1. GENERAL PROVISIONS
1.1. These Regulations on Non-Trading Operations (the "Regulations") have been developed within a framework of international cooperative measures aimed at combating financial misconduct, exposing and preventing violations of the law, and establishing the procedure for performing non-trading operations on a Client Account. (hereinafter referred to as the Company or Aron Broker).
1.2. “Non-trading operation” shall mean any operation performed by the Client that involves the depositing of funds to their Client Account, the withdrawal of funds ‘from their Client Account, or the internal transfer of funds between Client Accounts. The terms and definitions applicable to these Regulations are specified in Clause 1 of the Client Agreement, which can be found in the “Account Opening Agreements” subsection, located in the “Policies and Regulation” section on the Company Website. In cases where certain provisions of these Regulations concerning non-trading operations contradict those in the Client Agreement or the Terms of Business, the provisions of these Regulations shall prevail. This provision does not render other terms of the aforementioned documents invalid.
1.3. Requests for non-trading operations can only be sent by the Client to the Company. All other means of communication specified in Clause 3 of these Regulations are intended for further supporting correspondence between the Company and the Client and notifications to the Client by the Company.
1.4. When registering on the Company Website, the Client undertakes to provide accurate and authentic information to identify themselves in accordance with the requirements of the Client Registration Form on the Company Website and these Regulations. The Client shall inform the Company of any changes to their identification data in a timely manner.
1.5. The Company reserves the right to request the following documents at any time in order to verify the Client’s identity as an individual person:
a. Proof of legal existence issued by the local government. A high-resolution scanned copy or photo of the Client’s passport pages or any other national ID that clearly indicates the Client’s full name, date and place of birth, passport number, dates of issue and expiry, issuing country, and the Client’s signature;
b. Proof of address. A high-resolution copy or photo of a: utility bill (water, electricity, phone bill) issued within the last 6 months; bank statement (for a current account, deposit account or credit card account); bank reference letter confirming the Client’s address.
1.8. The Company shall have the right to amend at its sole discretion the terms of these Regulations at any time giving the Client 3 (three) business days' prior notification in one or several of the ways described in Clause 3.1 of these Regulations. Such amendments will come into effect on the date specified in the notification.
1.7. These Regulations are transparent and are an integral part of the Agreement concluded between the Company and the Client.
1.8. The Client guarantees the legitimate origin, lawful possession and right to use the funds transferred by the Client to the Client Accounts and such representation is deemed made each time such a transfer is being made.
1.9. The content of these Regulations shall be disclosed without limitation upon the request of any interested party.
2. SUSPICIOUS NON-TRADING OPERATIONS
2.1. The Company may declare a non-trading operation suspicious in cases including, but not limited to:
a. exposure of abuse of funds transfers without using the Company’s services (without completing trading operations on the trading account);
b. revelation of the unusual nature of operations that do not have obvious economic substance or obvious legal purpose;
c. revelation of circumstances providing grounds to believe that the operations are being performed for the purpose of money laundering or financing terrorism;
d. failure of the Client to provide proof of identity or other documents for verification, as well as the submission of inaccurate information by the Client;
e. inability to contact the Client using their registered email address and telephone number;
f. failure of the Client to provide proof of the identity of a beneficiary, i.e. a person for the benefit of whom the Client acts (in particular, on the basis of an agent contract, commission, and trust management contracts, while carrying out non-trading operations);
g. submission of counterfeit or invalid documents.
2.2. The Company can declare a non-trading operation suspicious on the basis of analysis of the nature of a non-trading operation, its components, attending circumstances, and interaction with the Client or the Client’s representative.
2.3. The Company reserves the right to investigate the nature of any suspicious non-trading operations listed in Clause 2.1 of these Regulations, whereupon such operations will be suspended until the reasons for their occurrence are ascertained and the investigation is complete.
2.4. During the course of an investigation, in accordance with Clause 2.3 of these Regulations, the Company shall have the right to request that the Client provide proof of their identity, proof-of-payment documents, and other documents confirming the lawful possession and legitimate origin of the funds transferred to the Client’s Account.
2.5. If suspicious non-trading operations should be exposed, the Company shall have the right to:
a. refuse to perform these operations by rejecting the respective request;
b. limit funds deposits and/or funds withdrawals to/from the Client’s Account, in any way, at the Company’s discretion;
c. return funds previously deposited to the Client’s Account to the source from which the deposit was made;
d. write off any compensated commissions or bonuses credited to the Client for operations performed by the Client; e. terminate relations with the Client.
2.6. In the case of refusal to perform suspicious non-trading operations or the termination of relations with the Client as a result of suspicious non-trading operations performed by the Client, the Company shall not be held liable for any breach of contract with the Client.
