BlackCores RM10 Standards

Make the firm's regulatory perimeter, licence identity and permitted activities clearly documented and internally consistent.

Applies to

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

Evidence examples

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

Public status language

Documentary Status: Defined Scope

Records documentation only. Not a regulatory approval or substitute for licensing.

Evidence how client categories, eligibility and distribution boundaries are defined and enforced.

Applies to

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

Evidence examples

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

Public status language

Criteria Coverage: Documented

Reflects documented boundaries only, not client outcomes.

Demonstrate controls over marketing, affiliate and introducing-broker activity and the records that support them.

Applies to

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

Evidence examples

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

Public status language

Evidence Submitted

Assesses control documentation, not individual campaigns unless separately reviewed.

Evidence financial-crime control frameworks across AML/CFT, sanctions screening and know-your-business.

Applies to

Firms with onboarding, funds-handling or counterparty exposure.

Evidence examples

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

Public status language

Criteria Coverage: Documented

Records documented controls; does not test live transactions.

Demonstrate governance over counterparties, suppliers and outsourced functions.

Applies to

Firms relying on counterparties, vendors or outsourced operations.

Evidence examples

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

Public status language

Documentary Status: Defined Scope

Covers governance documentation within the declared scope only.

Evidence responsible design of products, services and programmes, including target-market logic.

Applies to

Firms designing products, services, education or programmes.

Evidence examples

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

Public status language

Criteria Coverage: Documented

Reviews design documentation, not commercial performance.

Demonstrate complaints handling, fair-treatment practices and remediation record-keeping.

Applies to

Firms handling clients, partners or end-user complaints.

Evidence examples

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

Public status language

Evidence Submitted

Reflects documented handling processes within scope.

Evidence technology governance, data protection, cyber controls and operational resilience.

Applies to

Firms operating platforms, data systems or critical technology.

Evidence examples

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

Public status language

Criteria Coverage: Documented

Records control documentation; not a penetration test or certification.

Demonstrate boundaries and controls around money handling, payments, safeguarding and settlement.

Applies to

Firms handling, routing or safeguarding money or settlement flows.

Evidence examples

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

Public status language

Documentary Status: Defined Scope

Records documented boundaries; not an audit of financial soundness.

Evidence governance maturity, anti-corruption controls and a documented annual improvement cycle.

Applies to

All participating firms across the ecosystem.

Evidence examples

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

Public status language

Annual Update Filed

Records governance documentation and the annual update cycle.