Terms & Conditions

Introduction

This agreement is a legal contract between A5 Markets (referred to as “A5 Markets,” “us,” or “we”), its successors and assigns, and the party/parties (referred to as the “Customer,” “client,” or “you”) executing this document. Along with our Risk Disclosure Statement and Privacy Policy, this document outlines the terms and conditions under which A5 Markets will conduct business with the Customer. By accepting these terms and completing the application form, both parties agree to be bound by these conditions.

By opening an account with A5 Markets to trade in Forex, Contracts for Differences (CFDs), and other products or services that A5 Markets may offer, the Customer acknowledges that they have been informed of and understand the risks involved in trading in the Over-the-Counter (OTC) and/or Spread Betting markets. This understanding includes the information provided in the Risk Disclosure Statement that the Customer has received.

In consideration of A5 Markets agreeing to provide services for trading in Forex, CFDs, Options, and Spread Betting in commodities, currencies, metals, indices, and other financial products, the Customer agrees to the rights and obligations governing the relationship between A5 Markets and the Customer. These terms will apply to all transactions, including purchases or sales made on behalf of the Customer’s account(s).

1. PRINCIPLES OF INTERACTION

1.1. Trading Accounts
A5 Markets offers various types of Trading Accounts, each with distinct features and characteristics. The Company reserves the right to modify the features and eligibility criteria of these accounts or make any account type unavailable at any time. Any such changes will be communicated via our Website, email, or Trading Platform in advance.

1.2. Principal Relationship
Unless agreed otherwise in writing, the Client will engage with A5 Markets as a principal and not as an agent or representative of another party. This means that, unless specifically agreed, A5 Markets will consider you, the Client, as the primary party responsible for fulfilling obligations under any contract entered into, whether directly with A5 Markets or through an agent.

1.3. Acting on Behalf of a Principal
If the Client is acting on behalf of a third party, whether or not the Client discloses this, the third party will not be considered a Client of A5 Markets. A5 Markets will only have a contractual relationship with the Client and will not be obligated to engage with any principal unless otherwise agreed upon to meet specific requirements.

1.4. Execution-Only Basis
Unless otherwise agreed in writing, A5 Markets will interact with the Client on an execution-only basis. This means that A5 Markets will execute orders as directed by the Client without providing any advisory or decision-making services.

1.5. Right to Refuse Service
A5 Markets reserves the right to refuse service to the Client at any time. The Client acknowledges that A5 Markets is under no obligation to provide any reasons for such a decision.

1.6. Tax Responsibility
A5 Markets does not act as a tax agent. The Client is solely responsible for managing their own tax obligations, including submitting all necessary documents, tax returns, and reports to relevant authorities, whether governmental or otherwise. The Client is also responsible for paying all taxes arising from any transactions or income generated through trading.

1. Placing an Order

1.7. Trading Platform Access
The Trading Platform provides the Client access to the Trader’s Room. All orders must be placed through the Trading Platform. We do not accept orders or instructions via any other means unless agreed in advance. We are not liable for any interruptions in communication before we receive your order through the Trading Platform.

1.8. Responsibility for Orders
We are entitled to act on any order or instruction transmitted using your username, Trading Account number, or password.

1.9. Order Validation
Any order or instruction sent via the Trading Platform will be considered received and valid unless exceptional circumstances prevent it from being processed. Orders become a binding contract only once accepted by the Company and confirmed via the Trading Platform.

1.10. No Automatic Binding Contract
The transmission of an order does not automatically create a binding contract. Orders are subject to A5 Markets accepting the offer, and only when the Company has confirmed and recorded the acceptance of the order will it become binding. If you expect a confirmation for a transaction but do not receive it, you are responsible for contacting us.

1.11. No Liability for Delays or Errors
We are not responsible for any delays or errors in the transmission or execution of orders, except to the extent required by law.

1.12. Shared IP Addresses or Devices
In exceptional cases, if different clients use the same IP address or device, orders placed from this IP address or device may be considered as those of a single client.

2. Trading Account

2.1. Registration and Account Opening
To begin using A5 Markets, the Client must register on the Trader’s Room by providing an email address, which must be confirmed. The Trader’s Room provides all necessary data to manage your Trading Account.

2.2. Account Verification
After registering in the Trader’s Room, the Client can open a Trading Account. The registration process requires completing the verification procedure, which includes submitting personal information and KYC documents.