3. COMMUNICATIONS
3.1. In order to communicate with the Client, the Company may use: a. the MetaTrader trading platform internal mail;
b. email;
c. telephone;
d. post;
e. news in the “Company News” subsection, located in the “About Us” section on the Company’s website;
f. notifications
3.2. Should the need arise for the Company to contact the Client promptly regarding non-trading operations, the Company will use the contact details specified by the Client during registration or updated by the Client in accordance with Clause 3.4 of these Regulations. The Client agrees to accept notifications from the Company at any time.
3.3. Any correspondence sent to the Client (documents, notifications, confirmations, news, statements, etc.) is considered to have been received:
a. if sent by email, within 1 (one) hour after emailing it;
b. if sent by trading platform internal mail, immediately after sending it;
c. if sent by telephone, once the telephone conversation has ended;
d. if sent by post, 7 (seven) calendar days after posting it;
e. if posted on the “Company News” subsection, located in the “About Us” section on the Company’s website, immediately after the news is published;
f. if in AronPanel, immediately after the notification is published.
3.4. The Client shall notify the Company in a timely manner of any change in his contact details either by updating the information in AronPanel or by any other method offered by the Company.
3.5. The Client understands and accepts that the Company reserves the right to unilaterally terminate relations with the Client should the Client behave inappropriately when communicating with a Company employee.
3.6. Every non-trading operation by a Client shall be confirmed by a log in the “Transfer History” of AronPanel. If the Client has reason to believe that the log is inconsistent, the Client shall have the right to lodge a complaint in accordance with Chapter 7 of these Regulations.
3.7. If the Client has reason to believe that there has been a mistake in their own favour in the log, the Client is obliged to inform the Company about the mistake as soon as possible using the contact information provided on the “Contact us” subsection, located in the “About Us” section of the Company’s website.
4. PAYMENTS POLICY
4.1. Funds deposits to a Client Account and funds withdrawals from a Client Account may only be performed via the deposit and withdrawal methods available in AronPanel. Commission fees as well as other charges for each deposit and withdrawal option are published in AronPanel and on the Company Website and may periodically be changed by the Company.
4.2. The Client understands and accepts that any commissions or other charges incurred by the transfer of funds shall be at the Client’s expense. The Company shall not charge any additional commission for funds transfers, except for the commissions and other expenses specified in these Regulations.
4.3. The deposit of funds to a Client Account shall be carried out on the basis of a funds deposit request. The withdrawal of funds from a Client Account shall be carried out on the basis of a funds withdrawal request. The transfer of funds from one of a Client Account to another shall be carried out on the basis of an internal funds transfer request.
These requests shall be processed by the Company within 1 (one) business day, but not later than at the end of the business day following the day on which the request was received (or, in the case of deposits, following the day on which the funds were credited to the Company Account) whereby no additional information or document is needed.
4.4. Requests for non-trading operations such as deposit requests, withdrawal requests, and internal funds transfer requests shall be submitted by the Client in AronPanel and shall be considered as accepted by the Company if they are displayed in the “Transfer History” of AronPanel and in the Company records of Client requests.
4.5. The Company shall credit the sum received on the Company Account to the Client’s Account.
4.6. If Funds deposit / withdrawal is different from the Client Account currency, the transfer amount shall be converted into the transfer currency at the exchange rate as published in AronPanel.
4.7. Exchange rates are published in AronPanel and are periodically updated by the Company.
4.8. Currencies accepted by the Company for crediting Client Accounts, as well as currencies available for transfer to the Client's External Account, depending on the funds transfer method, are shown in AronPanel.
4.9. The Company shall have the right to set restrictions on the minimum and maximum transfer amounts, which may vary depending on the direction, method, and currency of transfer.
4.10. The Company shall have the right to set restrictions on the maximum number of withdrawal requests and internal funds transfer requests that can be submitted in one Client’s AronPanel every 24 hours. These restrictions are published in AronPanel and may be changed by the Company from time to time.
4.11. In the event that funds are returned to the Company Account after being transferred to the Client on the basis of their withdrawal request, the funds shall be credited to the Client’s Account in the same amount credited to the Company Account, while any commissions or other charges incurred by the returning of funds shall be at the Client’s expense and shall be paid by deducting them from the amount re-credited to Client’s Account.
4.12. If funds are transferred as a deposit to a Client Account via Exchange, the Company shall not have any responsibility for responding to the customer until the deposited amount is added. Also, the Company has no obligation about the Exchange.
4.13. the Company has no obligation about an Electronic Payment System If funds transferred as a deposit to a Client Account through an Electronic Payment System, Due to the fact that the Company does not have any business partners so the introduced Electronic Payment Systems are only to provide a payment solution, make sure that the desired service works correctly.
