London Stone Securities Ltd

Limits on what they may do

• No regulated activity

  (1) The Firm must immediately cease carrying on all regulated activities for which it has a Part 4A permission, other than where it has the express written consent of the Authority, given subsequent to the issuance of the First Supervisory Notice, to carry on a regulated activity (or activities); (2) The Firm must not on-board any new customers

• No further fees to be taken from clients

  (3) With immediate effect, the Firm must not charge its clients any further fees (including, but not limited to, annual management fees, inactivity fees and commission payments), other than where it has the express written consent of the Authority

• Assets requirement

  (7) Save as set out in sub-paragraphs (8) and (9) below, 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 of its own assets, and any funds it holds for, or to the order of, its customers or investors (whether in the United Kingdom or elsewhere), whether held by the Firm as at the date of the imposition of the Requirements or acquired thereafter; (8) The Firm may continue dealing with or disposing of any of its own assets in the ordinary and proper course of business provided that the sum or value of such dealings or disposals, whether as a single transaction or a combination of related transactions, does not exceed £1,000 (or £3,000 in the case of legal expenses); (9) For the avoidance of doubt, for the purposes of sub-paragraph (8) above, the following would be in the ordinary and proper course of business: (a) Any fees incurred or paid in exchange for professional advisory services provided to the Firm; or (b) Any salaries of the Firm’s staff, including to its directors, contractors or any other employees, where such salaries have been agreed prior to the imposition of the Requirements; (10) For the avoidance of doubt, for the purposes of sub-paragraph (8) above, the following would not be in the ordinary and proper course of business: (a) The making of any distribution to the Firm’s shareholders whether by way of capital distribution or dividends; (b) Subject to sub-paragraph (9)(b) above, any payment to the Firm’s shareholders, directors, officers, employees, any connected entities or persons; (c) The making of any gift or loan by the Firm to any party; or (d)The entry into any financial reconstruction, sale of any part of the Firm (whether share or asset based) or reorganisation. (11) Sub-paragraphs (7) to (10) constitute an assets requirement within the meaning of section 55P(4)(a) of the Act.

• Notification requirements

  (12) By 5pm on 16 April 2024, the Firm must publish in a prominent place on every website in its name (or that it operates) a notice setting out the terms and effects of the Requirements and the actions its clients can take to access their funds. The wording of this notice must be agreed by 5pm on 15 April 2024 with the Authority. (13) The Firm must, by 5pm on 16 April 2024, notify any investor, potential investor, or other relevant person directly affected by the Requirements of the terms and effect of the Requirements. The wording of this communication and the method of delivery must be agreed by 5pm on 15 April 2024 with the Authority. (14) Once the notifications referred to in sub-paragraphs (12) (12)and (13) above have been made, within 24 hours, the Firm must supply to the Authority: (a) Copies of the template notifications sent to all recipients; (b) A list of all parties to whom notifications have been sent; and (c) Confirmation that, to the best of its knowledge, the Firm has sent the specified notifications to all relevant parties. (15) The Firm must provide to the Authority, by no later than 12 noon each Friday until such time as is notified otherwise in writing by the Authority (starting from the first Friday after the imposition of the Requirements), account statements for all of the Firm’s bank accounts, e-money accounts and cryptoasset accounts showing all transactions for those accounts for the preceding seven days.

• Records Retention

  (16) The Firm must secure and preserve all records and/or information (physical or electronic) relating to its business, including payment, electronic money and digital services in their original form, or in a copy, provided it is identical to the source material. 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 on16 April 2024, such that they can be provided to the Authority, or a person named by the Authority, promptly on its request. (17) The Firm must provide written confirmation to the Authority that it is in compliance with the Requirements by 5pm on 16 April 2024.