Los clientes del Pacífico Asiático pueden operar con la plataforma de eToro a través de IC Markets Ltd., una empresa australiana de servicios financieros regulada por el ASIC, el cuerpo regulatorio de servicios financieros en Australia, bajo el número de licencia AFSL 335692.
eToroUSA está operada por Tradonomi LLC, que actúa como broker introductorio para Institutional Liquidity (ILQ). Tanto eToroUSA como ILQ están regulados por la Commodity Futures Trading Commission (CFTC) y son miembros de la National Futures Association (NFA). eToroUSA opera bajo el ID de miembro de la NFA 0382918. El ID de miembro de la NFA de ILQ es el 0367140.
La MiFID (Markets in Financial Instruments Directive) es una ley de la Unión Europea en vigor desde el 1 de noviembre del 2007, que proporciona un régimen regulatorio uniforme para los servicios de inversión en el área económica de la Unión Europea. Los principales objetivos de la Directiva son aumentar la competencia y la protección del cliente en los servicios financieros. Las actividades y servicios de eToro (Europe) Ltd. cumplen con los requisitos de la MiFID. Toda la documentación y procedimientos de la empresa cumplen con las reglas de la MiFID.
1.1 eToro (Europe) Ltd. (“the Company”) is an Investment Firm regulated by the Cyprus
Securities and Exchange Commission (“CySEC”) with license number 109/10.
1.2 This Policy is issued pursuant to, and reflects Compliance with, the European
Directive 2004/39/EC Of 21 April 2004 on Markets in Financial Instruments (MiFID)
and with the implementation in Cyprus legislation on Investment Services and Activities
and Regulated Markets Law of 2007 – Law 144(I)/2007 (the “Rules”) that apply to
the Company. It is not intended to create third party rights or duties that would
not already exist if the policy had not been made available and it does not form
part of any contract between the Company (or any of its affiliates) and any client
or prospective client.
1.3 What follows is an overview on how trades and orders are executed, the factors
that can affect an execution’s timing and the way in which market volatility plays
a part in handling orders when buying or selling a financial product.
1.4 Upon acceptance of a client order and when there is no specific client instruction
regarding the execution method, the Company will endeavor to execute that order
in accordance with the Best Execution policy.
1.5 Nevertheless, whenever there is a specific instruction from a client, the Company
shall execute the order following the specific instruction. In fact, any specific
instructions from a client may prevent the Company from taking the steps that it
has designed and implemented in the execution policy to obtain the best possible
result for the execution of those orders in respect of the elements covered by those
1.6 This Policy is available to clients upon request and is also made available
on our Website. The Company reserves the right to amend or supplement this Policy
at any time.
2.1 The financial products to which this Policy applies are all of the products
offered by the company.
2.2 The trading conditions of the above products are available on the Company’s
official web site at www.etoro.com
3.1 The Company identifies and seeks to obtain the most favorable terms reasonably
available when executing an order on behalf of a client.
3.2 To do this, the Company relies on three basic components:
3.3 When executing a buy or sell order, the Company always considers:
4.1 The Company uses automated systems to route and execute client orders. When
clients’ orders are received by the Company, it is automatically executed
4.2 For OTC financial instruments, the Company may trade against its own proprietary
desk or will route the orders to other market maker firms. Many of these firms also
provide automated executions of orders.
5.1 Routing determinations are based on five main criteria and are regularly reviewed
by the Company. Hence to determine the best way to execute an order for a client
the Company takes into consideration:
(1) Speed and Likelihood of the Execution. Due to the levels of volatility affecting
both price and volume, the Company seeks to provide client orders with the fastest
execution reasonably possible.
(2) Price Improvement and Overall Consideration of Costs. Orders are routed to market
makers and/or market centers where opportunities for price improvement exist.
(3) Size Improvement. In routing orders, the Company seeks markets that provide
the greatest liquidity and thus potential for execution of large orders.
(4) Overall Execution Quality. When determining how and where to route or execute
an order, the Company’s traders draw on extensive day‐to‐day experience with various
markets and market makers, focusing on prompt, sequential and reliable execution.
