Regulations

Referral Program

1. Purpose of the Regulations

These Regulations establish the rules governing interactions between the Referee and the Referral, the procedure for approving transfers of funds between them, applicable restrictions, areas of responsibility, and the procedure for documenting such transactions.

The purpose of these Regulations is to prevent disputes, tax and operational risks, and abuse related to the redistribution of remuneration between participants in the Referral Program.

2. Definitions

Referee — a participant in the Referral Program who has referred a Referral to the Company.

Referral — a Trader or Client of the Company who has been referred by the Referee.

Remuneration — an amount payable to the Referee or the Referral in accordance with the Agreement, the terms of the Referral Program, applicable Payout rates, and the Company's internal rules.

Payout — a portion of the Referee's remuneration accrued for a settlement period based on the results of the Traders referred by the Referee and payable subject to the restrictions set out in these Regulations.

Transfer between the Referee and the Referral — any redistribution of earned remuneration, PNL, bonuses, or other payments in favor of the other party.

Related Parties — persons whose relationship indicates affiliation, common control, family, employment, agency, or other forms of dependency.

3. General Principles

3.1. The Company calculates and pays remuneration to each participant separately in accordance with their Agreement, role, applicable Payout terms, and actual results.

3.2. The relationship between the Referee and the Referral must not be used to circumvent payment limits, tax restrictions, contractual terms, or the Company's internal rules.

3.3. Any transfer of earned funds between the Referee and the Referral is permitted only after review and approval by the Company.

3.4. The Company may refuse a transfer without disclosing the full review methodology if the transaction creates legal, tax, AML, operational, or reputational risk.

4. Permitted Transactions

The following transactions are permitted subject to the conditions set out below:

4.1. A transfer of funds between the Referee and the Referral is permitted in an amount not exceeding 70% of the sender's personal earnings available for withdrawal at the time of the transfer.

4.2. The transferred amount may not be withdrawn by a person who did not earn it independently. Such funds may be transferred between accounts solely as collateral in support of the recipient's trading strategies and do not become part of the recipient's personal earnings.

4.3. If, after the transfer, the recipient incurs losses that reduce the amount available for withdrawal, the recipient's own earned funds are applied first, and only after those funds have been exhausted are the transferred funds applied.

4.4. By making a transfer, the person providing the funds waives the right to demand their return until the recipient submits a request for a reverse transfer or until the recipient's account is closed.

4.5. Upon closure of the recipient's account, any remaining transferred funds not used to cover losses are returned to the account from which they were originally transferred (the sender's account).

4.6. A transfer is permitted only if all of the following conditions are met:

● both parties have confirmed their consent to the transfer in writing;
● the transaction does not violate applicable payment limits or the tax status of either party;
● there are no indications that the transaction is intended to circumvent the Company's rules.

4.7. One-time adjustments are subject to approval by the Head of the relevant department, the Finance Department, and, where necessary, the Legal Department.

4.8. Until transfer request functionality is implemented in the Trader's Personal Account, transfer requests must be submitted through Customer Support. Once the relevant functionality becomes available, requests must be submitted through the Personal Account.

5. Prohibited Transactions

The following transactions are prohibited:

5.1. Transfers between the Referee and the Referral without confirmation from both parties.

5.2. Transfers intended to circumvent payment limits, tax regimes, restrictions applicable to Individual Entrepreneurs, self-employed individuals, private individuals, or the terms of the Agreement.

5.3. Transfers between participants belonging to designated high-risk groups.

5.4. Transfers between Traders who have and actively use exclusive access to the Global Market and Traders who either do not have such access or have access but do not use it.

5.5. Transfers in which a Referral with a lower withdrawal limit transfers funds to a Referee with a higher withdrawal limit for the purpose of enabling the Referee to withdraw those funds.

5.6. Regular or split transfers that effectively constitute redistribution of income between participants outside the approved payment model.

5.7. Transfers where there is an active dispute, ongoing review, suspicion of intentional loss-making, market manipulation, an arrangement outside the Company, or another conflict of interest.