4.14. If funds transferred to the Client’s External Account through an Electronic Payment System or through a bank card transfer are not credited to the Client within 3 (three) business days of the withdrawal request acquiring “Processed” status, the Client shall have the right to request that the Company makes an inquiry into the transfer. The Company may provide the Client with a screenshot or an assigned reference number of the bank card transaction, confirming the transfer of funds to the Client’s External Account.
4.15. The Client understands and accepts that the inquiry and request for documents, may involve paying commission, which shall be at the Client’s expense. The payment method for such expenses shall be determined on an individual basis and may be carried out by transferring the necessary amount to the Company Account or by deducting the amount from the Client’s Account.
4.16. In the event that a Company employee makes a mistake when carrying out a transfer, which results in funds not being credited to the Client’s External Account, any expenses incurred in resolving the situation shall be at the Company’s expense.
4.17. In the event that the Client makes a mistake when filling out the withdrawal request form which results in funds not being credited to the Client’s External Account, any expenses incurred in resolving the issue shall be at the Client’s expense.
4.18. The Client agrees that the Company has the right to unilaterally collect arrears on a Client Account from funds held on any of the Client’s other Accounts in AronPanel, or from another AronPanel account if the Company believes that there is a connection between this AronPanel account and the Client.
4.19. The transfer of funds to the Company Account and funds withdrawals from Client Accounts shall meet the requirements and take into account the restrictions established by these Regulations, by current legislation, and other legal acts of countries within the jurisdiction of which the funds transfer takes place.
4.20. The Company has the right to restrict the Client’s ability to conduct non- trading operations (as well as to suspend the execution of requests submitted by the Client) until the situation has been resolved, in the following cases:
in the event that the Client breaches Clause 18.1 of the Client Agreement;
in order to rectify the consequences of a non-market quote;
in the event of a technical failure occurring at the Company or at an authorized Company Agent.
4.21. In the event that a Client Account falls into arrears, the Company retains the right to suspend any of the Client’s withdrawal and internal account-to-account transfer requests including requests that were already made before the Client Account fell into arrears - until the Client has paid off the arrears in full.
5. FUNDS TRANSFER OPTIONS
5.1. Electronic payment system
5.1.1. The Client may make transfers via an Electronic Payment System (hereinafter, “EPS”) to deposit funds to a Client Account and withdraw funds from a Client Account at any time, provided that this payment method is supported by the Company at the moment the transfer is executed.
5.1.2. The Client may only perform an EPS transfer through the Client’s personal account registered with the EPS.
5.1.3. The Client shall be obliged to check the details of the Company Account in AronPanel before carrying out an EPS transfer in cases where the transfer is not executed automatically from AronPanel.
5.1.4. The Company shall transfer funds to the Client's EPS account in accordance with the details provided in the withdrawal request.
5.1.5. The Client agrees that the Company is not responsible for the fund transfer time, the service policy and the technical problems (such as service interruption) in the relevant EPS.
5.1.7. The Client understands and accepts that the Company shall not be held responsible for the time required to execute the transfer, for the EPS’s terms of service, or for circumstances resulting in technical failure during the execution of transfers when the fault lies not with the Company, but with the EPS.
5.2. Internal funds transfer
5.2.1. The Client may submit an internal funds transfer request at any time provided that this method is supported by the Company at the moment the transfer is executed.
5.2.2. The Client may submit an internal funds transfer request to another Client Account in AronPanel. Internal funds transfer requests to the accounts of third parties shall not be accepted by the Company.
5.2.3. Upon performing an internal funds transfer from a Client’s account to which a deposit has previously been made via bank card or EPS, withdrawal restrictions shall be placed on the Client Account to which the funds are being transferred.
5.2.4. In the event that a Company employee makes a mistake when carrying out an internal transfer that results in funds being credited to the wrong account, the sum indicated in the request shall be returned to the Client at the Company’s expense.
5.2.5. In the event that the Client makes a mistake when filling out the internal funds transfer request that results in funds being credited to the wrong account, the sum indicated in the request shall not be returned to the Client.
5.3.bank transfer
5.3.3. Before carrying out a bank transfer to deposit funds, the Client shall download Bank Details. The Company bank details, purpose of payment, and the due date should be observed carefully by the Client. In the event that the Client cannot make a transfer with the specified purpose of payment in the Bank Details, the Client must contact the support Department to address this issue on an individual basis.
5.3.4. The Company shall have the right to reject the deposit of funds transferred by bank transfer to the Company Account in cases where the specified purpose of payment has been changed or in cases where funds have been transferred by a third party on the Client’s behalf. In such cases, the Company shall return the funds to the bank account from which they were transferred. All costs incurred by returning such transfers shall be at the Client’s expense
5.3.5. The Client may submit a withdrawal request via bank transfer only to bank accounts registered in the Client’s name.
