Anti-Fraud & Counter Terrorism Financing Policy
Arwena Limited recognizes that decentralized and distributed digital currency and payment systems in which payments are processed and secured by advanced cryptography and distributed computing power instead of a central bank, corporation or government pose a risk of illegal uses (as do all financial systems). Arwena Limited. believes, however, that the legitimate use of math-based currency networks provides untold benefits and efficiencies within the global economy.
Arwena Limited. innovative services and established specific controls address those risks as required by the law. It is the policy of Arwena Limited. to comply with applicable standards regarding anti fraud and identity verification, and to detect and prevent the use of its Service for fraud or to facilitate criminal or terrorist activities.
While Arwena Limited is committed to protecting its users’ privacy, it will not allow people to use its Services to commit fraud or other crimes, finance terrorist activities, or facilitate other illegal conduct.
Having in mind that (1) cryptocurrencies are transferred peer-to-peer, therefore, the “middleman” is cutting out, (2) cryptocurrencies transfers are recorded in the distributed public ledger and anyone has access to these transfers, and (3) the risk that anyone would attempt to use Arwena Limitedplatform to be used for illegal activities is very low, Arwena Limitedaims to prevent and, detect all and any attempt to commit any illegal act by anyone who use its services platform or it is connected with the Company.
The management of The Company places extremely high importance on assisting in discovering any fraud scheme. These policies are to be read by and adhered to by all officers, employees,associates, and agents of The Company.
This Policy applies only to customers who has opened an account with Arwena Limited.
Arwena Limited offers an online trading platform through xtexchange.com (“Arwena Limited”) that allows people to place interchange orders on Contracts denominated solely in cryptocurrency. The Company also offers tools that allow people to deposit or withdraw cryptocurrency units to and from an account via Peer-to-Peer Network. The Company doesn’t offer financial services/investment services/fiat to crypto conversion/crypto to fiat conversion services.
By using Arwena Limitedplatform, customers can open a long or short positions using deposited crypto units as leverage, or hold crypt units indefinitely. In order to prevent any abuse, all crypto deposits and withdrawals form customer accounts must be made from the same cryptocurrency Wallet. For avoidance of doubt cryptocurrency withdrawals must be made to the same cryptocurrency wallet that was used by registered customer. Registered customers are not required to disclose their identities.
3. RECORD KEEPING
When transferring cryptocurrency, the Company will record in its database at least the following information:
- The execution date of the transmittal order.
- The Bitcoin Transaction Identifier (“Txid”)
- The Bitcoin address.
- The amount of the transmittal order.
- The Bitcoin trading account number of the recipient.
For each transmittal order that The Company accepts, it will retain in its files any payment instructions received from the transmitter with the transmitter order and any form relating to the transmittal of funds that is completed by the person placing the transmittal.
Client Categorization Policy
1. Client Classification
Arwena Limited (hereinafter the “Company”) does categorize its Clients into one of the following three categories: retail, professional or eligible counter-party.
2. Client Classification / Risk Classification
The Company, prior to engaging in any business relationship with its potential clients, categorises the potential clients based on their level of experience and understanding of the risks involved. Clients shall be categorized as follows, based on the criteria outlined below:
- Professional Clients
Professional client is a client who possesses the experience, knowledge and expertise to make its own investment decisions and properly assess the risks that it incurs.
- Retail Clients
Each client, who is not a professional client, is considered to be a retail client. All the individual Clients are classified as Retail Clients.
Moreover, each Client, either Retail or Professional, will be categorised on three risk levels, based on his ability to bear the trading risk, as per the below classification:
When any of the above criterias are met, the Client can ask to be reclassified accordingly. For example, a Level 1 Client that sends to the Company 8 interchange orders for execution, needs to apply for Level 2 in order to be able to continue trading. Once he applies for Level 2 classification the Company will verify his Balance eligibility and proceed with his request. Once he will be classified as Level 2 he will be able to send up to 19 interchange orders and his trading account leverage will increase to 1:100.
