BlackCores RM10 Standards

Institution-facing counterparties and partners need a coherent, self-consistent picture of where a firm operates, under which entities, and within what permitted activities before they engage. Ambiguity here is a common source of mis-set expectations.

All firms operating in or adjacent to the FX/CFD ecosystem.

• Licence and registration references where applicable
• Entity structure and permitted-activity mapping
• Public disclosure consistency review

• That perimeter and licence-identity documentation was submitted within a defined scope
• The documentary status assigned for this criterion

How a firm classifies clients and bounds its distribution determines who it serves and how. Documented boundaries help institution-facing audiences understand the firm's intended market and the controls around it.

Firms that onboard, classify or distribute to clients or partners.

• Client classification policy
• Distribution and territory boundary controls
• Appropriateness and eligibility records

• That classification and distribution-boundary documentation was reviewed within scope
• The criteria-coverage status assigned

Marketing and third-party promotion are where conduct risk is most visible to the public. Documented approval and monitoring controls show how a firm governs the messages and partners that act in its name.

Firms using marketing, affiliates, IBs or third-party promotion.

• Marketing approval and review process
• Affiliate / IB onboarding and monitoring records
• Promotional content control samples

• That marketing and affiliate/IB control documentation was submitted
• The evidence-submission status for this criterion

Financial-crime controls are a baseline expectation for any firm handling funds or counterparties. Documented frameworks let institution-facing audiences see that the firm has defined policies, screening and beneficial-ownership procedures.

Firms with onboarding, funds-handling or counterparty exposure.

• AML/CFT policy and risk assessment
• Sanctions and PEP screening approach
• KYB and beneficial-ownership procedures

• That financial-crime control documentation was reviewed within scope
• The criteria-coverage status assigned

Modern firms depend on a web of counterparties and outsourced services. Documented governance shows how a firm selects, oversees and manages dependency on the third parties embedded in its operations.

Firms relying on counterparties, vendors or outsourced operations.

• Counterparty due-diligence framework
• Outsourcing and supplier register
• Service and dependency oversight records

• That counterparty and outsourcing governance documentation was submitted within scope
• The documentary status assigned

How products and programmes are designed shapes the outcomes they create. Documented design governance and target-market logic show that a firm considers suitability and responsibility at the point of design, not only at sale.

Firms designing products, services, education or programmes.

• Product governance and design records
• Target-market and suitability logic
• Review and approval trail

• That product and programme design documentation was reviewed within scope
• The criteria-coverage status assigned

How a firm responds when things go wrong is a strong signal of its conduct culture. Documented complaints, fair-handling and remediation processes show a structured approach to resolution and root-cause learning.

Firms handling clients, partners or end-user complaints.

• Complaints policy and workflow
• Remediation and root-cause records
• Fair-handling governance reporting

• That complaints and remediation documentation was submitted within scope
• The evidence-submission status for this criterion

Technology and data sit at the core of institution-facing operations. Documented security, resilience and continuity governance show how a firm protects systems and data and prepares for disruption.

Firms operating platforms, data systems or critical technology.

• Information-security and data-protection policies
• Resilience, continuity and incident records
• Cyber control and testing summaries

• That technology, data and resilience documentation was reviewed within scope
• The criteria-coverage status assigned

Where client money and settlement are involved, clear boundaries matter most. Documented safeguarding, segregation and reconciliation controls show how a firm structures and oversees the movement of funds.

Firms handling, routing or safeguarding money or settlement flows.

• Safeguarding and segregation approach
• Payment and settlement control records
• Reconciliation and oversight documentation

• That money-handling and safeguarding documentation was submitted within scope
• The documentary status assigned

Responsible conduct is sustained by governance and a habit of improvement. Documented oversight, anti-corruption controls and an annual update cycle show that a firm treats responsibility as an ongoing programme, not a one-off exercise.

All participating firms across the ecosystem.

• Governance and board oversight records
• Anti-corruption and ethics policies
• Annual improvement and update filing

• That governance and anti-corruption documentation was submitted
• Whether an annual update has been filed for the current cycle