5.3.6. The Company shall transfer money to the bank account of the Client in accordance with the details provided in the withdrawal request.
5.3.7. The Client understands and accepts that the Company shall not be held liable for the time required to execute transfers, the terms of execution by the card’s issuing bank, or for circumstances resulting in a technical failure during the transfer’s execution when the fault lies not with the Company.
6. AronPanel
6.1. The Client accepts the provisions of these Regulations concerning the use of AronPanel and consents to being subject to the obligations contained herein.
6.2. AronPanel is password-protected and the Client confirms and accepts that AronPanel is accessible only by using a password.
6.3. The Client accepts full responsibility for the security of their password and its protection from unauthorised access by third parties including Company employees. If ever Client gives access of their password to a third party, the latter should change the password with immediate effect.
6.4. All instructions completed through AronPanel after entering the password are considered to be executed by the Client.
6.5. Any party who has gained access to AronPanel by entering the password shall be considered to be the Client.
6.6. The Company shall not be responsible for any losses incurred as a result of theft, loss or disclosure of the password to third parties.
6.7. The Client shall have the right to change their AronPanel password independently or by following the password recovery procedure.
6.8. The Client can see the following deposit request statuses in the “Transfer History” section of AronPanel:
a. the “Processing” status means that the funds are waiting to be transferred to the Client’s Account;
b. the “Successful” status means that the funds have been deposited to the Client’s Account.
c. The “Denied” status means that the request has been denied. The reason for the request being denied is shown in the details of the transfer.
6.9. The Client can see the following withdrawal request and internal funds transfer request statuses in the “Transfer History” section of AronPanel:
a. the “Processing” status means that the request has been received by the Company;
b. the “Successful” status means that the funds have been transferred to the Client’s External Account that was specified in the request or that the funds have been deposited to another of the Client’s accounts in the case of an internal funds transfer;
c. the “Denied” status means that the request has been denied. The reason for the request being denied is shown in the details of the transfer.
6.10. Deposit requests, withdrawal requests, and internal funds transfer requests may be cancelled by the Client before they are executed.
6.11. Deposit request, withdrawal request, or internal funds transfer request may be rejected by the Company provided the Company specifies a reason for the rejection.
7. COMPLAINTS HANDLING AND PROCESSING/ENQUIRY
7.1. Complaints Handling and Processing
7.1.1. In the event that a dispute arises from a Client’s non-trading operations, the Client shall have the right to lodge a complaint with the Company or send a request for an inquiry. Such complaints and requests should be received by the Company within 7 (seven) business days of the situation occurring. Please refer to the Complaint Handling Policy for explicit understanding.
7.1.2. When lodging a complaint, the time at which the dispute arose shall be considered as the moment when the log appeared in the “Transfer History” section of AronPanel. Please refer to the Complaint Handling Policy.
7.2. Enquiry
When sending an enquiry into the transfer, the time at which the dispute arose shall be considered the moment as described in Clauses 4.15 and 4.16.
7.2.1. To file a request for an enquiry into a funds transfer, the Client shall:
a. complete the standard form. All requests filed through any other method (forum, email, telephone, etc.) shall not be taken into consideration; and
b. attach the following documents:
for an enquiry into a bank transfer: attach a SWIFT copy confirming the bank transfer’s execution;
for an enquiry into an EPS transfer; attach a screenshot of the transfer or payment notification in the payment system, confirming that the transfer has been made to the Company Account;
for an enquiry into a bank card transfer; attach a proof-of-identity document and a copy of the bank card.
7.2.2. To file an enquiry regarding non-trading operations, the Client should complete the standard form in AronPanel. All enquiries filed through any other method (forum, email, telephone, etc.) will not be taken into consideration.
7.3. Any enquiry or request filed in accordance with Clauses 8.2.1 and 8.2.2 is automatically assigned a unique number (TID). The Client shall be sent an email from the relevant Company department address.
7.4. The enquiry must not include:
a. an emotional assessment of the situation;
b. offensive language;
c. obscenities or expletives;
d. threats.
7.5. The Company shall have the right to request that the Client provide additional documents to hold an enquiry.
7.6. The Company shall have the right to refuse a Client’s enquiry regarding non- trading operations in the following cases:
a. where the enquiry was not made in accordance with Clauses 7.2.1 and 7.2.2 of these Regulations;
b. where the Client initiates a non-trading operation by way of internal account-to-account transfer to another account in the Client’s AronPanel using funds that were credited to the Client’s Account by way of a non- trading operation currently under dispute, or where the Client initiates a trading operation using funds that were credited to the Client’s Account by way of a non-trading operation currently under dispute;
c. in other cases, set out in these Regulations, the Client Agreement, or any of the other Regulatory Documents that can be found in the “Policies and Regulation” section of the Company Website.