactions are consistent with what we know of the client and the client’s business and resources Thus, the Firm shall consider the following while conducting ongoing monitoring of a business relationship which includes but not limited to:
** The knowledge of the individual (e.g., the source of the client’s funds, type of business, source of wealth)
** The customer’s risk profile (e.g. geography risk, product risk, etc.) Whenever ongoing monitoring gives rise to any suspicions of money laundering, promptly report them to the MLRO.
Consistent with the training obligations defined in the AMLR (2008), the Firm should provide adequate training for its staff.
** Ensuring that they receive appropriate and proportionate training to the level required by the Anti-money Laundering Regulations, 2008 in relation to money laundering and terrorist financing; and
** Ensuring appropriate periodic training to be given to all key staff, including front office staff, temporary and contract employees acting as third party.
** That is designed to test employee knowledge and understanding of the laws, policies and procedures, including the internal controls systems of the entity or professional, relating to AML/CFT on a periodic basis. Depending on the new releases within regulatory environment, the MLRO should update the training material and provide additional training to the related key staff. Records of all training activity, including completion and pass rates where applicable are maintained and retained in compliance for a period of 5 years.
APX Capital (“APX”) believes that its customers (the “client”, “customer”, “you”, or “your”) should be aware of the risks involved in entering over-the-counter contracts for foreign currency, precious metals, and contracts for difference (CFDs) and spot foreign exchange contracts (“Spot FX”) (collectively, “OTC Contracts”). The following is a brief, non-exhaustive summary of certain significant factors and special risks you should consider when deciding whether to trade OTC Contracts. For the avoidance of doubt, this statement does not constitute a form of investment advice, nor has the character of investment advice.
Before deciding whether to carry out a transaction in OTC Contracts, you are obliged to examine whether concluding such transactions is relevant to your investment targets and regarding your experience, knowledge, and willingness to take risks. If you have any doubts as to the essence of the functioning of financial instruments and their economic sense, you are obliged to ask APX for an explanation.
This Statement, which constitutes an addition to the Client Agreement and the Terms of Business of APX, does not disclose or explain all the risks and other significant aspects involved in trading OTC Contracts. Engaging in transactions offered by APX can carry a high risk to your capital, where there is the potential that it is lost completely. If more information on the risks involved is required, please contact APX Capital.
The information on this website is not targeted at residents of the United States, Belgium or any particular country outside the Saint Vincent and the Grenadines and is not intended for distribution to, or use by, any person in any country or jurisdiction where such distribution or use would be contrary to applicable law or regulation.
In accordance with our internal rules, we do not provide services to individuals who are residents or legal entities based in the United States of America, United Kingdom, Germany, France, Turkey and Belgium
APX Capital Ltd is incorporated under registration number 2023-00178 by the registered by the International Business Company Act. of Saint Lucia, Address: 1st Floor, The Sotheby Building, Rodney Bay, Gros-Islet, Saint Lucia P.O. Box 838, Castries, Saint Lucia