(5) Clients’ specific instructions. The Company will always execute client orders
in accordance with the instructions given by that client or on its behalf. Consequently,
if a client requires an order to be executed in a particular manner and not in accordance
with the Company’s best execution principles set forth herein, the client must clearly
state his/her desired method of execution when he/she places the order. To the extent
that a client instruction is not comprehensive, the Company will determine any non‐specified
components of the execution in accordance with these best execution principles.
5.2 The Company invites the clients to bear in mind that the duty of best execution
not only relates to price but also involves the consideration of various factors
including cost, speed and likelihood of execution and settlement. Even if a trade
appears not to have been executed at the best possible price, it does not necessarily
constitute a violation of the duty of best execution.
6.1 The Company regularly evaluates the overall quality of its order executions.
The Company studies the quality of executions for listed and OTC retail market orders.
6.2 The Company’s Management periodically evaluates the execution quality and makes
recommendations regarding order routing practices.
7.1 Execution Venues are the entities with which the orders are placed or to which
the Company transmits orders for execution. For the purposes for the financial instruments
provided by the Company, the Company act as a principal or an agent on the Clients
behalf; therefore the Company is not always the sole Execution Venue of the Client
orders. The Company might transmit the Client order in the external market (other
liquidity providers) if the order is for the financial instrument provided by the
7.2 The Company acknowledges that the transaction entered in Financial Instruments
with the Company are not undertaken on a recognized exchange, rather they are undertaken
through the Company’s Trading Platform, and accordingly, they may expose the Client
to greater risks that regulated exchange transactions. Therefore the Company may
not execute an order, or it may change the opening (closing) price of an order in
case of any technical failure of the trading platform or quote fees. The Client
is obliged to close an open position of any given Financial Instruments during the
opening hours of the Company’s Trading platform. The Client also has to close any
position with the same counter party with whom it was originally entered into, thus
7.3 The Company places significant reliance to the above execution venue(s) based
on the above mentioned factors and their relevant importance. It is the Company’s
policy to maintain such internal procedures and principles in order to act for the
best interest of its client and provide them the best possible result ( or “best
execution”) when dealing with them.
8.1 Volatility is one factor that can affect order execution. When clients place
a high volume of orders with brokers, order imbalances and backlogs can occur. This
implies that more time is needed to execute the pending orders. Such delays are
usually caused by the occurrence of different factors: (i) the number and size of
orders to be processed, (ii) the speed at which current quotations (or last‐sale
information) are provided to the Company and other brokerage firms; and (iii) the
system capacity constraints applicable to the given exchange, as well as to the
Company and other firms.
8.2 In order to minimize such a risk, the Company has in place procedures and arrangements
which to the furthest extent possible provide for the prompt, fair and expeditious
execution of client orders.
9.1 Clients should be aware of the following risks associated with volatile markets,
especially at or near the open or close of the standard trading session:
10.1 Given the risks that arise when trading in volatile markets, you may want to
consider using different types of orders to limit risk and manage investment strategies.
(1) Market order. With a market order the client instructs a broker to execute a
trade of a certain size as promptly as possible at the prevailing market price.
Financial institutions are required to execute market orders without regard to price
changes. Therefore, if the market price moves significantly during the time it takes
to fill a client’s order, the order will most likely be exposed to the risks outlined
above, including execution at a price substantially different from the price when
the order was entered.
(2) Limit order. With a limit order, the client sets the maximum purchase price,
or minimum sale price, at which the trade is to be executed. As a limit order may
be entered away from the current market price, it may not be executed immediately.
A client that leaves a limit order must be aware that he/she is giving up the certainty
of immediate execution in exchange for the expectation of getting an improved price
in the future. Limit orders may be routed to an exchange without human intervention.
(3) Stop order. Different from a limit order, a stop order allows selling below
the current market price or buying above the current market price if the stop price
is reached or breached. A stop order is therefore a “sleeping” order until the stop
price is reached or breached. When the stop price is reached or breached, the stop
order is converted to a market order. See section 10.1(1) for market orders.
(4) Trailing Stop Order. The trailing stop order is a stop order as described in
10.1(3) but the trailing stop price moves according to parameters set by the client.