The Client doesn’t have the option to change his RISK CLASSIFICATION. This is set by the Company based on his Balance and number of deals.
- OPTION TO CHANGE CLIENT CLASSIFICATION – The Client doesn’t have the option to change his RISK CLASSIFICATION. This is set by the Company based on his Balance and number of deals.
It is noted that an eligible counterparty or professional client is allowed to request non professional treatment and the Company may agree to provide a higher level of protection. In this respect, the Company notifies its clients in a written form of their option to be classified as retail clients. The Company proceeds in this action, in order to offer a uniform level of protection to all of its clients.
The higher level of protection will be provided by the Company when the client enters into a written agreement with the Company, to the effect that it shall not be treated as a professional. It is the responsibility of the client who is classified as a professional client to ask for a higher level of protection when he is not in a position to properly assess and manage the risks involved in the transactions.
3. Request for different Client Categorisation
In accordance with Section II above, the following request may be submitted to the company:
- a) A Retail Client requesting to be categorised as a Professional Client. In that case the Client will be afforded a lower level of protection.
- b) A Professional Client requesting to be categorised as a Retail Client. In that case the Client seeks to obtain a higher level of protection.
The Company reserves the right to decline any of the above requests for different categorisation.
4. Retail Clients/ Professional Clients
Where the Company treats the Client as a retail client, he/she/they will be entitled to more protections than if the Client was entitled to be a professional client. In summary the additional protections retail clients are entitled to are as follows:
- A retail client will be given more information/disclosures with regard to the Company, its services and any cost, commissions, fees and charges and the safeguarding of client instruments and client cryptocurencies.
- When executing orders, the Company must take all reasonable steps to achieve what is called “best execution” of the client’s orders that is to obtain the best possible result for their clients.
Where the Company executes an interchange order on behalf of a retail client, the best possible result shall be determined in terms of the total consideration, representing the value of the Contract and the cost related to execution, which shall include all expenses incurred by the client which are directly related to the execution of the order, including execution venue fees, clearing and settlement fees and any other fees paid to the third parties involved in the execution of the order, if such fees apply.
When providing professional clients with best execution the Company in not required prioritise the overall cost of the transaction as being the most important factor in achieving best execution for them.
- The Company must inform retail clients of material difficulties relevant to the proper carrying out of their order(s) promptly upon becoming aware of the difficulty.
- If the Company provides services to a new retail client, the Company must enter into a basic agreement with the client, setting out the essential rights and obligation of the firm and the client.
- We shall not use possessions held by us on behalf of a client for our own account or the account of another client of ourselves, without the client’s prior express consent to the use of the instruments on specified terms, as evidenced, in the case of a retail client, by his signature or equivalent alternative mechanism.
Bonus and Award policy
In the event of a conflict between Belfast Capital Grouip LLC. and a Client, terms expressed in English and expressed in any other language, the terms expressed in English shall prevail over those expressed in any other language.
Belfast Capital Grouip LLC (“the Company”) offers a number of attractive rewards to its new and existing customers (“Customers”). Bonuses and/or trading awards or promotions (“Award”) rewarded to Customers are part of the Company’s promotional program. These Awards have limited time offers of which the following terms shall apply in reference to the relevant Customer account (“Account”).
1.1 Bonus/Award – A bonus/Award is an added crypto value to the Client’s crypto currency deposit in his trading account with the Company which provides additional equity to use for trading purposes. The amount of Bonus each Client is eligible to receive is subject to the Company’s decision;
1.2 Customer Profit – profits incurred in the Customer account, coming from his/her trading activity;
1.3 Customer Loss – losses incurred in the Customer account, coming from his/her trading activity;
1.4 Trading Results – Customer profit(s)/loss(es) incurred in the Customer account;
1.5 Account Equity – Customer account Balance plus the Trading Results plus Bonus/Award;
1.6 Account Balance – Customer own funds net deposited in his account (deposits minus withdrawals) plus realised profits;
1.6 Customer Account – Customer trading account, opened on www.belfastcapital.net.
2. Award/Bonus rules acceptance
Prior to accepting any Award offer Customers shall consider the particular terms and conditions associated with the Award and these Bonus and Award Policy, as both may be amended from time to time. Acceptance of the Award is done by placing a trade in the Account. After accepting the Bonus/Award the Customer acknowledges and agrees that the leverage in his trading account may increase.
