Our client was a third country broker active in CFD trading and portfolio management. Although not regulated by the FCA, on occasion they would have UK clients. Any fees from these clients would go to their correspondent bank. The situation arose where the correspondent bank would not release a significant amount due to concerns around regulatory compliance.
Having reviewed the clients offering and the way the UK clients were obtained, we provided a reverse solicitation opinion. The opinion satisfied their bank and it released the funds to our client. Further, we worked with our client in improving their governance arrangements and systems in order to block any inadvertent cross-selling efforts or overly leveraged CFD trades.