This way the trailing stop can be used to sell if price drop more than a specified
distance from the highest price traded, or to buy if the price trades above a set
level form the lowest traded price.
a) eToro (Europe) Ltd. or that person is likely to make a financial gain, or avoid
a financial loss, at the expense of the Client
b) eToro (Europe) Ltd. or that person has an interest in the outcome of a service
provided to the Client or of a transaction carried out on behalf of the Client,
which is distinct from the Client’s interest in that outcome
c) eToro (Europe) Ltd. or that person has a financial or other incentive to favour
the interest of another Client or group of Clients over the interests of the Client
d) eToro (Europe) Ltd. or that person carries on the same business as the Client
e) eToro (Europe) Ltd. or that person receives or will receive from a person other
than the Client an inducement in relation to a service provided to the Client, in
the form of monies, goods or services, other than the standard commission or fee
for that service
a) Effective procedures to prevent or control the exchange of information between
relevant persons engaged in activities that may cause a conflict of interest where
the exchange of that information may harm the interests of clients.
b) The separate supervision of relevant persons whose principal functions involve
carrying out activities on behalf of, or providing services to, clients whose interests
may conflict, or who otherwise represent different interests that may conflict,
including those of eToro (Europe) Ltd.
c) The removal of any direct link between the remuneration of relevant persons engaged
in one activity and the remuneration of, or revenues generated by, different relevant
persons principally engaged in another activity, where a conflict of interest may
arise in relation to those activities.
d) Measures to prevent or limit any person from exercising inappropriate influence
over the way in which a relevant person carries out investment services or activities.
e) Measures to prevent or control the simultaneous or sequential involvement of
a relevant person in separate investment or ancillary services or activities where
such involvement may impair the proper management of conflicts of interest.
(a) The Cyprus Securities and Exchange Commission has determined that eToro (Europe)
Ltd. is for the time being unable to meet its obligations arising from its investors-customers’
claims, in connection with the covered services it has provided, as long as such
inability is directly related to eToro (Europe) Ltd.’ financial position which has
no realistic prospect of improvement in the near future; OR
(b) A Court, based on grounds directly related to the financial position of eToro
(Europe) Ltd., has made a ruling which has the effect of suspending the investors-customers‘
ability to lodge claims against eToro (Europe) Ltd..
1.1 Credit Risk
Credit Risk arises when failures by counterparties to discharge their obligations
could reduce the amount of future cash inflows from financial assets on hand at
the balance sheet date. The Company has no significant concentration of credit risk
and implements the standardised approach for credit risk.
Cash balances are held with highly rated financial institutions and the Company
has policies in accordance with the relevant legislation, to limit the amount of
credit exposure to any financial institution, the company also developed internal
policy which reviews on weekly basis and examine the rates of the financial institutions
and limit its assets according to the risk rate of the institutions. The risk of
default of these credit institutions is quite low, based on the relevant calculations
in the Company’s capital requirements.
Further to the above the Company has policies to diversify risks and to limit the
amount of credit exposure to any particular counterparty in compliance with the
requirements of the CySEC Directive DI144-2007-06. The Company uses the Standardized
Approach to Credit Requirements for the calculation of its credit risk.
1.2 Operational Risk
Operational risk means the risk of loss resulting from inadequate or failed internal
processes, people and systems or from external events. Operational risk includes
legal risk but excludes strategic and reputational risk. The following list presents
some event types, included in operational risk, with some examples for each category:
The Company manages operational risk through a control-based environment in which
processes are documented and transactions are reconciled and monitored. This is
supported by continuous monitoring of operational risk incidents to ensure that
past failures are not repeated. For the calculation of operational risk in relation
to the capital adequacy returns, the Company uses the Basic Indicator Approach.
1.3 Foreign Exchange Risk
Foreign exchange risk is the effect that unanticipated exchange rate changes have,
on the Company. In the ordinary course of business, the Company is exposed to minimal
foreign exchange risk, which is monitored through various control mechanisms. The
foreign exchange risk in the Company is effectively managed by setting and controlling
foreign exchange risk limits, such as through the establishment of maximum value
of exposure to a particular currency pair as well as through the utilization of
sensitivity analysis. The Company is mainly exposed to the fluctuation of the Euro
versus the United States Dollar (USD), due to the fact that Major Company’s assets
are denominated in Euro whereas the reporting currency is the USD. The Risk Manager
monitors these risks with the assistance of the accounting function and based on
the fluctuation of the relevant exchange rates, the necessary hedging activities
1.4 Interest Rate Risk
Interest rate risk is the risk that the value of financial instruments (including
currencies) will fluctuate due to changes in the market interest rates. The Company
is exposed to interest rate risk in relation to its bank deposits.
