Guidelines for Non-Introducing Partners on Client Onboarding

At Saxo, we are committed to maintaining the highest standards of compliance and regulatory adherence. This article outlines Saxo’s jurisdictional appetite for our non-introducing partners, including White Labels Clients (WLC), Institutional Multi Accounts (IMA), and Single Omnibus Accounts (SOA).

Jurisdictional Appetite Definition
For this article, the jurisdictional appetite refers to the countries of residence of a natural person or the domicile of a legal entity, where business relationships can be onboarded and serviced. This definition can in some instances also include other jurisdictional risk factors of a business relationship, regardless of the  country of residence or incorporation.

Individual Assessment of Controls
Non-introducing partners are generally not subject to Saxo’s jurisdictional appetite for retail clients as outlined in this help article. While Saxo’s risk appetite is based on our own controls, measures and local knowledge, partners with more targeted mitigation measures in a specific jurisdiction may be allowed use their structure with Saxo to onboard and operate outside of Saxo’s direct jurisdictional appetite. During the partner onboarding and ongoing due diligence, Saxo will assess the partner's controls, measures and local knowledge to determine if the risk of the jurisdictions involved can be adequately mitigated. Partners are expected to collaborate in full, declaring the countries in which clients are onboarded and demonstrating a robust compliance framework and controls. If compliance standards are met, partners may onboard clients from most countries, however, Saxo must be informed whenever a partner begins operating in a new country.

Prohibited Countries
Certain countries are strictly prohibited for business via Saxo regardless of the circumstances. Partners are expressly prohibited from using Saxo accounts for transactions with, for, or on behalf of residents of or legal entities domiciled in these countries. If a partner becomes aware of an end-client residing or domiciled in these countries, the partner must immediately remove the end-client’s access and inform Saxo, to enable further investigation and confirm full closure of the account.

1. Sanctioned parties
   US law and certain US Exchanges prohibit access to markets by sanctioned parties. For the purposes of this article, a sanctioned party is a person domiciled in jurisdictions subject to comprehensive economic sanctions by OFAC. They are (subject to changes): 
   • Cuba
   • Iran
   • North Korea
   • Syria
   • Sudan
   • Russia
   • Ukrainian Regions: Crimea, Donetsk, Kherson, Luhansk, Zaporizhzhia
2. Saxo’s internal policies
   Persons domiciled in the following countries are prohibited from accessing Saxo accounts:
   • Belarus
   • Northern Cyprus
   • Myanmar/Burma
   • The United States
   • Yemen

Changes to the Jurisdictional Appetite
The jurisdictional appetite is subject to change. Saxo will update this list to ensure ongoing compliance with global regulations and standards. We will keep you informed of any changes to ensure compliance with our policies.

If you have any questions or need further clarification, feel free to contact your Saxo representative. We also ask that you immediately inform us if the institution is unable to comply with these terms.

We appreciate your cooperation and understanding in adhering to these guidelines.