1. Introduction
1.1 Gametech (Cyprus) Ltd (hereafter the "Company") is an Investment Firm incorporated and registered under the laws of the Republic of Cyprus, with registration number C342580. The Company is authorised and regulated by the Cyprus Securities and Exchange Commission (hereafter the "CySEC") under the license number 291/16. This Dormant Account Policy sets forth the Company's policy and methodology for the treatment of the Client Dormant Accounts.
2. Scope
2.1 The Dormant Account Policy lays down the procedure to be followed regarding the Dormant Client accounts and the procedure to be followed when receiving an instruction for an account which is classified by the Company as Dormant. This policy gives full description of the time period and method considered for classifying an account Dormant and also various steps required to be adhered for re-activating such Dormant accounts.
3. Definition
3.1 An account shall be classified to be Dormant if it is inactive or remains non-operational without any trading activity by its holder for a specified period of time. The dormancy period for all customer accounts will stand at 6 (six) months. For instance, if no trading transactions have been carried out in relation to the account by the holder of the account for a minimum period of 6 months, it will be classified as a Dormant account.
3.2 If an account continues to be dormant for another 6 months (12 in total), then the company will consider this account to be Closed on the first day after 12 months of no transactions, and will take all necessary measures for closing the account including deleting any Bonus / Premiums that was credited to the account and remained unused.
3.2 The Company will not consider a Client's account of paragraph 3.1 above to be Dormant in the following cases:
4. Application
4.1 The Back office department reviews and identifies inactive accounts at least every 6 months.
4.2 If inactive accounts satisfy provisions of paragraph (3.1) above then are classified as "Dormant accounts".
4.3 The Dormant accounts will be frozen immediately and the Client will not be permitted to undertake any further transaction in such dormant account.
4.4 The Back office department sends a request to the accounting department to check for any pending financial obligations.
4.5 If there are financial obligations the accounting department informs the Back-Office Department which confirms the pending obligation with the client if possible.
4.6 The Back Office Department ascertains reasons for non-operation, and requests Clients to close the accounts if they are no longer required:
i. In case of Client's consent to close the accounts the pending Financial obligations are settled (transfer of clients funds to the account designated by the client) and the Back-office department informs in writing the client about the termination of his/her account.
ii. In case the Client wishes to keep his/her account then KYC/CDD procedures as described in Company's IOM are applied.
iii. In case the Back-office Department cannot establish contact with the Client the "Dormant Accounts" are classified as "Dormant Whereabouts Unknown" (DWAU)". DWAU accounts are freeze.
4.7 DWAU accounts are frozen and the Client will not be permitted to undertake any further transaction in these accounts. In case of possible request from an owner of a DWAU account for a transaction the Company will apply KYC/CDD procedure as described in Company's IOM and if is satisfied that he/she is the real owner of the account it will reactivate the account.
5. Account Maintenance Fee Policy
5.1 The Company will be charging an Account Maintenance Fee (AMF) on all client accounts that are deemed dormant after the time period of 6 months. The monthly AMF will be Euro 10 per month and will be charged and debited from the balance of the specific account.
5.2 This Account Maintenance Fee (AMF) of Euro 10, will be charged monthly, as long as the client account has the required funds available.
5.3 The Company will be reimbursing / refunding the Account Maintenance Fee (AMF) on all dormant client accounts that are re-activated. A re-activated account will be deemed to be any dormant account that a Client makes a new minimum amount deposit to his/her dormant account, and conducts at least 1 trade with the company.
6. Monitoring and review
6.1 The Company will review and monitor the effectiveness of this Dormant Accounts Policy and arrangements to identify and, where appropriate, correct any deficiencies. It will assess, at least on a yearly basis the efficiency of the procedures set in this Policy.