Understanding of a client's background and purpose for opening an investment account may help a CIF and the Client to avoid a number of risks and correctly determine client's investment profile.
A clear Client Acceptance Policy
and relevant procedures were developed by the Company based on such key factors as a client's background, country of origin, public or high-profile position, linked accounts, business activities and origin of funds, investment services and financial instruments applied for, anticipated level and nature of business transactions, and other indicators. A new client has to submit certified copies of the documents required according to Know Your Customer
(KYC) Policy and complete relevant Investor Questionnaire
Where a client wants an investment firm simply to follow client's instruction to buy or sell an investment, a different set of protections apply. These protections are referred to as the Appropriateness test
. The test aims to protect those who may not understand or be aware of the implications and level of risk involved in a transaction, particularly where the products are 'complex'*
When client's investments are managed by an investment firm, the firm will not communicate with the client every time it makes an investment on the client's behalf; it will need to have enough information from the client at the outset to enable it to provide the client with the required service. To achieve this, the firm will carry out a Suitability test
If you do not supply the firm with adequate information it cannot provide the service of investment management to you. If you provide only limited information, this will affect the nature of the services the investment firm will be allowed to provide to you.
BEST EXECUTION POLICY
This information (Execution Policy) always constitutes integral part of an investment agreement with a client. When establishing its Execution Policy
the Company determines the relative importance of the factors related to Execution, and implements effective arrangements in order to deliver the best possible result to its clients.
The best possible result for persons classified under the Law as retail customers is determined in terms of total consideration, representing the price of the financial instruments and the costs related to execution, including the Company remuneration, fees payable to execution venues, clearing and settlement agencies and other implicit costs related to execution, if applicable.
SAFEGUARDING & SAFEKEEPING
When you place financial assets or money with an investment firm, the firm will safeguard your ownership rights by having arrangements in place to:
RAM Cyprus has opened a number of accounts for its clients, both for funds and securities safekeeping, in reputable, internationally recognized, regulated financial organizations, such as:
- keep them separate from both the firm's and other clients' assets and money;
- keep accurate records and accounts and perform regular reconciliations;
- send you a statement, as agreed (at least once a year), with details of the assets held on your behalf.
Hereby the Company notifies its potential clients of the fact that clients’ financial instruments and funds might be held in a jurisdiction outside the EU and be subject to the law of ‘third country’ jurisdiction.
- Cash accounts - in Citibank London, Citibank Moscow, and in Bank of Cyprus;
- Safekeeping Accounts - in Citibank Moscow and in Libra Capital Depository (Russia).
CONFLICT OF INTEREST
Any investment firm should act in accordance with client's best interests; and to this end, it should have in place effective arrangements to prevent conflicts from adversely affecting clients' interests (Procedures on the Prevention of Conflicts of Interest). RAM Cyprus is making all efforts in order to avoid unduly putting any other clients' interests or the firm's interests ahead of yours when providing you with a service.