Risk Disclosures

RISK DISCLOSURES DOCUMENT

Important Risk Warning and Disclaimer

Figure Markets Ireland Limited (“Figure Markets Ireland”) provides the following risk disclosures to help customers independently evaluate their engagement with Virtual Asset transactions. These disclosures are for informational purposes only and do not constitute legal, tax, regulatory, or investment advice. Customers are solely responsible for assessing their financial circumstances, legal obligations, and risk tolerance before using the Services. General Considerations: Independent Advice: Customers are strongly encouraged to seek independent advice from qualified legal, tax, or regulatory professionals to assess their obligations and risks: Important: Figure Markets Ireland does not provide legal, tax, regulatory, or investment advice; Regulatory Awareness: Customers should stay informed of changes to local and international regulations that may impact the legality, use, or value of Virtual Assets or related services in their jurisdiction; and Risk Mitigation Practices: Customers are responsible for implementing appropriate risk mitigation measures, such as (but not limited to: (i) Diversifying Virtual Asset holdings; (ii) Safeguarding private keys and enabling two-factor authentication; (iii) Ensuring the security of personal devices and access credentials. No Personal Advice: Independent Decision-Making: Figure Markets Ireland is not your adviser, broker, intermediary, or agent. The company has no fiduciary responsibility to monitor your transactions or ensure their alignment with your financial goals; Limited Information Provided: Figure Markets Ireland provides factual information about its Services, transaction procedures, and associated risks. However, all decisions to use the Services or engage with Virtual Assets are the sole responsibility of the customer; and Scope of Advice Communications from Figure Markets Ireland should not be construed as investment, financial, tax, legal, or trading advice. Customers must independently assess the suitability of any activity conducted through the Services based on their financial position, risk appetite, and personal circumstances.

Figure Markets Ireland Services

Figure Markets Ireland Limited (“Figure Markets Ireland”) is committed to compliance and consumer protection. This Risk Warning outlines some of the key risks associated with using our Services. Each Service involves distinct risks, and this document provides a general description of these risks.

This Risk Warning does not address all possible risks or how these risks may relate to your personal circumstances. Before using the Services, you must fully understand the risks involved and carefully read the relevant terms applicable to the specific Services. By using the Services, you acknowledge and accept all related risks.

Regulatory Status and Compliance Information

Virtual Asset Service Provider (VASP) Registration
Figure Markets Ireland is registered with the Central Bank of Ireland (CBI) as a Virtual Asset Service Provider (VASP) for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) purposes. This registration mandates compliance with specific AML/CFT obligations, including customer due diligence, transaction monitoring, and reporting of suspicious activities.
Central Bank of Ireland

MiFID II Authorization Status
Figure Markets Ireland Limited is not authorized under the Markets in Financial Instruments Directive II (MiFID II). Consequently, the services provided are not subject to MiFID II regulations, which govern investment services and activities within the European Union.

Implications for Clients

• Service Scope: As a registered VASP, Figure Markets Ireland Limited offers services related to virtual assets. These services are distinct from those provided by MiFID II-authorized firms, which may include investment advice, portfolio management, and other financial instruments.
• Regulatory Protections: Clients engaging with Figure Markets Ireland Limited do not receive the investor protections afforded under MiFID II, such as access to the Investor Compensation Scheme or specific conduct of business rules applicable to MiFID II firms.

Clients are encouraged to:

• Understand Service Limitations: Recognize the scope of services offered and the regulatory framework governing them.
• Seek Independent Advice: Consult with qualified professionals for legal, tax, or financial advice tailored to individual circumstances.
• Stay Informed: Keep abreast of regulatory developments that may impact the use and regulation of virtual assets.

Availability Risk

Service Interruptions

While Figure Markets Ireland strives to provide uninterrupted access to its Services, certain factors, including regulatory obligations, technical issues, or market conditions, may result in temporary or prolonged service outages. Customers are advised to plan their transactions accordingly, as delays or interruptions may prevent timely access to the platform or execution of transactions.

Jurisdictional Restrictions

Figure Markets Ireland is subject to various legal and regulatory requirements that may restrict or limit the Services we can provide in certain jurisdictions. These restrictions may affect access to fiat services, trading functionality, or other features within the Exchange. Customers are responsible for ensuring compliance with applicable laws in their jurisdictions before using the Services.

