Hi Annie
6% is only refering to high risk clients, and has nothing to do with 6% accounting for 31% of the revenue
31% of the revenue comes from this list of businesses below - The 6% of clients (13/226 approx) would be in this 31% revenue producing group. Look back through the historical ann. Isx have signed more than 13 clients in this group. So the others are not classified as high risk.
Less than 31% of ISX’s preliminary unaudited revenue for the quarter ended 30 September 2019 was derived from regulated customers that provide banking services, contracts for difference (“CFDs”
and forex trading (“FX”
, online gambling facilities (“online gambling”
and cryptocurrency.
See defination below as referenced in the email about what slots 6% of isx business clients into the high risk group. You'll find a full copy of the IR email was posted by
@thepylee today if you need to read the full copy.
From IR Email 18-12-19
"Only 13 out of 226 (or less than 6%) of ISX’s active/approved customers are reported as being “high-risk”, per the classification requirments defined under the 4th Anti Money Laundering Directive EC 2015/849 Annex II and III1."
ANNEX II
The following is a non-exhaustive list of factors and types of evidence of potentially lower risk referred to in Article 16:
(1) Customer risk factors:
(a) public companies listed on a stock exchange and subject to disclosure requirements (either by stock exchange rules or through law or enforceable means), which impose requirements to ensure adequate transparency of beneficial ownership;
(b) public administrations or enterprises;
(c) customers that are resident in geographical areas of lower risk as set out in point (3);
(2) Product, service, transaction or delivery channel risk factors:
(a) life insurance policies for which the premium is low;
(b) insurance policies for pension schemes if there is no early surrender option and the policy cannot be used as collateral;
(c) a pension, superannuation or similar scheme that provides retirement benefits to employees, where contributions are made by way of deduction from wages, and the scheme rules do not permit the assignment of a member's interest under the scheme;
(d) financial products or services that provide appropriately defined and limited services to certain types of customers, so as to increase access for financial inclusion purposes;
(e) products where the risks of money laundering and terrorist financing are managed by other factors such as purse limits or transparency of ownership (e.g. certain types of electronic money);
(3) Geographical risk factors:
(a) Member States;
(b) third countries having effective AML/CFT systems;
(c) third countries identified by credible sources as having a low level of corruption or other criminal activity;
(d) third countries which, on the basis of credible sources such as mutual evaluations, detailed assessment reports or published follow-up reports, have requirements to combat money laundering and terrorist financing consistent with the revised FATF Recommendations and effectively implement those requirements.
ANNEX III
The following is a non-exhaustive list of factors and types of evidence of potentially higher risk referred to in Article 18(3):
(1) Customer risk factors:
(a) the business relationship is conducted in unusual circumstances;
(b) customers that are resident in geographical areas of higher risk as set out in point (3);
(c) legal persons or arrangements that are personal asset-holding vehicles;
(d) companies that have nominee shareholders or shares in bearer form;
(e) businesses that are cash-intensive;
(f) the ownership structure of the company appears unusual or excessively complex given the nature of the company's business;
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2015_141_R_0003