3. Trading the Bonus/Award
The Bonus/Award can be traded and can be lost.
4. Withdrawal, Removal and Trading Results
4.1 Withdrawal – the Award cannot be withdrawn. The Award is used solely for trading.
4.2 Profit – the Customer Net Profit, obtained by trading with the Bonus awarded, can be withdrawn, without any conditions related to Awards.
4.3 Removal – in the case that the available balance on account as at the time the Bonus was granted is withdrawn/lost by the Client, the Bonus will be removed. In these circumstances the Company shall not be liable for any consequences of the bonus removal, including, but not limited to, order(s) closure by Stop Out.
4.4. Trading results – in case the customer realizes losses in an account that was granted a bonus or an award, these losses will be settled from the customer’s deposits and trading results and not from the bonus that was granted. The losses will be settled from the bonus only if the account’s equity (excluding the bonus or the award) is zero.
5. Account Terms
Customers are prohibited from opening multiple accounts with the Company for the sole purpose of enjoying more than one Award. Duplicate accounts (accounts opened for the same beneficial owner) may be closed without notice. In such cases the Company shall retain any Award rewarded to the Customer, any earnings will be forfeited and any amount deposited by the Customer to the Account will be returned to the Customer accordingly.
6. Opt out
The Customer is not required to accept any Award offered by the Company; all Awards are optional. The Customer may choose not to accept an Award. In these circumstances, the Customer will not be bound to the terms relating to Awards. Should the Customer mistakenly accept an Award, the Customer shall not trade in the Account and notify the Customer Support within 5 working days from mistakenly accepting the Award. In such circumstances, the Company will remove the Award from the Customer’s account and the Customer shall not be held to the Award terms.
7.1 Any improper or abusive trading, not in accordance with the Company’s Client Retail Agreement or Terms and Conditions, will result in the Award/Bonus being revoked or not awarded, and may also result to your Account being frozen.
7.2 No delay or omission to exercise any right, power, or remedy accruing to any party upon any breach or default under this Agreement, shall be deemed a waiver of any other breach or default theretofore or thereafter occurring;
7.3 If any provision of this Agreement is held invalid or unenforceable, such invalidity or unenforceability shall not affect the other provisions of this Agreement, and, to that extent, the provisions of this Agreement are intended to be and shall be deemed severable;
7.4 Please note that once a trading account is classified as Inactive/Dormant Account all Bonuses and/or Awards may be removed without prior notice. Please refer to section “Inactive and Dormant Accounts” for information on Inactive Accounts.
7.5 The Company will not be liable for any stop outs or any other consequences that result out of a Bonus cancellation and/or removal.
7.6 If the Company suspects that the Client has abused or attempted to abuse the Bonus and Awards Policy, or otherwise acted without good faith towards the Company, then the Company reserves the right, at its sole discretion, to deny, withhold or withdraw from the trading account the Bonus or promotion and if necessary to cancel any terms and conditions, either temporarily or permanently, or terminate Client’s access to the service and/or block the Trading Account.
7.7 The Bonus only applies to funded accounts with available balance of at least USD500 or equivalent at the time the Bonus is granted.
7.8 Transfers between other Trading accounts maintained with the Company under the name of the Client or a third person, are not considered as deposits.