Promotions and Campaigns

Promotional activities, such as campaigns, competitions, or bonuses, are not available to customers in Restricted Locations or jurisdictions where such activities are prohibited by law. Figure Markets Ireland reserves the right to limit or withdraw participation in promotions at its sole discretion.

Cross-Border Access

Customers accessing the Services from outside their primary jurisdiction must be aware of potential legal and regulatory implications, including cross-border data transfers and differing local laws. Figure Markets Ireland is not liable for any legal consequences arising from unauthorized access or use of the Services in restricted regions.

Restricted Locations

Access to Figure Markets Ireland Services is restricted in certain locations due to regulatory, legal, or operational limitations. Customers are prohibited from using the Services in the following jurisdictions:

1. Sanctioned Jurisdictions: Afghanistan, Belarus, Cuba, Iran, North Korea, Russia, Syria, Venezuela, Yemen, Zimbabwe.
2. High-Risk Jurisdictions: Bosnia and Herzegovina, Burundi, Central African Republic, Chad, Democratic Republic of the Congo, Guinea, Guinea-Bissau, Haiti, Libya, Mali, Myanmar (Burma), Nicaragua, Somalia, South Sudan, Sudan, Tunisia.
3. Jurisdictions with Crypto Restrictions: Turkey, Hong Kong, Lebanon, Pakistan, Palestine/Gaza/West Bank, Serbia, Ukraine.
4. Non-Operational Regions: Antarctica, Bouvet Island, French Southern and Antarctic Lands, Heard Island and McDonald Islands, United States Minor Outlying Islands, South Georgia and South Sandwich Islands.

This list is subject to change at Figure Markets Ireland’s discretion without prior notice based on updates to applicable laws or policies. Customers are required to consult the most recent list of restricted locations on the Figure Markets website before accessing or using the Services.

Customer Responsibility

Customers are solely responsible for determining whether their use of the Services complies with local laws and regulations. It is recommended that customers seek independent legal advice if they are uncertain about restrictions in their jurisdiction.

Data Transfers

Accessing the Services from restricted jurisdictions may involve cross-border data transfers subject to differing legal frameworks. Customers acknowledge that Figure Markets Ireland is not responsible for any legal consequences arising from unauthorized access or use of Services in restricted regions.

Promotional Activities

Figure Markets Ireland may periodically run promotions, including competitions, referral programs, or other campaigns. The availability of these promotions is subject to the following conditions:

1. Jurisdictional Limitations: Promotions are not available to customers in Restricted Locations or other jurisdictions where such activities are prohibited.
2. Eligibility: Participation in promotions may be limited to specific client types or regions, as determined by Figure Markets Ireland.
3. Withdrawal of Promotions: Figure Markets Ireland reserves the right to modify or withdraw any promotional activity at its sole discretion and without prior notice.

Customers must review the terms and conditions of any promotion to confirm their eligibility before participating.

COMMUNICATION RISKS

When you communicate with Figure Markets Ireland via electronic means, including email, chat, or other digital platforms, you should be aware of the following risks:

1. Transmission Failures: Electronic communications may fail to send, be delayed, or not reach their intended recipient due to technical or network issues.
2. Security Risks: Electronic communications are not inherently secure and may be intercepted, altered, or accessed by unauthorized third parties.
3. Responsibility for Verification: Clients are responsible for verifying the receipt of critical communications, such as instructions or confirmations of transactions. Figure Markets Ireland is not liable for any consequences arising from communication failures unless explicitly stated otherwise in the Customer Agreement.

Client Responsibility for Mitigating Risks

Clients are solely responsible for assessing and managing the risks associated with Virtual Asset transactions. While Figure Markets Ireland provides a secure platform, no system is entirely risk-free. Customers must take independent steps to safeguard their activities and ensure the accuracy of their transactions.

The following are general techniques clients may independently consider to mitigate risks. These do not constitute advice from Figure Markets Ireland, and clients remain fully responsible for their decisions:

Secure Communication: Use the secure messaging features available on the platform for sensitive communications whenever possible to reduce the risk of interception or unauthorized access.

Transaction Verification: Promptly review and verify all transaction details and confirmations to ensure accuracy and completion. Errors or discrepancies should be addressed immediately to avoid potential losses.