2.3. Accuracy of Information
The Client warrants that all information provided to A5 Markets is correct. The Client agrees to notify the Company of any significant changes, including changes to contact details or financial status, immediately.

2.4. Notification of Changes
If personal data changes or identification documents expire, the Client must notify the Company within three (3) business days. Notifications should be sent to support@a5markets.com from the email used during registration. The Company may request additional verification documents to comply with Anti-Money Laundering Legislation.

2.5. Username and Password Security
Upon registration, the Client will create a unique username and password for accessing the system. These credentials are personal and confidential. The Client is solely responsible for safeguarding this information and is liable for all actions performed in the Trading Account. If there is unauthorized use of your account or a security breach, you agree to inform A5 Markets immediately.

3. Deposit and Withdrawals

3.1. Deposit and Withdrawal Methods
The Client may deposit and withdraw funds into the Trading Account at any time during the Client Agreement using the payment methods available in the Trader Area. Minimum deposit and withdrawal requirements, as well as any commissions or fees, can be found in the Trader Area. The Company does not accept third-party or anonymous payments to the Trading Account.

3.2. Payment Method Consistency
The Client must use the same payment method for withdrawals as was used for deposits, unless the Company agrees otherwise, at its discretion.

3.3. Refusal of Deposits and Withdrawals
The Company reserves the right to refuse any deposit or withdrawal operation if the email, phone number, identity, address, or other provided or collected information is not fully verified or up to date, as per the Company’s discretion.

3.4. Deposit Processing
Upon receiving a deposit, the Company will credit the relevant Trading Account with the actual amount received as soon as possible after the amount is cleared in the Company’s account.

3.5. Withdrawal Processing
The Company will process withdrawal requests from the Trading Account without undue delay. However, withdrawals may take longer than expected for various reasons, some of which may be within the Company’s control and others not.

3.6. Withdrawal Restrictions
Withdrawals will only be processed to the Client’s own account. The Company does not permit withdrawals to third parties or to anonymous accounts.

3.7. Minimum Deposit and Withdrawal Amounts
The Company may set minimum deposit and withdrawal amounts in accordance with the payment service provider’s requirements. The minimum and maximum deposit/withdrawal amounts are specified on the payment form. The Client should ensure the requested withdrawal amount meets the minimum required for the chosen withdrawal method before submitting a request.

4. Conflicts of Interest

4.1. Conflict Management
The Company may need to implement arrangements to manage conflicts of interest between the Company and its clients, or between clients. The Company will take reasonable steps to avoid such conflicts. If conflicts cannot be avoided, the Company will disclose the nature and source of the conflict to the Client. The Company ensures fair treatment of clients, maintaining integrity and protecting their interests at all times.

5. Margin Leverage Levels

5.1. Margin Requirement and Leverage
The Company requires a Margin deposit to secure the Client’s liability for any potential losses in a transaction. The “Leverage Level” refers to the ratio of Margin to the market value of the open position. By accepting this Agreement, the Client acknowledges and accepts the Leverage Levels, as provided on the Company’s website. The Company may alter the Leverage Level of the Client’s account based on factors such as deposit, Margin amount, and credit exposure.

5.2. Margin Adjustments
Margin requirements or Leverage Levels can be changed at the Company’s discretion, without prior notice, in order to cover any realized or unrealized losses arising from Transactions. The Client may request a change in leverage at any time, but the Company retains the discretion to modify leverage, with or without the Client’s consent, based on risk parameters. Any such changes will be communicated to the Client.

5.3. Maintaining Margin
The Client is responsible for ensuring that sufficient funds are maintained in the Trading Account to meet all Margin requirements. The Company is entitled to treat any assets deposited by the Client (other than those for safe custody) as collateral against the Margin requirements. Only funds received, net of any transfer-related bank charges, will be credited.

5.4. Margin Monitoring
The Client acknowledges the responsibility for monitoring the Margin on their account.

5.5. Account Type Changes
The Company reserves the right to change the Client’s account type based on the total Margin deposits and the current balance of the Client’s trading account.

6. Communication Between Client and the Company

6.1. Primary Communication Method
Communication between the Company and the Client will primarily be electronic via the Company’s website and online trading platforms.