7.9 Bonuses cannot be transferred between, or from Eligible Clients’ trading Accounts within the Company.
7.10 Internal funds transferred between trading Accounts within the Company are considered as withdrawals, therefore Bonus removal will be applied if the amount being transferred out from the 100% Bonus account is from the original balance that was awarded a respective bonus.
7.11 If a part of the available balance on account as at the time the Bonus was granted is withdrawn/lost the bonus can be removed on a pro rata basis, therefore in this case there will be a partial bonus removal.
7.12. It is considered improper or abusive trading, the Client by himself or acting with others (including an Introducing Broker), establishing a trading position(s) which has the purpose or effect of extracting any profits generated by the Bonus awarded, without exposure to economic risk.
7.13 It is considered improper or abusive trading, the Client by himself or acting with others, having an account or accounts where the accumulated Bonuses/Awards amount is greater than the amount which could have been accumulated if the Client and such others had complied with the Terms and Conditions of the Promotions.
In consideration of Arwena Limited (hereafter the “Company”) agreeing to enter into over-the-counter (“OTC”) derivative contracts denominated in crypto currency units with the undermentioned (hereinafter referred to as the “Customer”, “ you”, “ your”), Customer acknowledges, understands and agrees that:
1. Trading is very speculative and risky
Trading derivative products is highly speculative, involves a significant risk of loss and is not suitable for all investors but only for those customers who: – understand and are willing to assume the economic, legal and other risks involved; – are experienced and knowledgeable about trading in derivatives and in underlying asset types; and – are financially able to assume losses significantly in excess of margin or cryptocurrency units deposited because investors may lose the total value of the contract not just the margin The Contracts are not appropriate placements for retirement funds. CFDs are among the riskiest types of trading instruments and can result in large losses. Customer represents, warrants and agrees that Customer understands these risks, is willing and able, financially and otherwise, to assume the risks of trading CFDs and that the loss of Customer’s entire account crypto currency balance will not change Customer’s lifestyle.
2. Risks related to long Contract positions, i.e. for purchasers of Contracts
Being long in a Contract means you are buying the Contract on the market by speculating that the market price of the underlying asset will rise between the time of the purchase and sale. As owner of a long position, you will generally make a profit if the market price of the underlying rises whilst your Contract long position is open. On the contrary, you will generally suffer a loss, if the market price of the underlying falls whilst your Contract long position is open. Your potential loss may therefore be bigger than the initial crypto margin deposited. In addition, you might suffer a loss due to the closure of your position, in case you do not have enough units for the margin on your account in order to maintain your position open.
3. Risks related to short Contract positions, i.e. for sellers of Contracts
Being short in a Contract means you are selling the Contract on the market by speculating that the market price of the underlying asset will fall between the time of the purchase and sale. As owner of a short position, you will generally make a profit if the market price of the underlying falls whilst your Contract short position is open. On the contrary, you will generally suffer a loss, if the market price of the underlying rises whilst your Contract short position is open. Your potential loss may therefore be bigger than the initial crypto margin deposited. In addition, you might suffer a loss due to the closure of your position, in case you do not have enough liquidity for the margin on your account in order to maintain your position open.
4. High leverage and low margin can lead to quick losses
The high degree of “gearing” or “leverage” is a particular feature of Contracts. The effect of leverage makes investing in Contracts riskier than investing directly in the underlying asset. This stems from the margining system applicable to Contracts which generally involves a small crypto currency deposit relative to the size of the transaction, so that a relatively small price movement in the underlying asset can have a disproportionately dramatic effect on your trade. This can be both advantageous and disadvantageous. A small price movement in your favour can provide a high return on the deposit, however, a small price movement against you may result in significant losses. Your losses will never exceed the crypto balance of your account, which is balanced to zero, if the losses are higher than the amount deposited. Such losses can occur quickly. The greater the leverage, the greater the risk. The size of leverage therefore partly determines the result of your trade.