Counterparty Risk

When using the Services provided by Figure Markets Ireland, you may be exposed to counterparty risk in several circumstances. These include, but are not limited to:

1. Liquidity Providers and Market Makers: Issues faced by market makers or liquidity providers could result in slippage, delays, or an inability to execute trades at desired prices.
2. Payment Processors: Failures by or disputes with payment processors may delay deposits or withdrawals, affecting your ability to fund or access your account.
3. Default on Obligations: Borrowers may default on repayment obligations, particularly in lending or staking products, which could delay or prevent the redemption of assets.

Potential Outcomes of Counterparty Risks:

In exceptional circumstances, counterparty risks may adversely affect your Virtual Assets or your ability to transact with them. This could result in:

• Transactions not completing as expected or being canceled.
• Loss of trading costs or fees, which may not be recoverable.
• Inability to acquire, sell, or transfer Virtual Assets at desired times or prices.
• Loss of profits due to unforeseen delays or disruptions.

Virtual Asset Risks

Given the nature of Virtual Assets and their underlying technologies, several intrinsic risks exist, including but not limited to:

A. Technological and Protocol Risks

• Faults and Failures: Virtual Assets rely on complex protocols and technologies that may experience faults, defects, errors, or unforeseen failures. Such issues may result in total or partial loss of the Virtual Asset’s value or functionality.
• Irreversibility: Transactions in Virtual Assets are irreversible. Consequently, losses due to fraudulent, accidental, or unauthorized transactions may not be recoverable.
• Protocol Attacks: Virtual Asset protocols may be vulnerable to attacks such as denial-of-service (DoS) or exploits that disrupt their functionality or value.

B. Obsolescence and Technological Advancements

• Technological Obsolescence: Rapid advancements in blockchain and related technologies may render certain Virtual Assets or protocols obsolete, reducing their demand or value.

C. Emerging Technology and Product Risks

The Virtual Asset market is rapidly evolving, introducing novel technologies and products that carry unique risks:

• Decentralized Finance (DeFi): DeFi platforms may lack regulatory oversight, making them susceptible to fraud, technical failures, or vulnerabilities in smart contracts.
• Non-Fungible Tokens (NFTs): The value of NFTs is highly speculative and may be impacted by illiquidity, lack of standardized valuation, and evolving regulatory treatment.
• Experimental Protocols: New Virtual Asset protocols or products may lack a proven track record, increasing the risk of failure or obsolescence.

Client Responsibility: Clients should conduct thorough research before engaging with new technologies or products and should only invest funds they can afford to lose.

D. Network and Transaction Risks

• Network Congestion: High traffic or technical issues on blockchain networks may delay transaction settlement, affecting timely access to Virtual Assets.
• Settlement Risks: Transactions may fail to settle on the scheduled delivery date due to network delays or errors.

E. Blockchain Forks

• Hard Forks: Updates to a Virtual Asset’s software may lead to incompatible versions of the blockchain, creating parallel networks. These forks can decrease demand for certain Virtual Assets, adversely impacting their price.

F. Concentrated Ownership Risks

• Volatility from Large Holders: Certain blockchain addresses hold significant portions of a Virtual Asset’s supply. Sudden liquidation from these holders may trigger market volatility and price declines.

G. 51% Attack Risks

• Network Manipulation: If an entity gains control of over 51% of a blockchain network’s computing power, it could manipulate the network by double-spending or reversing transactions. While this is unlikely for major networks, such attacks would erode trust and reduce asset value.

H. Fraud and Cybersecurity Risks

• Hacking and Theft: Virtual Assets are vulnerable to fraud, hacking, and phishing attempts, potentially leading to loss of funds. Clients should adopt secure practices such as enabling two-factor authentication and using trusted wallets.

I. Lack of Investor Protections

• No External Protections: Virtual Assets purchased through Figure Markets Ireland’s Exchange are not covered by external investor compensation, deposit protection, or insurance schemes.

J. Emerging Risks in Novel Virtual Assets

• Speculative Nature: New Virtual Assets or complex transaction strategies may introduce unforeseen risks. The Virtual Asset market is inherently speculative, marked by significant uncertainty, rapid price swings, and market manipulation.

K. Regulatory and Market Risks

• Increased Regulation: Regulatory changes in jurisdictions where Virtual Assets operate may restrict their use, impacting their demand and value. Clients are advised to monitor relevant legal developments.

