IOPC
Internal Operational Protection Commitment (CFD)
Bkquote Global Market Limited
The Sotheby Building, Rodney Village, Rodney Bay, Gros-Islet, Saint Lucia
Company Register: No. 2025-00089
Preamble
Bkquote Global Market Limited (hereinafter, “Bkquote” or the “Broker”), within the scope of its intermediation activity in OTC derivative instruments, hereby institutes this Internal Operational Protection Commitment (the “Commitment”) in favor of holders of Contracts for Difference (CFD) accounts. The Commitment articulates—ex abundanti cautela—a reinforced regime of asset safeguarding, segregated custody, prudential controls, and verifiable transparency, intended to endure and aligned with sector best practices. The Commitment constitutes a unilateral, voluntary, and self-executing declaration of the Broker; it is not an insurance policy nor an adherence to any public compensation scheme, and shall be construed strictly in accordance with its terms and the principles of objective good faith and contractual loyalty.
Clause 1. Purpose, nature, and scope
1.1. Purpose. To secure, within the parameters set forth herein, the availability of client funds against strictly operational contingencies attributable to the Broker that cause material unavailability of recognized balances, once ordinary channels of verification and recovery have been exhausted.
1.2. Nature. The Commitment is internal, voluntary, and maintained at Bkquote’s discretion; it does not cover market risk nor losses arising from price evolution, leverage, volatility, or conditions inherent to trading.
1.3. Personal scope. Beneficiaries: clients (natural or legal persons) with an active CFD account duly verified pursuant to the Broker’s contractual terms.
1.4. Material scope. Cash balances and liquid, certain, and enforceable credits recorded in the Broker’s recognized accounting and official account statements, expressly excluding market losses, margin adjustments, and close-out liquidations.
Clause 2. Execution architecture and economic neutrality
2.1. Agency/STP model. Bkquote operates, prima facie, under a market-execution (agency/STP) model, routing orders to external liquidity providers, thereby mitigating counterparty risk vis-à-vis the Broker itself, without wholly excluding residual operational contingencies.
2.2. Economic neutrality. The Broker’s economic exposure to client positions is structured so as not to create incentives adverse to the client’s best interest, subject to routing controls, best execution, and functional segregation.
Clause 3. Custody and segregation of funds
3.1. Bank custodian. Funds classified as client money are held, segregated from Bkquote’s proprietary resources, in accounts specifically dedicated to such purpose, opened with Wio Bank PJSC, Etihad Airways Centre, 5th Floor, Abu Dhabi, UAE (the “Custodian”).
3.2. Account structure. Accounts not commingled with corporate treasury; their use for the Broker’s operational purposes, proprietary investment, or collateralization unrelated to the client relationship is prohibited.
3.3. Reconciliations and evidence. Daily reconciliations shall be performed among: (i) the Broker’s sub-ledgers and general ledger; (ii) Custodian statements; and (iii) trading platform reports. Any discrepancy shall be investigated and regularized on a priority basis within < 24 business hours, with documentary record.
Clause 4. Internal protection reserve
4.1. Constitution. Bkquote maintains a dedicated internal reserve (“Client Protection Reserve”) in high-quality liquid assets, intended exclusively to satisfy obligations arising from operational events covered by this Commitment.
4.2. Size and adjustment. The Reserve shall have an annual aggregate limit of USD 20,000,000 (twenty million United States dollars), subject to quarterly review considering exposure metrics, average client money balances, and stress scenarios.
4.3. Governance. Any disposition of the Reserve requires dual authorization and resolution by the Risk & Treasury Committee, with full traceability (sequential recordkeeping, time-stamping, and evidence custody).