5. Margin Requirements
Customer must maintain the minimum crypto margin requirement on their open positions at all times. It is Customer’s responsibility to monitor his/her crypto account balance. Customer may receive a margin call to deposit additional crypto units if the margin in the account concerned is too low. The Company has the right to liquidate any or all open positions whenever the minimum margin requirement is not maintained and this may result in Customer’s positions being closed at a loss for which you will be liable.
6. Cryptocurrency Settlement
Customer understands that the Contracts can only be settled in cryptocurrency and the difference between the buying and selling price partly determines the result of the interchange.
7. Prices, Margin and Valuations are set by the Company and may be different from prices reported elsewhere
The Company will provide prices to be used in trading, valuation of Customer positions, possessions and determination of Margin requirements. The performance of your Contracts will depend on the prices set by the Company and market fluctuations in the underlying asset to which your contract relates. Each underlying asset therefore carries specific risks that affect the result of the Contract concerned.
8. Rights to Underlying Assets
You have no rights or obligations in respect of the underlying instruments or assets relating to your Contracts. The Customer understands that Contracts can have different underlying assets, such as stocks, indices, currencies and commodities.
9. Currency Risk
Investing with an underlying asset listed in a currency other than your base crypto currency entails a currency risk, due to the fact that when the Contract is settled in a currency other than your base crypto currency, the value of your return may be affected by its conversion into the crypto currency.
10. One click trading and immediate execution
The Company’s online trading system provides immediate transmission of Customer’s order once Customer enters the notional amount and clicks “Buy/Sell.” This means that there is no opportunity to review the order after clicking “Buy/Sell” and Market Orders cannot be cancelled or modified. This feature may be different from other trading systems you have used. Customer should utilize the Demo Trading System to become familiar with the Online Trading System before actually trading online with the Company. Customer acknowledges and agrees that by using the Company’s online trading system, Customer agrees to the one-click system and accepts the risk of this immediate transmission/execution feature.
11. The Company is not an adviser or a fiduciary to customer
Where the Company provides generic market recommendations, such generic recommendations do not constitute a personal recommendation or investment advice or investment/financial service and have not considered any of your personal circumstances or your investment objectives, nor is it an offer to buy or sell, or the solicitation of an offer to buy or sell, any Contracts. Each decision by Customer to enter into a Contract with the Company and each decision as to whether a transaction is appropriate or proper for Customer, is an independent decision made by the Customer. The Company is not acting as an advisor or serving as a fiduciary to Customer. Customer agrees that the Company has no fiduciary duty to Customer and no liability in connection with and is not responsible for any liabilities, claims, damages, costs and expenses, including attorneys’ fees, incurred in connection with Customer following the Company’s generic trading recommendations or taking or not taking any action based upon any generic recommendation or information provided by the Company.
12. Recommendations are not guaranteed
The generic market recommendations provided by the Company are based solely on the judgment of the Company’s personnel and should be considered as such. Customer acknowledges that Customer enters into any Transactions relying on Customer’s own judgment. Any market recommendations provided are generic only and may or may not be consistent with the market positions or intentions of the Company and/or its affiliates. The generic market recommendations of the Company are based upon information believed to be reliable, but the Company cannot and does not guarantee the accuracy or completeness thereof or represent that following such generic recommendations will reduce or eliminate the risk inherent in trading Contracts.
13. No guarantees of profit
There are no guarantees of profit nor of avoiding losses when trading Contracts. Customer has received no such guarantees from the Company or from any of its representatives. Customer is aware of the risks inherent in trading Contracts and is financially able to bear such risks and withstand any losses incurred.
14. Internet Trading
When Customer trades online (via the internet), the Company shall not be liable for any claims, losses, damages, costs or expenses, caused, directly or indirectly, by any malfunction, disruption or failure of any transmission, communication system, computer facility or trading software, whether belonging to the Company, Customer, any exchange or any settlement or clearing system.