5.8. Transfers exceeding 70% of the sender's personal earnings available for withdrawal at the time of the transfer.

6. Enhanced Transfer Review

A transaction is subject to additional review if:

6.1. The Referral is self-employed and the Referee is an Individual Entrepreneur.

6.2. The transfer amount exceeds RUB 25,000.

6.3. The transfer is made more than once per month.

6.4. The transfer represents a significant portion of the earned PNL or remuneration.

6.5. The participants have previously made similar transfers.

6.6. There are indications that the actual recipient of the income is not the participant to whom the remuneration was originally accrued.

7. Transfer Approval Procedure

7.1. The initiator of the transfer submits a request to the responsible manager.

The request must specify:

● the sender;
● the recipient;
● the amount;
● the reason for the transfer;
● the period to which the amount relates;
● the source of funds;
● confirmation that the transfer is not intended to circumvent limits or tax restrictions.

7.2. The responsible manager requests confirmation from the other party.

7.3. Confirmation may be provided in simple written form, including by email or through another communication channel that allows the participant to be identified.

7.4. The minimum confirmation wording is:


7.5. Once both confirmations have been received, the manager submits the transaction to the Finance Department for review.

7.6. The Finance Department reviews:

● applicable limits;
● the tax status of the parties;
● transfer history;
● the presence of Related Parties;
● any applicable restrictions or risk indicators.

7.7. Where necessary, the transaction is also referred to the Legal Department or the Head of the relevant department for approval.

8. Grounds for Refusal

The Company may refuse a transfer if:

8.1. Confirmation from one of the parties has not been provided.

8.2. The reason for the transfer is unclear or appears merely formal.

8.3. The transaction appears to be intended to circumvent withdrawal limits.

8.4. The participants belong to a prohibited or high-risk group.

8.5. There are indications of nominal or artificial income redistribution.

8.6. The transfer creates tax, legal, or AML risk.

8.7. The transaction conflicts with the Agreement, the Company's internal rules, or a previously issued decision relating to the participant.

9. Documentation

9.1. For each transfer, the information specified in Section 7.1, the Company's decision, and the responsible employee are recorded.

9.2. A separate formal agreement between the Referee and the Referral is not required unless otherwise determined by the Legal Department.

9.3. Confirmation from both parties is stored in the Company's internal system.

9.4. In the event of a dispute, the absence of proper confirmation may constitute grounds for cancellation of the transaction or refusal of similar transfers in the future.

10. Responsibility of the Parties

10.1. The Referee and the Referral are responsible for the accuracy of the information they provide.

10.2. If it is subsequently determined that a transaction was used to circumvent the Company's rules, the Company may:

● prohibit similar transfers in the future;
● revise the applicable Payout terms;
● deduct the disputed amount from future payments;
● suspend payments;
● terminate cooperation with the participant.

10.3. The responsible manager must not approve a transfer independently without completing the required review and obtaining confirmation from both parties.

11. Payments under the Agreement

11.1. If the Agreement requires the Company to pay remuneration to a specific Contractor, the default rule is that payment must be made to that Contractor.

11.2. A transfer in favor of another person is permitted only as a separately approved transaction after the remuneration has been accrued or as part of an approved redistribution procedure.

11.3. The Company is not required to comply with a Contractor's request to make payment to a third party if such payment creates legal, tax, or operational risk.

12. Referee Payout and Remuneration

12.1. Payout accrued to the Referee may be withdrawn no earlier than 14 calendar days after accrual.

12.2. If the aggregate losses (drawdown / PNL loss) of Traders referred by the Referee exceed 30% of the total balances provided to those Traders, the Referee's unwithdrawn Payout is deducted to cover those losses.

The deducted amount is restored to the Referee in full once the profit generated by the referred Traders exceeds 30% of the balance provided by the Company.

12.3. If a Trader loses more than 15% of the balance provided to them, the Referee's remuneration attributable to that Trader is not deducted; however, the corresponding Payout may not be withdrawn.

12.4. The standard Referee remuneration share is 30%. A Referee whose referred Traders demonstrate a stable return of more than 100% on the total capital provided may contact Customer Support to request an increase in their remuneration share to 50%.

12.5. Traders with exclusive access to the Global Market may not transfer earned funds to their Referee or receive funds from their Referee.

13. Final Provision

Any non-standard transfer between the Referee and the Referral is treated not as an entitlement of the participant, but as an exception requiring separate approval.

The Company's priorities are transparency of payments, compliance with contractual terms, prevention of attempts to circumvent applicable limits, and minimization of tax and legal risks.