However, the Company’s income and operating cash flows are substantially independent
on changes in market interest rates due to the fact that the Company, other than
cash at bank which attracts interest at normal commercial rates, it has no other
significant interest bearing financial assets or liabilities.
Nonetheless, the Risk Manager monitors these risks with the assistance of the accounting
function and based on the fluctuations of the relevant rates, the necessary hedging
activities is undertaken, the review is being done on weekly basis by the accounting
During 2011, the interest rate risk has been minimal, due to the generally low level
of key interest rates such as those set by the United States Federal Reserve and
the European Central Bank, in addition to the fact that these levels have not fluctuated
significantly during the period under review.
1.5 Funding Liquidity Risk
Funding liquidity risk is the possibility that, over a specific horizon, the Company
will be unable to meet its demands/needs for money (i.e. cash) through mismatch
of assets and liabilities. During the period under review, the Company was not exposed
to funding liquidity risk.
Policies and procedures for the measurement and management of the Company’s net
funding position and requirements, on an ongoing and forward-looking basis, have
been established in order to mitigate the funding liquidity risk. Furthermore, the
Company has considered, alternative scenarios and the assumptions underpinning decisions
concerning the net funding position were reviewed regularly by the Risk Manager.
1.6 Money Laundering and Terrorist Financing Risk
Money laundering and terrorist financing risk mainly refers to the risk that the
Company may be used as a mean to launder money and/or finance terrorism. The Company
has established policies, procedures and controls in order to mitigate the money
laundering and terrorist financing risks.
1.7 Compliance Risk
Compliance risk is the current and prospective risk to earnings or capital arising
from violations of, or non-conformance with, laws, bylaws, regulations, prescribed
practices, internal policies, and procedures, or ethical standards. This risk exposes
the Company to financial loss, fines, civil money penalties, payment of damages,
and the voiding of contracts. Compliance risk can lead to diminished reputation,
reduced Company value, limited business opportunities, reduced expansion potential,
and an inability to enforce contracts. In general the Company has enhanced the compliance
of all departments according to regulatory requirements.
Compliance risk is limited to a significant extent due to the supervision applied
by the Compliance Officer, as well as the monitoring controls and systems applied
by the Company.
1.8 Reputation Risk
Reputation risk is the current or prospective risk to earnings and capital arising
from an adverse perception of the image of the Company by Clients, counterparties,
shareholders, investors or regulators. Reputation risk could be triggered by poor
performance, the loss of one or more of the Company’s key directors, the loss of
large Clients, poor Client service, fraud or theft, Client claims, legal action,
regulatory fines and from negative publicity relating to the Company’s operations
whether such fact is true or false.
The Company has policies and procedures in place when dealing with possible Client
complaints in order to provide the best possible assistance and service under such
circumstances. The possibility of having to deal with Client complaints is low,
compared to the high amount of the Company’s Clients, as the Company does its best
to provide high quality services to its Clients and has the appropriate procedures
in place. In addition, the Company’s Board members and Senior Management is comprised
of experienced professionals who are recognized in the industry for their integrity
and ethos, and, as such, add value to the Company.
In the few occasions which the Company had dealt with Client complaints, the Company
has successfully resolved the relevant complaints.
1.9 Online Fraud
Online fraud could occur when Clients illegally use the credit cards or other online
payment methods of others in order to fund their accounts with the Company. This
risk exposes the Company to monetary loss and to potential implications with the
credit cards’ issuers.
The Company has developed robust risk management technology to identify fraudulent
transactions. To this end, the Company employs the Risk Rule Engine Alerting and
Flagging System to prevent and identify online fraud.