6.2. Contacting the Company
Any notices, instructions, requests, or communications from the Client must be sent via email to support@a5markets.com, unless otherwise specified.

6.3. Language of Communication
All notices and information provided by the Company or received from the Client must be in English.

7. Complaint Handling Procedures

7.1. Internal Dispute Resolution
The Company has established an internal dispute resolution system for addressing complaints or concerns. Clients who are dissatisfied with any aspect of the service should contact the Customer Support Department at support@a5markets.com.

7.2. Review of Complaints
Despite any timeframes, the Company will review and address complaints submitted outside the specified periods, in its commitment to treating clients fairly.

8. Confidentiality

8.1. Confidential Information
The Company treats all information about the Client as confidential and will only use it in connection with the provision of services. Confidential information will be kept private unless it is in the public domain.

8.2. Company Intellectual Property
The Client acknowledges that the Company’s intellectual property (IP) is confidential and was developed through substantial investment in time, skill, and resources.

8.3. Protection of IP
The Client agrees to protect the confidentiality of the Company’s IP and not grant website access to any third parties.

8.4. Restrictions on Use of IP
The Client will not publish, distribute, or share any information derived from the Company’s IP or relating to it. The Client will not copy, modify, de-compile, reverse engineer, or create derivative works from the Company’s IP or the manner in which it operates.

9. RECORDING OF TELEPHONE CONVERSATIONS

9.1. The Client agrees to the electronic recording of any telephone conversations with the Company, whether or not a disclosure is made at the time of each call. These calls may be recorded with or without an audible tone;
9.2. The Company may record and retain all electronic communications with the Client, including, but not limited to, communications via email or through the Trading Platform, with or without further notice during the communication;
9.3. The recordings, transcripts, or electronic communications from such recordings may be used for any purpose, including, but not limited to, use as evidence in any dispute between the Client and the Company, staff training, and monitoring compliance with regulatory and contractual obligations;
9.4. All recordings are the property of the Company and may be used in instances, including but not limited to, disputes, and shall serve as conclusive and binding evidence.

10. RULES OF TRADING

10.1. The Client agrees to abide by the following rules when using the Company’s Services:
10.2. The Client must not reverse engineer, bypass, or attempt to avoid any security measures on the trading platform;
10.3. The Client must not use any software, artificial intelligence, high-speed trading algorithms, or mass data entry tools to manipulate, abuse, or gain an unfair advantage on the platform;
10.4. The Client must not enter into trades that manipulate the platform, such as simultaneously placing buy and sell orders for the same or similar products at the same time;
10.5. The Client must not engage in transactions that manipulate the trading platform, including holding long and short positions in the same or similar instruments at the same or similar times, whether acting alone or in concert with others, including between related accounts or across different entities of the Company;
10.6. The Client must not engage in unfair, abusive, manipulative, or illegal practices when using the Company’s Services, such as scalping;
10.7. The Client must not exploit errors in prices or execute trades at off-market prices;
10.8. The Client must not place orders that violate exchange rules or securities/commodities laws, regulations, or rules, or are intended to defraud or manipulate the market;
10.9. If the Client profits from breaching the above rules, the Company may withhold those funds or deduct them from the Client’s account;
10.10. Any breach of the above rules will be recorded, and the Company may cancel the Client’s orders, freeze or block the Client’s account, and/or terminate the Agreement.

11. REQUIRED DOCUMENTS (KYC)

11.1. The Company requires certain documents to ensure the integrity of sensitive data, including account information and transactions. These documents are necessary for security measures when depositing funds:
11.1.1. A copy of a valid passport with the signature page, Government-issued ID card, or Driving License;
11.1.2. A recent utility bill in the Client’s name and address.
11.2. Optional – Additional documents may be requested to verify the Client’s identity and the source of funds in case of suspected fraudulent activity:
11.2.1. Copies of the credit card(s) used for the deposit (front side showing only the last 4 digits, back side with CVV covered);
11.2.2. A signed history of online transactions.
11.3. For any questions, the Client can contact customer support at support@a5markets.com.

11.4. The Client must provide all required documents promptly to avoid delays in processing transactions. The Company may require the documents before processing deposits, trades, or withdrawals. If the required documents are not received, any pending withdrawals will be canceled and credited back to the trading account, with notification via the system.
11.5. The Client must scan or take high-quality pictures of documents and upload them via the trader’s room or send them to support@a5markets.com.