L. Environmental and Sustainability Risks

Certain blockchain technologies and Virtual Assets rely on energy-intensive processes, such as Proof of Work (PoW) consensus mechanisms. Key risks include:

• Energy Consumption: High energy use associated with PoW protocols may lead to increased costs or reputational risks due to environmental concerns.
• Regulatory Impact: Governments may impose restrictions or taxes on energy-intensive blockchain activities, potentially affecting the availability or value of certain Virtual Assets.

Client Responsibility: Clients should consider the environmental and sustainability implications of their Virtual Asset investments and assess whether these align with their values and risk tolerance.

Communication Risks

When communicating with Figure Markets Ireland via electronic means, customers should be aware of the following risks:

• Transmission Failures: Emails, chats, or other digital messages may fail to send, be delayed, or not reach the intended recipient due to network or technical issues.
• Security Risks: Electronic communications are not inherently secure and may be intercepted, altered, or accessed by unauthorized parties.
• Impact on Transactions: Communication failures may result in incomplete or delayed instructions, affecting transaction integrity.
• Verification Responsibility: Clients are responsible for verifying that critical communications, including transaction confirmations, have been received and executed as intended.

Currency Risks

• Currency Exchange Fluctuations: Virtual Asset transactions involving fiat or other virtual currencies may be affected by fluctuations in exchange rates, potentially leading to additional losses or gains.
• Cross-Border Transaction Risks: Differences in currency availability and exchange rates across jurisdictions may delay or affect the outcome of transactions.

Fees & Charges

When using Figure Markets Ireland Limited’s (“Figure Markets Ireland”) Services, customers should be aware of the applicable fees and charges, as these will directly affect the returns generated.

1. Fee Transparency

• All applicable fees and charges are outlined in the [Fee Schedule](insert link to fee schedule). These include, but are not limited to:
  • Trading Fees: Charges for executing buy, sell, or exchange orders on the platform.
  • Deposit and Withdrawal Fees: Costs associated with transferring funds to or from your account, including fiat and Virtual Asset transfers.
  • Inactivity Fees: If applicable, charges for accounts that remain inactive for a specified period.
  • Other Service Fees: Fees for ancillary services, such as enhanced reporting or expedited processing, where applicable.

2. Fee Changes

• Figure Markets Ireland reserves the right to update fees and charges at its sole discretion. Any changes to the Fee Schedule will be communicated in advance where required by law. Customers are responsible for reviewing the Fee Schedule regularly to stay informed of applicable charges.

3. Impact on Returns

• Fees and charges will reduce the net returns generated from transactions and investments. Customers should consider all applicable costs when evaluating the profitability of using the Services.

4. Third-Party Fees

• Customers may incur additional fees from third parties, such as payment processors, custodians, or banks, which are not controlled by Figure Markets Ireland. Such fees are the sole responsibility of the customer.

5. Currency Conversion Costs

• If transactions involve currency conversion, customers may incur additional fees or costs related to exchange rate fluctuations. These fees may vary depending on the currencies involved and the service provider used.

Legal, Regulatory, And Compliance Risks

Virtual Assets operate in a dynamic legal and regulatory environment that is subject to significant changes. Customers must carefully consider the following risks, as these factors may materially impact the value, use, and accessibility of Virtual Assets and related services.

1. Legislative and Regulatory Changes

• Evolving Legal Landscape: Laws and regulations governing Virtual Assets are rapidly evolving. Legislative changes may impact the legality, use, transfer, exchange, and value of Virtual Assets.

• MiCAR (Regulation (EU) 2023/1114): The Markets in Crypto-Assets Regulation introduces comprehensive requirements for Crypto-Asset Service Providers (CASPs), such as licensing, operational standards, and reporting obligations. Compliance with MiCAR may require modifications to the services offered by Figure Markets Ireland. Customers will be notified of material changes where required.

• Impact on Services: Legislative changes can restrict or prohibit the availability of certain Virtual Assets or services, with little or no advance notice.

2. MiCAR-Specific Compliance Risks

• Enhanced CASP Obligations: Under MiCAR, Figure Markets Ireland must meet strict licensing requirements, implement enhanced customer verification, and ensure operational security.
• Service Adjustments: Customers may experience temporary restrictions, fee changes, or delays during the transition to MiCAR compliance.
• Cross-Border Risks: MiCAR harmonizes regulations within the EU but does not eliminate risks for clients in non-EU jurisdictions where local laws may impose additional or conflicting requirements.