Clause 5. Per-client limit, deductible, and order of priority (“waterfall”)
5.1. Individual limit. Coverage is limited to a maximum per client of USD 500,000 per event.
5.2. Deductible. For purposes of this Commitment, the per-client deductible is set at USD 0 (zero) per event.
5.3. Waterfall. Upon verification of a covered operational event, satisfaction of the client’s claim shall follow this order of priority:
a) Re-emergence and recovery of funds in segregated accounts held with the Custodian;
b) Set-off and application of duly credited and enforceable balances in favor of the client;
c) Application of the Client Protection Reserve up to the individual limit and within the annual aggregate of USD 20,000,000;
d) Issuance of final resolution and accounting close.
Clause 6. Covered events
6.1. The Commitment strictu sensu encompasses events causing effective unavailability of client balances due to:
i) Material custody failure attributable to the Broker, evidenced by bank and accounting documentation;
ii) Serious operational error in treasury and safeguarding processes;
iii) Dishonest internal acts (fraud by employees or agents) duly substantiated and directly impacting client funds.
6.2. Any coverage is subordinated to prior determination of the recognized balance through reconciliation and reliable documentation.
Clause 7. Exclusions
7.1. The following are excluded, inter alia:
a) Market risk in all its forms (volatility, gaps, slippage, margin calls, forced liquidations, partial or delayed execution due to market conditions);
b) Contractual breaches, market abuse, or fraud by the client;
c) Failures of uncontrolled third parties (infrastructure, telecommunications, critical providers) save for gross negligence or willful misconduct by the Broker;
d) Legal/sanction constraints or force majeure preventing disposition of funds;
e) Amounts not reflected in official account statements or not reconciled;
f) Any circumstances not expressly falling within Clause 6.
Clause 8. Claims procedure
8.1. Notice. The client shall provide written notice to contact@bkquote.com within 30 business days from the date on which the client had reasonable knowledge of the event.
8.2. Documentation. The client shall submit: account statements, trade confirmations, Custodian statements, relevant correspondence, and any other reasonably required evidence.
8.3. Opening and acknowledgment. Within 48 business hours, Bkquote shall acknowledge receipt and open a case file, assigning a unique case number.
8.4. Inquiry and decision. Upon conducting reconciliation and verification, Bkquote shall issue a reasoned resolution within 30 business days, applying the waterfall where appropriate and making payment up to the applicable limit.
8.5. Close. The resolution shall include the balance computation, a statement of the sources of payment used, and evidence archiving.
Clause 9. Audit, transparency, and independent oversight
9.1. External review. An independent audit/accounting firm, Digital Vis Solutions FZCO, with address Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates, shall perform agreed-upon procedures on: (i) segregation of funds; (ii) reconciliations; and (iii) existence and reasonable sufficiency of the Reserve.
9.2. Publications. Bkquote shall make available a quarterly aggregated client money report (without personal data), as well as an annual safeguarding statement.
9.3. Information integrity. Security controls (encryption, access controls, immutable logging) and data-governance principles consistent with internationally recognized best practices shall be adopted.
Clause 10. Business continuity and operational resilience
10.1. BCP/DRP. Bkquote maintains a business continuity and disaster recovery plan, with targets of RTO 48 hoursand RPO 30 minutes for critical systems (trading, back-office, treasury).
10.2. Testing and evidence. Annual tests shall be conducted and findings documented, with a remediation calendar and reporting to the Audit Committee.
10.3. Sites and access. Capabilities for secure remote operation, communications contingency, and failover of essential services.
Clause 11. Corporate governance and segregation of functions
11.1. Risk & Treasury Committee. Collegial body responsible for the Reserve, and supervision of custody and client money movements.
11.2. Audit Committee. Oversight of independent reviews, follow-up of findings, and improvement roadmap.
11.3. Compliance/AML-KYC. Identity verification, sanctions screening, transactional monitoring, and continuous staff training.
11.4. Traceability. Every relevant decision shall be subject to a complete audit trail, with evidence retention for 2 years.