Following an alert/flag by the Company’s Risk Rule Engine Alerting and Flagging
System, the Company investigates the relevant account(s) to establish whether the
transaction(s) in question are indeed fraudulent. In case the Company establishes
that fraud activity has been performed, the Company then refunds the funds to the
original mean of payment (i.e. to the real payment account holder).
When there is unauthorized access to credit card data that results in financial
loss, there is the potential that the Company could experience reputational damage
and parties could seek damages from the Company.
1.10 Information Technology Risk
Information Technology (hereinafter, “IT”) risk could occur as a result of inadequate
information technology and processing, or arise from an inadequate IT strategy and
policy or inadequate use of the Company’s IT. Specifically, the company recruited
an IT Manager, policies have been implemented regarding improved backup procedures,
software maintenance, hardware maintenance, improved security policies, use of the
internet, anti-virus procedures and monitoring systems. Materialization of this
risk has been minimized to the lowest possible level.
3.1 The Ongoing Financial Crisis
The Company’s business primarily involves the offering of investment services relating
to non-deliverable foreign exchange, mainly to Retail Clients. Despite the ongoing
uncertainty over the global economic conditions and the volatility of the financial
markets during the period under review, the activity level of the retail foreign
exchange market has endured the financial crisis relatively better than most other
investment firms involved in other type of investment services and/or financial
instruments, and, as such, the Company’s business has not been significantly affected
by the ongoing financial crisis. Nevertheless, the Company is closely monitoring
the effects of the ongoing global financial crisis, and it is ready to take the
relevant actions when and where necessary.
3.2 Data Retention Policy
The Company pays particular attention to its data retention. To this end, the Company
conducts frequent backups with respect to all the Company’s IT systems for all types
of data and information and stores these backups at a safe remote location outside
the Company’s head offices.
eToro (Europa) Ltd., una empresa de servicios financieros autorizada y regulada por la Comisión del Mercado de valores de Chipre (CySEC) con la licencia n.º 109/10.
eToro (Reino Unido) Ltd, una empresa de servicios financieros autorizada y regulada por la Autoridad de Conducta Financiera (FCA) con la licencia FRN 583263.
Desempeños anteriores no son una indicación de resultados futuros.
Los Contratos por diferencias (CFD, por sus siglas en inglés) son productos apalancados. La negociación de CFD vinculados a divisas, valores, materias primas, índices financieros y otras variables subyacentes implica un riesgo elevado que puede conllevar la pérdida total de la inversión. Por esta razón, los CFD pueden no ser adecuados para todos los inversores. No invierta dinero que no pueda permitirse perder. Antes de empezar a invertir debe conocer todos los riesgos asociados a las transacciones con CFD y solicitar consejo a un asesor financiero independiente que cuente con una licencia apropiada. Bajo ninguna circunstancia asumimos responsabilidad ante ninguna persona física o jurídica por (a) pérdidas o daños, totales o parciales, derivados, resultantes o relacionados con transacciones asociadas a CFD; (b) daños directos, indirectos, especiales, consiguientes o incidentales de ninguna índole. Realizar transacciones con siguiendo, copiando o replicando las operaciones de otros inversores conlleva un elevado nivel de riesgo, incluso si se siguen, copian o replican las inversiones de los mejores. Entre dichos riesgos se encuentra el que pueda estar siguiendo/copiando las decisiones de inversores inexpertos/no profesionales, así como el riesgo general inherente a las transacciones con CFD o al hecho de seguir a inversores cuyos objetivos o propósitos, o su situación financiera, sean diferentes de los suyos. Las rentabilidades históricas de cualquier inversor que aparezca en la comunidad no constituyen un indicador fiable de sus rentabilidades futuras. El contenido de la comunidad es generado por sus integrantes y no contiene ningún consejo ni recomendación por parte, o en representación, de eToro Online Trading. No garantizamos, avalamos ni respaldamos la exactitud, puntualidad, integridad o idoneidad de los datos y/o herramientas disponibles en nuestros sitios web, ni de las comunicaciones que le enviamos. Esos datos y herramientas los facilitamos exclusivamente para ayudarle a tomar sus propias decisiones de inversión, y no constituyen una recomendación de invertir ni promociones financieras no solicitadas.
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