3. Jurisdictional and Property Risks

• Jurisdictional Restrictions: Virtual Asset services may be restricted or unavailable in certain jurisdictions due to local regulations. Customers are responsible for ensuring their use of services complies with the laws of their jurisdiction.
• Property Classification: In some jurisdictions, Virtual Assets may not be classified as “property.” This can affect legal rights, ownership, and enforceability of interests in these assets. Legislative and regulatory changes may adversely affect or restrict (as applicable) the use, transfer, exchange and value of Virtual Assets, as well as the provision of the Services in certain jurisdictions. Legislative and regulatory changes may occur quickly and without prior notice

4. Compliance Obligations

• Customer Responsibility: Customers are solely responsible for understanding and complying with applicable local laws, including tax, reporting, and regulatory requirements.
• Tax Reporting: Figure Markets Ireland may report customer transactions, transfers, and payments to regulatory authorities when required by law. Customers must meet their tax obligations and seek independent tax advice if necessary.
• Non-Compliance Risks: Failure to comply with local laws may result in penalties, service restrictions, or additional legal obligations.

5. Non-Compliance and Penalties

• Non-compliance with MiCAR or other applicable regulations could lead to:
  • Regulatory penalties against Figure Markets Ireland or its customers.
  • Temporary suspension or permanent withdrawal of certain services.
  • Limitations on access to specific Virtual Assets.

6. Service Modifications and Notifications

• Adjustments to Services: To align with MiCAR and other applicable laws, Figure Markets Ireland may:
  • Modify the availability of certain Virtual Assets or features.
  • Update terms, conditions, and fee structures.
  • Enhance disclosure requirements or transaction limits.
• Advance Notifications: Customers will be informed of material changes in advance where legally required.

7. Cross-Border and Systemic Risks

• Harmonization vs. Divergence: MiCAR seeks to harmonize crypto regulations across the EU, reducing legal uncertainty for EU clients. However, customers in non-EU jurisdictions may face overlapping or conflicting regulations.
• Systemic Risks: Events such as regulatory crackdowns, bans on Virtual Assets, or failures of key platforms can cause market-wide instability and impact the value of Virtual Assets.

8. Cross-Border Regulatory Risks

Clients engaging with Figure Markets’ services across multiple jurisdictions may encounter overlapping or conflicting regulatory requirements. Key considerations include:

• Regulatory Inconsistencies: Laws governing Virtual Assets may differ between jurisdictions, potentially impacting the legality of certain transactions or services.
• Access Limitations: Clients may face restrictions or prohibitions on Virtual Asset activities depending on local regulations.
• Reporting Obligations: Clients may have additional reporting or tax compliance requirements in their jurisdiction that Figure Markets does not oversee or facilitate.

Client Responsibility: Clients are solely responsible for ensuring compliance with applicable laws in all jurisdictions where they operate. Independent legal advice is strongly recommended for navigating cross-border regulatory challenges.

MARKET RISKS

Investing in Virtual Assets involves significant risks. Customers must carefully consider these risks before engaging in any transaction. The value of Virtual Assets can fluctuate significantly, and customers may lose all or part of their investment. Customers should only invest what they can afford to lose.

1. Speculative Nature of Virtual Assets

• Virtual Asset trading is inherently speculative. Prices are highly volatile and can change rapidly without warning, driven by factors such as:
  • Regulatory developments.
  • General economic trends.
  • Technological advancements in the Virtual Asset ecosystem.
• Market movements are unpredictable, and supply and demand for Virtual Assets may shift quickly, often with little or no advance notice.

2. Volatility and Unpredictability

• The value of Virtual Assets is subject to rapid fluctuations, which may occur at any time, including outside standard business hours.
• Virtual Asset markets operate 24/7, meaning significant price changes can happen when customers are not actively monitoring their investments.

3. Systemic and Systematic Risks

• Systemic Risks: These are industry-wide risks that may arise from the collapse or failure of major companies, exchanges, or service providers within the Virtual Asset ecosystem.
• Systematic Risks: These are broader market-wide risks that stem from external factors such as economic, sociopolitical, technological, or natural events. Both systemic and systematic risks can adversely impact the value of Virtual Assets.

4. Past Performance Not Indicative of Future Results

• Historical performance of Virtual Assets does not guarantee or predict future results. Customers should not rely on past trends as an indicator of future outcomes.
• Figure Markets Ireland does not provide any assurance or guarantees about the performance, market price, or returns of Virtual Assets available through its Services.