Clause 12. Communications and amendments
12.1. Key Facts. Bkquote shall publish a Key Facts document summarizing limits, exclusions, and procedure (Annex I).
12.2. Amendments. Bkquote may update, refine, or strengthen the Commitment, providing reasonable prior noticewhen a change is material, without prejudice to claims validly initiated under the version in force at the time of the event.
12.3. Language. In case of versions in different languages, the Spanish version shall prevail unless expressly stipulated otherwise.
Clause 13. Risk warning
13.1. CFDs are complex instruments; leverage may work for or against you, increasing the likelihood of loss.
13.2. The Commitment does not cover market risk losses nor guarantee economic outcomes. Its scope is operationaland governed by Clauses 6 and 7.
Clause 14. Governing law and forum
14.1. The Commitment shall be construed pursuant to the governing law arising from the Client Terms and general principles of international commercial contracting, with choice of forum as contractually stipulated.
14.2. In case of interpretive conflict, the principle of preservation of the juridical act and proportionality in enforcement shall apply.
Clause 15. Acceptance and effectiveness
15.1. This instrument enters into force upon its publication by Bkquote and remains effective while it remains published, unless replaced or withdrawn in accordance with Clause 12.
15.2. Claims made in good faith under a version in force shall be resolved in accordance with that version.
For Bkquote Global Market Limited
Name: James Collins Cooper
Title: Chief Executive Officer
Date: 05/01/2025
Annex I — Key Facts (public summary)
Nature: Internal operational safeguarding commitment; not an insurance policy and does not cover market losses.
Custodian: Wio Bank PJSC, Etihad Airways Centre, 5th Floor, Abu Dhabi, UAE.
Per-client limit: USD 500,000 per event.
Annual aggregate: USD 20,000,000 (twenty million United States dollars).
Deductible: USD 0 per event.
Scope: Operational unavailability of recognized balances, following reconciliation.
Process: Notice (contact@bkquote.com) → Reconciliation → Waterfall → Resolution (30 business days) and payment.
Transparency: Quarterly aggregated reports and independent verification by Digital Vis Solutions FZCO.
Annex II — Segregation policy (normative extract)
No commingling between client accounts and corporate treasury.
Daily reconciliation with zero tolerance for unjustified differences.
Dual signatures for outbound payments and whitelisting of beneficiaries.
Immutable recordkeeping of entries and probative support.
Periodic confirmation letters from the Custodian and archiving for 2 years.
Annex III — Reconciliation procedure
Frequency: daily (operational), weekly (executive summary), monthly (close).
Sources: statements from Wio Bank PJSC, platform reports, and general ledger.
Evidence: reconciled items, differences, root cause, and documented remediation.
Independent review: sampling and agreed-upon procedures by Digital Vis Solutions FZCO.
Annex IV — Governance and roles
Operational owner: Treasury Director.
Second line: Risk and Compliance.
Third line: Internal/External Audit.
Committees: Risk-Treasury; Audit; Business Continuity.
Annex V — Resilience and continuity (BCP/DRP extract)
Critical risks: system unavailability, key provider failure, cyber incident, physical disaster.
Target RTO: 48 hours; RPO: 30 minutes.
Backups: encrypted, with periodic restoration testing.
Communications: protocols with clients and counterparties under contingency.
Annex VI — Frequently Asked Questions (FAQ)
Is this insurance? No. It is an internal, self-imposed commitment by Bkquote.
What does it cover? Exclusively operational events causing unavailability of recognized balances.
What is the limit? USD 500,000 per client and event; annual aggregate USD 20,000,000.
Deductible? USD 0 per event.
Where are my funds? In segregated accounts at Wio Bank PJSC (Abu Dhabi).
How is it evidenced? Through reconciliations and verifiable bank/accounting documentation.
External auditor? Digital Vis Solutions FZCO (Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates).
Will I receive information? Yes: quarterly aggregated reports and periodic external review.
If you’d like, I can also deliver this as a branded PDF and a one-page Key Facts for your website.