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Course Description

This course analyses the various FX broker models and explains how (a) Dealing Desk (DD) FX broker/ Authorised Market Maker, (b) Non-Dealing-Desk (NDD) or ‘Straight through processing’ Model (STP) and (c) Non-Dealing Desk (NDD STP+ECN) operate.

Investment Firms must maintain and operate effective organisational and administrative arrangements with a view to taking all reasonable steps designed to prevent conflicts of from adversely affecting the interests of its clients.

There are certain business model characteristics and practices that give rise to particular conflicts of interest which are often observed in firms offering CFDs and other speculative products to retail clients. Many of these conflicts of interest arise as a result of the remuneration models adopted by firms in this sector like for example when the firm is the other side of the client’s trade or if the firm or other relevant parties are remunerated based on the volume or value of trades placed by retail clients speculating in CFDs and rolling spot forex.

Investment Firm’s arrangements shall ensure that the management body defines, approves and oversees a remuneration policy of persons involved in the provision of services to clients aiming to encourage responsible business conduct, fair treatment of clients as well as avoiding conflict of interest in the relationships with clients.

When entering into any commercial arrangement with a third party or an intra-group entity, the Company should identify, assess, manage, and disclose any conflict of interests arising from such an arrangement, including those arising as a result of the terms of the remuneration arrangements between the two parties.

An Investment Firm must ensure, when relying on a third party for the performance of operational functions which are critical for the provision of continuous and satisfactory service to clients and the performance of investment activities on a continuous and satisfactory basis, that it takes reasonable steps to avoid undue additional operational risk.

In the case that outsourcing would conclude to the transfer of functions of the Company to such a degree which renders the Company a letter box entity, this is considered to undermine the conditions for authorisation of the Company.

Topics covered

The course is split into the following sections:

Section 1: Description of different broker models

  • Dealing Desk (DD) FX broker/ Authorised Market Maker
  • Non-Dealing-Desk (NDD) or ‘Straight through processing’ Model (STP)
  • Non-Dealing Desk (NDD STP+ECN)
  • Dealing Desk + Non-Dealing Desk- White Labelling Model
  • Managed account services or allow retail customers to access the FX market
  • Copy – Trading

Section 2: Conflicts of interest arising from business models

  • Conflicts of interest arising from business models that may be adopted by firms offering speculative products (i.e. CFDs) to retail investors
  • Assessment of Conflict of interest
  • Conflict of interest due to remuneration arrangements
  • Circular C181- critical or important operational functions
  • Market makers and other models – associated risks

Section 3: Outsourcing and Risks arising from payment for order flow

  • Legal Framework
  • Outsourcing activities
  • Risks arising from payment for order flow and from certain practices by “zero-commission brokers”

    Course Duration:

    This course may take up to 5 hours to be completed. However, actual study time differs as each learner uses their own training pace.

    The course is addressed to:

    This course is addressed to all individuals who are involved in Investment Firms (forex, brokers, etc) such as:

    • Executive Directors, Non-executive directors, Senior Managers
    • Compliance Officers, Risk Managers, Product Managers, Portfolio Managers, Investment Advisors, Dealers, Marketing Managers and in general employees of investment firms.
    • Internal Auditors
    • Consultants

    It is also suitable to professionals pursuing CPD in Regulatory Compliance for the renewal of CySEC Certificate (CySEC Basic or CySEC Advance Certificate) or other relevant certificates in other jurisdictions.

    Training Method

    The course is offered fully online using a self-paced approach. The learning units consist of power point presentations. Learners may start, stop and resume their training at any time.

    At the end of the course, participants take a Quiz to complete the course and earn a Certificate of Completion once the Quiz has been passed successfully.

    Accreditation and CPD Recognition

    The course may be accredited by regulators and other bodies for up to 5 CPD Units, that require CPD training in financial regulation. The course may be also approved for up to 5 CPD Units by institutions that approve general financial training, such as the CySEC, ICPAC, CBA and CISI.

    Eligibility criteria and CPD Units are verified directly by your association or other bodies in which you hold membership.

    Registration and Access

    To register to this course, click on the Take this course button to pay online and receive your access instantly. If you are purchasing this course on behalf of others, please be advised that you will need to create or use their personal profile before finalizing your payment.

    Access to the course is valid for 60 days.

    If you wish to receive an invoice instead of paying online, please Contact us by email. Talk to us for our special Corporate Group rates.


    George Papanicolaou has more than 20-years experience in the Financial industry. He worked for several years in managerial positions as area Manager, Head of Brokerage, Compliance Officer, Anti Money Laundering Officer, General Manager and Executive Director in Cypriot Investment Firms as well as Managing Director of GP GLOBAL LTD offering consulting services and training courses to Investment Firms, focuses in Internal Audit, compliance & AML issues. He offered numerous courses/seminars both in Cyprus and abroad in Investment Firms Law as well as in Compliance & Anti Money Laundering. George Papanicolaou is also a Chairman of a Nomination Committee in a company listed in the Oslo Stock Exchange.

    George Papanicolaou holds a BSc in Electronic Engineering from the University of Texas at Austin (USA), an MBA with specialization in Finance from Leicester University (UK) and a Postgraduate Certificate in the Mechanics of Risk Management from Middlesex University (UK).

    He also holds an ICA International Diploma in Anti Money Laundering from the International Compliance Association and the University of Manchester, as well as an Advance and Money Laundering certificate from the Cyprus Securities and Exchange Commission for the provision of investment services/activities.

    He is a Fellow of the International Compliance Association (FICA), Mentor of ICA new students, member of the Cyprus Institute of Internal Auditors and Network chair for Cyprus of the International Compliance association.

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    Course Description (click to download)