YWO (MU) Ltd · Legal
CLIENT MONEY AND SAFEGUARDING OF CLIENT ASSETS POLICY
Last Updated: May 2026
1. INTRODUCTION
YWO (MU) LTD (the “Company”) is incorporated under the laws of the Republic of Mauritius with registration number 229766 and registered office at Legacy Capital Co Ltd, 2 Floor, Suite 201, The Catalyst, Ebene, Republic of Mauritius.
The Company is licensed as an Investment Dealer (Full-Service Dealer, Excluding Underwriting) and is regulated and authorised by the Financial Services Commission (“FSC”) of Mauritius under licence number GB25205550.
This Client Money and Safeguarding of Client Assets Policy (the “Policy”) sets out how the Company treats client funds and assets in accordance with applicable Mauritian laws, FSC rules, and regulatory expectations.
This Policy must be read together with the Company’s:
- Client Agreement / Terms & Conditions
- Risk Disclosure
- Best Execution Policy
- Conflicts of Interest Policy
2. SCOPE AND APPLICATION
This Policy applies to:
- all retail and professional clients of the Company; and
- all investment services provided by the Company on an execution-only basis.
It governs:
- the handling of client money received in connection with trading activity; and
- disclosures regarding the non-custodial nature of the Company’s services.
3. EXECUTION-ONLY AND NON-CUSTODIAL MODEL
The Company provides investment services strictly on an execution-only basis and does not provide custody, safekeeping, or asset-management services.
Accordingly:
- the Company does not act as a trustee, custodian, or depositary of client assets;
- the Company does not hold financial instruments or securities on behalf of clients; and
- clients retain full ownership of any underlying assets referenced by derivative instruments.
All trading offered by the Company is conducted through over-the-counter (OTC) derivative products, including CFDs and FX contracts, which are cash-settled and do not involve delivery of underlying assets.
4. CLIENT MONEY – GENERAL PRINCIPLES Client money refers to funds received from clients for the purpose of:
- margin requirements;
- trading activity;
- settlement of profits or losses; and
- fees or charges related to trading services.
The Company applies the following principles:
- client funds are received solely for the purposes of facilitating trading activity;
- client funds are not accepted as deposits;
- client funds do not constitute savings, investments, or protected deposits;
- the Company does not guarantee the safety or return of client funds beyond regulatory requirements.
5. SEGREGATION OF CLIENT MONEY
Where client funds are held by the Company prior to or during trading activity:
- such funds are maintained separately from the Company’s own operational funds, in designated client accounts with reputable financial institutions;
- segregation is implemented for accounting and operational purposes in line with FSC expectations;
- segregation does not create a trust relationship, fiduciary duty, or custodial arrangement.
The Company may use client funds:
- to meet margin requirements;
- to settle trading obligations arising from client positions;
- to pay fees, charges, or commissions owed by the client.
6. USE OF CLIENT MONEY
Client money may be used by the Company strictly for purposes connected to the provision of investment services, including:
- execution, maintenance, and settlement of OTC derivative positions;
- margin close-out and liquidation processes;
- payment of realised losses, spreads, fees, or other agreed charges;
- transfers to and from payment service providers or banking partners.
The Company does not:
- lend client money to third parties for unrelated purposes;
- use client money for proprietary investment unrelated to client trading; or
- pledge client money as collateral for the Company’s own obligations, except where required for execution or hedging of client positions.
7. COUNTERPARTY AND INSOLVENCY RISK
Clients acknowledge that:
- the Company acts as principal and counterparty to OTC derivative transactions;
- client funds are exposed to the credit risk of the Company; and
- in the event of insolvency or default of the Company, client funds may be subject to claims by creditors, in accordance with applicable law.
Segregation of funds does not guarantee full recovery in the event of insolvency.
8. THIRD-PARTY BANKS AND PAYMENT SERVICE PROVIDERS
Client money may be held with:
- regulated banks;
- payment service providers; or
- financial institutions located in Mauritius or other jurisdictions.
The Company performs due diligence on such institutions but is not responsible for:
- the solvency of third-party banks or PSPs;
- failures, delays, or losses arising from third-party systems; or
- actions taken by such institutions beyond the Company’s control.
9. NO INVESTOR COMPENSATION OR DEPOSIT PROTECTION
Client funds held with the Company are not covered by any investor compensation scheme, deposit guarantee scheme, or insurance mechanism, unless expressly required by law.
Clients should ensure they understand that:
- trading involves risk; and
- losses may exceed initial deposits, subject to applicable negative balance protection for retail clients.
10. RECORD KEEPING
The Company maintains accurate and complete records relating to:
- client balances;
- deposits and withdrawals;
- margin utilisation;
- reconciliations; and
- client money movements.
Records are retained for a minimum period of seven (7) years, in accordance with Mauritian law and FSC requirements.
11. MONITORING AND REVIEW
The Company monitors compliance with this Policy on an ongoing basis through:
- internal controls;
- reconciliation procedures; and
- compliance oversight.
This Policy is reviewed at least annually, and whenever material changes occur in:
- regulatory requirements;
- business operations; or
- the Company’s execution model.
12. CLIENT ACKNOWLEDGEMENT
By opening an account and trading with the Company, clients acknowledge that they have read, understood, and accepted:
- the Company’s execution-only and non-custodial model;
- the treatment and use of client money as described in this Policy; and
- the risks associated with OTC derivative trading.
13. AMENDMENT
The Company reserves the right to amend or update this Policy to reflect changes in applicable law, regulatory guidance, or business practices. Updated versions will be made available on the Company’s website.
