Halo Financial Limited

Limits on the record

• Voluntary Undertaking Effective 30 April 2026

  With Immediate effect, the Firm undertakes to comply with the following requirements (“the Requirements”) as set out below: Business Restriction (cease activity) 1. The Firm must not, without the prior written consent of the Authority: (a) conduct any payment service as defined in regulation 2(1) of the Payment Services Regulations (“PSR”); (b) register and/or onboard any new customers. (c) accept any additional funds or account credits from any existing customers; or (d) open any new FX trades or positions. Notification 2. By 4pm on 1 May 2026, the Firm must notify in writing all customers of the imposition and effect of these Requirements in a form to be agreed in advance with the Authority. 3. By 4pm on 1 May 2026, the Firm must display, in a prominent place on its website, its customer log in portal page, and any other communication channels or contact method by which the Firm communicates with customers (e.g. mobile applications, other digital channels, etc), a notice setting out the terms and effects of these Requirements in a form to be agreed in advance with the Authority. Asset Restriction 4. Subject to paragraph 5, the Firm must not, without the prior written consent of the Authority, in any way dispose of, withdraw, transfer, deal with or diminish the value of any funds held in its operational accounts, including but not limited to the Firm’s accounts held with The Currency Cloud Limited and Crown Agents Bank Limited. 5. The asset restriction at paragraph 4 does not apply to the disposal of assets or monetary payments made by the Firm in the ordinary course of business. 6. For the purposes of the preceding paragraph; a. the following are payments made in the ordinary course of business: i. payments to the Firm’s suppliers or other third parties in satisfaction of the Firm’s contractual and/or legal obligations (including but not limited to payments of or on account of professional fees or expenses, including but not limited to legal, compliance and/or other professional fees or expenses of any professionals or consultants appointed by the Firm to advise in connection with its wind down or otherwise); and/or ii. usual and proper salary payments made by the Firm (which had been agreed prior to the Effective Date). b. the following are not made in the ordinary course of business: i. payments of unusual or significant amounts to the Firm’s controllers, shareholders, directors, officers, employees or any connected persons (whether as a single transaction or a combination of related transactions); ii. the making of any capital distribution or payment of any dividend; iii. the making of any gift or loan by the Firm to any party; and/or iv. payments made as part of any financial restructuring or reorganisation of its business, of from the sale of any part. Records retention 7. The Firm must make all reasonable efforts to secure and preserve all records and/or information (physical or electronic) relating to its business in their original form, or in a copy provided it is identical to the source material. In the event that the firm is unable to access certain records it should secure and preserve those that it has access to as above. These must be retained in a form and at a location within the United Kingdom, to be notified to the Authority in writing by 5pm on 7 May 2026, such that they can be provided to the Authority, or to a person named by the Authority, promptly on its request. Reporting 8. The Firm must continue to provide the Authority with a written update by 12 noon every Thursday, beginning on 7 May 2026 until such time as it is notified otherwise in writing by the Authority, with confirmation that it is in compliance with these Requirements. 9. For the avoidance of doubt, the Firm must continue to comply with its reporting obligations in accordance with the previous undertakings given to the Authority.