Last updated 17 December 2023
Changex Risk Appetite Policy
Risk Strategy
Whilst success for Changex is measured by the ability to grow the business profitably, its long-term strategic goals are:
As a regulated company, Changex must hold capital to meet uncertainties and mitigate risks. Risks and uncertainties primarily arise from trading activity but also arise from associated commercial activities such as operations and strategy.
Changex Risk Strategy aligns its risk profile (including regulatory responsibilities) with strategic plans through a clear risk appetite. This facilitates the identification and mitigation of risks that might prevent the company from achieving its business objectives as well as consistently enabling it to execute its business based on an objective assessment of risk and reward.
The Changex team takes both a prudent and conservative approach to risk in line with intended business development and strategic business plans. Risk strategy and appetite are formed with the objective of being able to run at significantly reduced revenue, due to loss of business or systemic events like individual market shocks for a prolonged time, without materially impacting the business or the fulfilment of its regulatory obligations.
The Changex team agrees on the specific ways in which risk may be mitigated (e.g. through holding additional capital, implementing controls, or defining management actions or behaviours) and its appetite or tolerance for the risks affecting the business. The CEO also defines the amount of exposure to or potential adverse impact from, internal or external events that it is willing to accept. This document provides a summary of the company’s risk appetite and the associated tolerances.
The detailed assessment of risks is subject to review at least annually or more frequently to reflect changes in strategy, regulatory obligations, or the profile of the risk facing the business.
Recognized Risks
The Company has categorized risks into medium, and high risks.
Implementation of the Risk Appetite
Changex creates all of its internal rules and procedures with due reference to this Statement of Risk Appetite. Modifications to internal rules or procedures or changes in business strategy will be made only after an assessment of the risks including reference to the company’s risk appetite.
Risk Appetite Oversight
The Statement of Risk Appetite forms the cornerstone of the business operations and will be reviewed and approved by the CEO at least annually or more frequently to reflect changes in strategy, regulatory obligations, or the profile of the risk facing the business.
Risk Appetite Disclosure
Where appropriate and mandated under applicable law and regulatory framework, the company discloses its Statement of Risk Appetite with its clients and business partners.
Summary of Risk Appetite
Risk Classification |
Capital |
Risk Tolerance |
Status |
High Risk |
> EUR 100 000 |
Case by case basis. Additional KYC always requested |
Within appetite |
Medium Risk |
EUR 0 – EUR 100 000 |
Case by case basis. Additional KYC is requested if questionable activity |
Within appetite |
PEP (Politically Exposed Person) |
Not Applicable |
Not tolerated |
Not within appetite |
Changex does not enter into relationships or enter into transactions with customers located, directly or indirectly associated with the following countries and territories: Afghanistan, American Samoa, Antarctica, Burkina Faso, Burundi, Cameroon, Canada, Central African Republic, Chad, Comoros, Congo Rep, Cuba, DR Congo, East Timor, Eritrea, Gambia, Guinea-Bissau, Haiti, Iran, Iraq, Japan, Kiribati, North Korea, Lao, Lebanon, Liberia, Libya, Mali, Marshall Islands, Micronesia, Mozambique, Myanmar/Burma, Namibia, Niger, Nigeria, Palestine, Papua New Guinea, Solomon Islands, Somalia, South Korea, South Sudan, Sudan, Syria, Switzerland, Tajikistan, Tuvalu, United States, Venezuela, Virgin Islands (U.S.), Western Sahara, Yemen, Zimbabwe, Russia, Belarus.
Changex does not enter into relationships or enter into transactions with customers, directly or indirectly associated with the following commercial activities: Alcohol and tobacco trading online; Unauthorized prescription drugs; Drugs or illegal drugs; Quickly perishable food in bulk; Marriage, bridal order by mail; Scientific Degrees and Diplomas; Weapons, ammunition, rifles and related goods; Incitement to racial hatred, religious persecution, or force against other initiation; Products for providing unauthorized electronic communications; Spyware, malware sales; Satellite signal decoding products, cards, and card programming; Unregistered charities; Services or products to receive a service that has not been paid (bypass locks, programming codes, etc.); Escort services; Prostitution services; Trade in human body parts, liquids, pallets; Trade in cultural monuments; Representation of religious symbols in an offensive or inappropriate form; Hazardous chemicals, fuels; Fireworks or pyrotechnic articles or accessories; Trust companies; Carbon trading; Cash for gold; Cheque cashing; Counterfeit goods; Diamond merchants; Medical marijuana/cannabis; Illegal goods; Jewellers, Precious metal and stone merchants; MLM/pyramid schemes; Pawnbrokers; Penny stock trading, binary options trading & other complex derivatives or financial products in jurisdictions that do not have or require regulation /licensing; Political groups; Shell banks.