11.6. The Company ensures that personal data is protected from unauthorized access, alteration, destruction, or misuse. Strong security measures are in place to prevent data breaches.

12. FEES AND CHARGES

12.1. The Client agrees to pay all charges related to the Services provided under the Client Agreement (“Costs”). These Costs are outlined on the Website, in the Trader Area, or communicated to the Client through other means.
12.2. Trading operations may incur Trading Spreads charged at the opening, during, or closing of such trades.
12.3. Costs, including commissions, spreads, and other fees, are payable by the Client as specified on the Website or in the Contract specifications.
12.4. The Company reserves the right to change any Costs without prior notice, with changes displayed on the Website, in the Trader Area, or communicated through other means.
12.5. The Client agrees to cover all expenses related to the Client Agreement and any necessary documentation for completing transactions.
12.6. Costs may include, but are not limited to:
12.6.1. Transaction charges, including trading commissions, swap fees, margins, taxes (excluding income tax or penalties), and any other amounts due under the Client Agreement.

13. INTELLECTUAL PROPERTY

13.1. The content of the Trading Platform, software, Website, and mobile application, including all copyrights, trademarks, patents, logos, graphics, and software code, is protected by international copyright and trademark laws. Except for third-party content, all materials within the Online Trading Facility are original works owned by the Company or its licensors.

14. LIMITATION OF LIABILITY AND INDEMNITY

14.1. The Company is not liable for:
14.1.1. Losses arising from system errors, technical malfunctions, or network failures;
14.1.2. Losses due to unauthorized use of the Trading Platform or the Client’s account;
14.1.3. Losses resulting from litigation or actions that place the Company in an adversarial position;
14.1.4. Losses from inaccurate information on the Website, Trading Platform, or software;
14.1.5. Losses caused by events beyond the Company’s control, such as government restrictions, strikes, or natural disasters.
14.2. The Client agrees to indemnify the Company from any loss, liability, or claims arising from their use of the Trading Platform.

15. TERMINATION

15.1. This Agreement remains in effect until terminated. The Client may terminate at any time with three days’ prior written notice, provided there are no open positions or outstanding liabilities. The Company may terminate the Agreement at any time with written notice. Termination does not affect prior transactions or obligations.

16. LIQUIDATION OF ACCOUNTS AND PAYMENT OF DEFICIT BALANCES

16.1. The Company may take actions such as liquidating positions or canceling orders if certain conditions arise, including:
16.1.1. Death or judicial incompetence of the Client;
16.1.2. Bankruptcy, insolvency, or failure to provide requested information;
16.1.3. Abuse of trading practices or fraud.
16.2. The Company may liquidate accounts without prior notice and may initiate hedging transactions to protect positions.
16.3. Any deficit in the Client’s account must be promptly paid by the Client, including any legal or collection costs.

17. ACKNOWLEDGMENT OF RISKS

17.1. The Client acknowledges the risks involved in trading CFDs and other derivatives, which may involve greater risk than on-exchange transactions.
17.2. Leverage products carry a high risk of loss, and the Client should understand the risks involved before engaging in trading.
17.3. The Client acknowledges the potential for loss of the entire margin deposit in leveraged transactions.
17.4. The Company does not provide investment advice and the Client is solely responsible for their investment decisions.

17.5. The Client fully acknowledges and understands that trading in Financial Instruments carries a high risk of incurring substantial losses. By engaging in such activities, the Client accepts and affirms their willingness to assume this risk.

17.6. The Client acknowledges that A5 Markets does not offer investment advice. A5 Markets does not act as a fiduciary or advisor, and expressly disclaims any obligations or duties of that nature.

17.7. A5 Markets provides margin-traded products that carry the risk of losing the entire initial deposit. Before trading such products, the Client should carefully consider their investment goals, risk tolerance, and experience level. These products may not be suitable for every investor, and the Client should seek independent financial advice if necessary.

18. ROLLOVER AND SWAPS

18.1. Positions may be subject to rollover, during which amounts will be debited or credited to your account based on interest rate differentials between currencies and/or swap rates provided by our liquidity providers. Please note that daily swap rates are not fixed and may be adjusted by A5 Markets without prior notice, in line with prevailing market conditions. It is your responsibility to monitor the swap rates for the instruments you are trading by checking the contract specifications and details available on A5 Markets’ website and trading platforms. In the event of any discrepancies, the information displayed within the trading platforms will take precedence.