5. Impact of Technological Developments

• Blockchain technology is evolving rapidly, and its future growth or sustainability depends on various factors that are difficult to predict.
• Advances in technology may render certain Virtual Assets obsolete, while sustainability challenges (e.g., energy consumption or network congestion) may negatively impact Virtual Asset networks.

6. Perception and Public Sentiment Risks

• Negative public perceptions or events involving Virtual Assets may reduce investor confidence, leading to heightened volatility or significant depreciation in value.
• Events that trigger negative publicity, such as fraud, regulatory crackdowns, or environmental concerns, can have a cascading impact on the entire Virtual Asset market.

7. Investment Considerations

• Customers should:
  • Conduct independent research to fully understand the risks of investing in Virtual Assets.
  • Consider starting with small investments, particularly if they are new to Virtual Assets.
  • Regularly monitor their investments and market conditions.

Regulatory Status, Classification, and Compliance Risks

Regulatory Status of Figure Markets Ireland

Figure Markets Ireland Limited is registered with the Central Bank of Ireland (CBI) as a Virtual Asset Service Provider (VASP) for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) purposes.

As a VASP, Figure Markets Ireland complies with all applicable regulatory requirements, which include:

1. AML and CFT Obligations:
   • Conducting thorough customer due diligence, including verifying customer identity and assessing the source of funds.
   • Monitoring transactions to detect suspicious activities and reporting them to relevant authorities, such as the Financial Intelligence Unit (FIU).
2. Regulatory Reporting:
   • Submitting required reports to the CBI in accordance with Irish law.
3. GDPR Compliance:
   • Ensuring secure processing, collection, and storage of customer data, including for AML purposes, under the General Data Protection Regulation (GDPR).

MiCAR Transition and Compliance Dependencies

Figure Markets Ireland operates in an evolving regulatory environment shaped by Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCAR). The regulation introduces harmonized rules for Crypto-Asset Service Providers (CASPs) across the EU, applicable from December 2024.

As part of its transition to MiCAR compliance, Figure Markets Ireland:

• CASP Licensing:
  • Will obtain licensing under MiCAR, which extends beyond current VASP requirements to include stricter operational, reporting, and customer protection standards.
• Service Adjustments:
  • Some products, services, or features may need to be modified or temporarily suspended to align with MiCAR requirements. Customers will be notified in advance of any material changes, as required by law.
• Customer Impact:
  • Enhanced disclosures, stricter verification processes, and possible changes to fees or transaction limits may arise as part of MiCAR compliance.

MiFID II Classification and Risks

Under the Markets in Financial Instruments Directive II (MiFID II), Figure Markets Ireland classifies clients as retail clients, professional clients, or elective professional clients. This classification determines the level of regulatory protection provided to customers and carries associated risks.

1. Retail Clients:
   • Protections: Retail clients receive the highest level of protection, including suitability assessments, detailed risk disclosures, and additional safeguards.
   • Risks:
     • Restricted access to certain high-risk products or services due to regulatory limitations.
     • Over-reliance on protections, potentially leading to an underestimation of financial risks.
2. Professional Clients:
   • Protections: Professional clients waive some regulatory protections, such as suitability assessments and detailed risk warnings.
   • Risks:
     • Increased responsibility to independently understand and manage investment risks.
     • Reduced access to tailored disclosures or protections.
3. Elective Professional Clients:
   • Protections: Retail clients may request reclassification as professional clients if they meet specific criteria (e.g., portfolio size, trading experience).
   • Risks:
     • Misjudgment of eligibility or risks may result in financial losses.
     • Clients must acknowledge reduced protections and the waiver of retail client safeguards.

Reverse Solicitation

Figure Markets Ireland may provide services under the principle of reverse solicitation, where the client engages with the company on their own initiative.

1. What is Reverse Solicitation?

   • Reverse solicitation occurs when a client independently contacts Figure Markets Ireland to request services, without any prior solicitation or promotion by the company.

2. Regulatory Implications:

   • Services offered under reverse solicitation may not comply with local regulations in the client’s jurisdiction if initiated without solicitation.

3. Risks:

   • Client Risks:
     • Limited regulatory protections may apply to services accessed through reverse solicitation.
   • Company Risks:
     • Failure to document client-initiated engagements may result in regulatory scrutiny or penalties.

4. Documentation:

   • Figure Markets Ireland implements strict documentation protocols to confirm that engagements are unsolicited and client-initiated.

NOVEMBER 2024