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Risk Appetite

Last updated 21 June 2021
X1 Risk Appetite Policy
Risk Strategy
Whilst success for X1 is measured by the ability to grow the business profitably, its long term strategic goals are:
  • To increase the profitability of the business by delivering a service that meets customer expectations;
  • To deliver greater control over trading risk management and, as a result, the long term stability of the company;
  • To ensure absolute regulatory compliance in all jurisdictions X1 operates.
As a regulated company, X1 must hold capital to meet uncertainties and mitigate risks. Risks and uncertainties primarily arise from trading activity but also arise from associated commercial activities such as operations and strategy.
X1 Risk Strategy aligns its risk profile (including regulatory responsibilities) with strategic plans through a clear risk appetite. This facilitates the identification and mitigation of risks that might prevent the company from achieving its business objectives as well as consistently enabling it to execute its business based on objective assessment of risk and reward.
The X1 team takes both a prudent and conservative approach to risk in line with intended business development and strategic business plans. Risk strategy and appetite are formed with an objective of being able to run at significantly reduced revenue, due to loss of business or systemic events like individual market shocks for a prolonged time, without materially impacting the business or the fulfilment of its regulatory obligations.
The X1 team agrees that the specific ways in which risk may be mitigated (e.g. through holding additional capital, implementing controls, or by defining management actions or behaviours) and its appetite or tolerance for the risks affecting the business. The CEO also defines the amount of exposure to, or potential adverse impact from, internal or external events that it is willing to accept. This document provides a summary of the company’s risk appetite and the associated tolerances.
The detailed assessment of risks is subject to review at least annually or more frequently to reflect changes in strategy, regulatory obligations, or the profile of the risk facing the business.
Recognised Risks
The Company has categorised risks into low, medium, and high risk. 
Implementation of the Risk Appetite
X1 creates all of its internal rules and procedures with due reference to this Statement of Risk Appetite. Modifications to internal rules or procedures or changes in business strategy will be made only after an assessment of the risks including reference to the company’s risk appetite.
Risk Appetite Oversight
The Statement of Risk Appetite forms the cornerstone of the business operations and will be reviewed and approved by the CEO at least annually or more frequently to reflect changes in strategy, regulatory obligations, or the profile of the risk facing the business.
Risk Appetite Disclosure
Where appropriate and mandated under applicable law and regulatory framework, the company discloses its Statement of Risk Appetite with its clients and business partners.
Summary of Risk Appetite

Risk Classification


Risk Tolerance


High Risk

> EUR 100 000

Case by case basis. Additional KYC always requested

Within appetite

Medium Risk

EUR 15 000 – EUR 100 000

Case by case basis. Аdditional KYC requested if questionable activity

Within appetite

Low Risk

EUR 15 000 and below

Case by case basis. Аdditional KYC requested if questionable activity

Within appetite


(Politically Exposed Person)

Not Applicable

Not tolerated

Not within appetite


X1 does not currently provide services to citizens of the following countries and territories:

Afghanistan, American Samoa, Antarctica, Burkina Faso, Burundi, Cameroon, Canada, Central African Republic, Chad, Comoros, Congo Rep, Cuba, DR Congo, East Timor, Eritrea, Gambia, Guinea-Bissau, Haiti, Iran, Iraq, Japan, Kiribati, North Korea, Lao, Lebanon, Liberia, Libya, Mali, Marshall Islands, Micronesia, Mozambique, Myanmar/Burma, Namibia, Netherlands, Niger, Nigeria, Palestine, Papua New Guinea, Solomon Islands, Somalia, South Korea, South Sudan, Sudan, Syria, Switzerland, Tajikistan, Tuvalu, United States, Venezuela, Virgin Islands (U.S.), Western Sahara, Yemen, Zimbabwe.