19. DISCLAIMER OF WARRANTIES / LIMITATION OF LIABILITY

19.1. If the Client is an individual, they confirm that they are over the age of 18 and possess the full legal capacity to enter into this Agreement.

19.2. The Client has obtained all necessary consents, authorizations, licenses, and powers to lawfully enter into and execute this Agreement, as well as any related Transactions.

19.3. All individuals acting on the Client’s behalf in relation to this Agreement and any Transactions are duly authorized to do so.

19.4. This Agreement and each Transaction entered into are binding and enforceable against the Client, in accordance with applicable laws, and do not violate any existing obligations, regulations, or agreements to which the Client is bound.

19.5. No Event of Default or Potential Event of Default has occurred with respect to the Client.

19.6. The Client is acting on their own behalf (unless otherwise agreed in writing) and not as a trustee in entering into this Agreement and any Transactions.

19.7. Any information provided by the Client to A5 Markets concerning their financial situation or other relevant matters is accurate and not misleading in any material respect.

19.8. The Client acknowledges their financial ability to sustain the total loss of funds as a result of trading.

19.9. Unless otherwise agreed, the Client is the sole beneficial owner of all Margin transferred to A5 Markets, free from any third-party security interests.

20. MARKET RECOMMENDATIONS AND INFORMATION

20.1. The Client acknowledges that:

20.1.1. Any market recommendations, signals, or information provided by A5 Markets, its subsidiaries, affiliates, or agents, do not constitute an offer to buy or sell any financial instruments. A5 Markets does not provide investment advice.

20.1.2. Such recommendations and information are based on sources that A5 Markets believes to be reliable; however, these are not guaranteed and may be incomplete or unverified.

20.1.3. A5 Markets makes no guarantees regarding the accuracy or completeness of any market information or recommendations provided and shall not be held responsible for any loss or damage arising from reliance on such information, including the loss of margin or profits.

20.2. The Client understands that they are solely responsible for assessing the merits and risks of any trade they enter into, regardless of whether the trade is based on information from A5 Markets.

20.3. The Client acknowledges that A5 Markets, its officers, directors, affiliates, or representatives may hold positions in or may intend to buy or sell the same financial instruments discussed in recommendations provided to the Client, and that these positions may not align with the recommendations offered.

20.4. The Client understands that A5 Markets does not provide advice on the tax implications of any trading activities.

21. ANTI-MONEY LAUNDERING LEGISLATION

21.1. The Client acknowledges that the Company may require additional information from time to time to comply with Anti-Money Laundering (AML) Legislation. By opening the Trading Account or engaging in transactions, the Client agrees to provide all required information, documents, and cooperation to help the Company comply with AML/Counter-Terrorism Financing (CTF) Laws.

21.2. The Company may pass on information and documents related to transactions to comply with AML/CTF Laws or other applicable regulations without obligation to inform the Client. The Company may carry out necessary anti-money laundering checks (including checks against restricted lists, blocked persons, and country lists) and reserve the right to take action, without liability, based on these checks. For further details, please refer to the Company’s Anti-Money Laundering Policy.

21.3. The Client warrants that they are not aware of, nor suspect, that the funds used for transactions are derived from, or related to, money laundering, terrorism financing, or any illegal activities, as prohibited under applicable laws or international conventions.

21.4. Different customer profiles may present different risks. Basic Know Your Customer (KYC) checks help assess risk. For instance, near-retired individuals making regular contributions represent less risk compared to middle-aged individuals making irregular payments that do not align with their financial profile. The intensity of due diligence varies based on perceived risks, with corporate structures potentially presenting higher risks.

Product Risk

21.5. Product risk refers to the potential for the product itself to be used for money laundering. Products are categorized into three risk bands: reduced, intermediate, and increased, depending on their functionality and the sales process involved. For example, pure protection contracts are considered lower risk, while investments in unit trusts are deemed higher risk.

21.6. The geographic location of the client or the origin of business activity also influences the risk assessment. The firm will determine the required level of due diligence based on these risk factors.

21.7. The Company’s Customer Identification Program (CIP) ensures that all customers undergo the necessary identity checks. This includes verifying the customer’s identity and recording the verification methods.