15. Quoting Errors
Should a quoting error occur (including responses to Customer requests), the Company is not liable for any resulting errors in account balances and reserves the right to make necessary corrections or adjustments to the relevant Account. Any dispute arising from such quoting errors will be resolved on the basis of the fair market value, as determined by the Company in its sole discretion and acting in good faith, of the relevant market at the time such an error occurred. In cases where the prevailing market represents prices different from the prices the Company has posted on our screen, the Company will attempt, on a best efforts basis, to execute Transactions on or close to the prevailing market prices. These prevailing market prices will be the prices, which are ultimately reflected on the Customer statements. This may or may not adversely affect the Customer’s realized and unrealized gains and losses.
16. Bitcoin Risk Warning
Unlike fiat currencies, which are backed by governments or other legal entities, or by commodities such as gold or silver, Bitcoin is a unique kind of “virtual currency”, backed by technology and trust. There is no central bank that can take corrective measure to protect the value of Bitcoins in a crisis or issue more currency. Instead, Bitcoin is an as-yet autonomous and largely unregulated worldwide system of currency firms and individuals. Considering abovementioned information, Bitcoin formally cannot be deemed as a fiat currency.
16.1 Characteristic of placements in Bitcoins
Traders in Bitcoins put their trust in a digital, decentralized and partially anonymous system that relies on peer-to-peer networking and cryptography to maintain its integrity. Confidence of the Traders in Bitcoins might collapse as a result of unexpected changes imposed by the software developers or others, a government crackdown, the creation of superior competing alternative currencies, or a deflationary or inflationary spiral. Confidence might also collapse because of technical problems: if the anonymity of the system is compromised, if money is lost or stolen, or if hackers or governments are able to prevent any transactions from settling.
16.2 Risks when investing in Bitcoins
Without prejudice to Risk Disclosure investing in Bitcoins involves particular risks in particular (but not limited to) specified herein below: Bitcoin exchanges are entirely digital and, as with any virtual system, are at risk from hackers, malware and operational glitches. If a thief gains access to a Bitcoin owner’s hard drive and steals his private encryption key, he could transfer the stolen Bitcoins to another account. This is particularly problematic once you remember that all Bitcoin transactions are permanent and irreversible. Bitcoin exchanges and Bitcoin accounts are not insured by any type of federal or government program. While Bitcoin uses private key encryption to verify owners and register transactions, fraudsters and scammers may attempt to sell false Bitcoins. For instance, in July 2013, the SEC brought legal action against an operator of a Bitcoin-related Ponzi scheme.
Refund and Cancellation
- The Client has the right to deposit their trading account only using the cryptocurrencies permitted.
- The actual settlement of services is deemed to be the moment when all appropriate cryptocurrencies are credited to the Company’s account.
- The Company holds no responsibility for the result of trading operations on the Client’s account, in case there are any delays in depositing into his account. The Client is solely responsible for any loss risks coming from possible delays in depositing funds to the Client’s trading account.
- In the event the trading account is credited in any cryptocurrency other than the one in which the trading account is maintained, such funds are to be credited to the trading account on the basis of an internal exchange rate adopted by the Company from the crypto currency exchange serving the Company at the date of deposit.
- When processing an internal transfer request, the Company shall use its internal cryptocurrency rates adopted by the Company from the crypto currency exchange serving the Company at the date of the transfer.
- If the trading account cannot be credited automatically, the appropriate application will be fulfilled within 72 hours since the client’s notice on crediting the trading account is received.
- The Client bears full responsibility for the adequacy of all the information set out in its application for the withdrawal of funds.
- The Company has the right to refuse the Client’s request for withdrawal, if the Client uses the same crypto currency for withdrawal and depositing, but with different wallet details.
- The Company reserves the right to deduct from the account an amount paid to the Client in compensation. Please refer to the Bonus and Awards policy.
- In case the settlement system stops operating for some time, the Company has the right to postpone the date of withdrawal until the settlement system resumes working.
- The Company undertakes to take any and all expedient actions to preclude any illegal operations and fraud with the employment of the Company’s resources.