This document is a template prepared for review. It must be reviewed, completed and approved by qualified legal and compliance professionals for each jurisdiction in which services are offered before publication. Bracketed items are placeholders.
1. Introduction
This Client Funds Policy describes how [LEGAL ENTITY NAME], trading as JDGlobalFX ("we", "us", "our"), receives, holds and returns money belonging to clients. It forms part of the Client Agreement and should be read with the AML/KYC Policy, which sets out the financial-crime controls that apply to payments.
2. How Client Money Is Held
Client money is held in accordance with [CLIENT MONEY RULES / ARRANGEMENT]. The specific arrangements applying to your account, including whether your funds are held separately from the firm's own funds, where they are held, and their treatment in the event of the firm's insolvency, are set out in [CLIENT MONEY DISCLOSURE DOCUMENT] and depend on your classification and jurisdiction. Interest is [INTEREST TREATMENT] on client money balances. Where client money is held with an institution outside your jurisdiction, the regime applying to that institution, and your rights if it fails, may differ from your own.
3. Account Currencies
Accounts may be denominated in [AVAILABLE ACCOUNT CURRENCIES]. The account currency is selected at account opening and cannot be changed without opening a new account.
4. Deposits
4.1 Accepted methods
We accept deposits by [ACCEPTED PAYMENT METHODS]. Availability may depend on your country of residence. Minimum and maximum deposit amounts per method are set out in [DEPOSIT LIMITS SCHEDULE].
4.2 Own-name requirement and no third-party payments
Deposits must originate from a bank account, card or wallet held in your own name. We do not accept deposits from third parties, including family members, joint accounts where you are not a named holder, or corporate accounts (unless the client is that corporation). Third-party deposits identified after receipt are returned to the originating account, less any charges, and may result in account suspension.
4.3 Crediting
Deposits are credited once cleared and matched to your account; typical times are shown in [DEPOSIT PROCESSING TIMES SCHEDULE]. We are not responsible for delays caused by payment providers or banks.
4.4 Deposit fees
We charge [DEPOSIT FEE ARRANGEMENT] on deposits. Your bank, card issuer or payment provider may impose separate charges that we do not control.
4.5 Chargebacks
Raising a chargeback in respect of a validly made deposit is a breach of the Client Agreement. We may suspend your account, close open positions, recover the disputed amount and associated costs from your balance, and terminate the relationship.
5. Withdrawals
5.1 Requesting a withdrawal
Withdrawals are requested through the client portal and processed only where the account is fully verified, sufficient free margin remains to support open positions, and no compliance hold applies.
5.2 Return to source
Withdrawals are returned to the payment account and method from which funds were originally deposited, in the same currency where possible, until the original deposit amount has been fully returned. Where a method does not support refunds or the original account has been closed, we will request documentary evidence of an alternative account in your own name. We do not make payments to third parties in any circumstances.
5.3 Processing times
We process withdrawal requests within [NUMBER OF BUSINESS DAYS] business days of receiving a complete request. The time for funds to reach your account thereafter depends on the payment method and receiving institution, as indicated in [WITHDRAWAL PROCESSING TIMES SCHEDULE].
5.4 Withdrawal fees
We charge [WITHDRAWAL FEE ARRANGEMENT] on withdrawals. Minimum withdrawal amounts per method are set out in [WITHDRAWAL LIMITS SCHEDULE]. Intermediary banks may deduct their own charges from international transfers.
5.5 Verification and holds
We may request additional information before processing a withdrawal, including evidence of source of funds, and may delay or decline a withdrawal where required by law, where a payment is under investigation or chargeback, or where the request appears inconsistent with your prior activity. We will explain any delay where permitted.
6. Currency Conversion
Where a deposit or withdrawal is made in a currency different from your account currency, or where you trade an instrument denominated in a different currency, conversion is carried out at [CONVERSION RATE BASIS], which may include a mark-up of [CONVERSION MARK-UP]. The rate applied is shown on the transaction record in the client portal. Exchange-rate movements between deposit and withdrawal may mean you receive more or less than you deposited in your original currency.
7. Promotional Credits
Promotional credits, where offered, are subject to separate terms, are not client money, cannot be withdrawn, and are not offered where prohibited in your jurisdiction.
8. Dormant Balances and Errors
Balances on accounts inactive for [DORMANCY PERIOD] are subject to the inactivity fee and dormancy provisions of the Client Agreement. Where an account is closed with a positive balance, we return the balance to source where possible and make reasonable efforts to contact you where it is not.
If funds are credited to your account in error, you must notify us promptly and must not withdraw or trade with them. We may reverse erroneous credits, and positions opened using such funds may be voided.
9. Summary of Key Points
| Topic | Position |
|---|---|
| Client money holding | In accordance with [CLIENT MONEY RULES / ARRANGEMENT] |
| Third-party payments | Not accepted in either direction |
| Withdrawals | Returned to source until original deposit returned |
| Withdrawal processing | Within [NUMBER OF BUSINESS DAYS] business days |
| Deposit / withdrawal fees | [DEPOSIT FEE ARRANGEMENT] / [WITHDRAWAL FEE ARRANGEMENT] |
| Currency conversion | At [CONVERSION RATE BASIS] plus [CONVERSION MARK-UP] |
10. Contact
Questions about deposits and withdrawals should be directed to [SUPPORT EMAIL]; questions about how client money is held to [COMPLIANCE EMAIL].