Identification

21.8. Standard identification requirements vary based on the level of risk associated with the product and customer profile. For lower-risk products, standard identification includes:

• Full Name
• Residential Address

Verification

21.9. Verification must be based on reliable and independent sources, which may include documents produced by the customer or electronic verification methods. In face-to-face transactions, original documents should be presented for verification.

21.10. If documentary evidence is used for identity verification, it should ideally be issued by a government authority or court to provide higher confidence in the individual’s identity.

Suspicious Activity

21.11. If suspicious activity is detected (often referred to as “red flags”), additional due diligence will be carried out before proceeding with the transaction. If no reasonable explanation is found, the suspicious activity will be reported to the AML Compliance Committee.

Examples of Red Flags:

• Reluctance to provide information or suspicious documents.
• Transactions lacking apparent business sense or investment strategy.
• Unexplained sources of funds or frequent large transactions.
• Unusual or excessive wire transfers to unrelated third parties.

22. KNOW YOUR CUSTOMER – BASIS FOR RECOGNIZING SUSPICIONS

22.1. A suspicious transaction is one that is inconsistent with a customer’s known, legitimate activities. Recognizing such transactions requires a good understanding of the customer’s business or personal activities.

22.2. Key questions to ask when determining if a transaction might be suspicious include:

• Is the transaction size consistent with the customer’s usual activities?
• Is the transaction rational given the customer’s business or personal circumstances?
• Has the pattern of transactions changed?

Suspicious Scenarios:

• Clients who are unwilling to provide identity proof.
• Clients who place undue reliance on an introducer, possibly hiding their true identity.
• Requests for cash-related business or unclear sources of funds.

22.3. If any of these suspicions arise, it should be investigated thoroughly.

Reporting a Suspicion

22.4. If there is reason to suspect that a customer is involved in a transaction that may involve criminal proceeds, it must be reported as soon as possible in writing.

Investigation

22.5. Once a suspicion is reported, the AML Compliance Committee will conduct an investigation, which may involve reviewing payment history, addresses, and other relevant details. If necessary, a recommendation will be made to file a Suspicious Activity Report (SAR) with the appropriate authorities.

Freezing of Accounts

22.6. If the funds in an account are determined to be derived from criminal activity or fraudulent instructions, the account will be frozen. If the account holder is suspected of involvement in fraudulent activity, the account may also be frozen.

23. CONSENT TO ELECTRONIC SIGNATURE

23.1. By electronically signing the General Terms & Conditions and related documents, the Customer acknowledges receipt of the customer account letter, agreement, and other documents, and agrees to be bound by these terms.

23.2. By signing the agreement, the Customer consents to receiving electronic records of their trades and accounts from the Company.

24. AMENDING THESE TERMS AND CONDITIONS

24.1. The Company reserves the right to amend these Terms and Conditions at any time. Any changes will be effective upon publication on the website or notification via email, and will apply to all open positions and unfilled orders. If the Client does not accept the amendments, the Trading Account will be suspended, and the Client will be required to close the account.

25. AGREEMENT

25.1. This Agreement, together with all references to the Company’s policies and procedures, including the Risk Disclosure Statement and Privacy Statement, constitutes the entire agreement between the Company and the Customer, superseding any prior agreements.

26. ASSIGNMENT

26.1. The Client may not assign or transfer any rights or obligations under this Agreement without prior written consent from the Company. The Company may assign the Agreement freely.

27. GOVERNING LAW AND JURISDICTION

27.1. This Agreement shall be governed by and construed in accordance with the laws of St. Vincent and the Grenadines and any relevant local laws.

28. BINDING EFFECT

28.1. This Agreement remains in effect for all accounts opened or reopened with the Company, regardless of changes in personnel or successors.

29. INSTRUCTIONS AND COMMUNICATIONS

29.1. The Company may require additional instructions for contracts or proposed contracts. If the Client does not respond, the Company may take necessary actions at the Client’s expense.

29.2. Communication from the Company, including account statements, may be sent electronically via email or the Trading Platform. The Client is required to provide an email address for these communications.

30. SWAP FREE ACCOUNTS (INTEREST-FREE ACCOUNTS)

30.1. If the Client observes Islamic religious beliefs and cannot receive or pay interest, they may designate their trading account as a swap-free account, as per the Company’s procedures.