ZYC-CLC-001 Client Categorisation Policy
(Applies to all Zeyro staff, directors, contractors, and consultants — Updated October 2025)
Background
Zeyro’s clients are always businesses, not individuals. We provide two types of regulated activity:
Financial Promotion Approvals — for unregulated cryptoasset firms and overseas fund managers.
These clients are businesses seeking compliance with UK financial promotion rules.
Categorisation under COBS 3 does not apply because Zeyro is not providing a regulated service to them.
Facilities Services (MiFID Arranging) — for authorised fund managers.
These clients are categorised as Professional Clients (per se or elective).
Zeyro does not provide services to Retail Clients or Eligible Counterparties.
This policy sits within the Conduct & Governance Suite and supports:
Our Business-Wide Risk Assessment (BWRA).
Purpose
To ensure Zeyro:
Accurately records the nature and regulatory status of all business clients.
Applies the correct MiFID client categorisation where relevant.
Maintains evidence that no Retail Clients are serviced in any business line.
Scope
Applies to all business clients engaging Zeyro for:
Financial promotion approvals; or
Facilities (arranging) services under MiFID.
Key Principles
1. Business-Only Clients
Zeyro contracts only with incorporated entities, authorised firms, or other legal persons.
We do not onboard individuals or sole traders.
All client structures are verified through DotFile KYB before engagement.
How this controls our risks: Prevents exposure to retail investors or unverified individuals.
2. Financial Promotion Clients
Firms seeking approval of financial promotions are not categorised under COBS 3, as Zeyro does not perform a regulated service for them.
However, reviewers must still consider the intended target audience of each promotion to ensure it is suitable for its stated category (e.g., retail or professional end users).
This assessment is recorded in Jira as part of the approval workflow.
How this controls our risks: Ensures that while our clients are professional firms, the audience of the promotions they create is always properly considered.
3. Facilities Services Clients (MiFID Arranging)
All facilities service clients are Professional Clients under COBS 3.5.
Most are per se professional (authorised fund managers); others may be elective professional if they meet the qualitative and quantitative tests.
The MLRO/Compliance Officer must approve all elective professional classifications and retain supporting evidence in Confluence.
Zeyro does not provide arranging services to Retail Clients or Eligible Counterparties.
How this controls our risks: Confirms Zeyro’s MiFID obligations are limited to professional firms with appropriate expertise.
4. Verification and Record Keeping
Client categorisation is confirmed and recorded within client contracts, which specify the nature of the engagement and the client’s regulatory status.
Zeyro does not currently maintain separate categorisation logs in DotFile or Confluence, as all clients are business entities and contractual evidence provides sufficient auditability.
Supporting evidence (e.g., regulatory permissions or elective professional confirmations) is retained with the contract file.
The MLRO reviews client classifications annually as part of the Business-Wide Risk Assessment (BWRA).
How this controls our risks: Ensures categorisation evidence is preserved in a single authoritative source while maintaining proportional governance for a business-only client base.
5. Oversight and Review
The MLRO is responsible for ensuring this policy remains consistent with COBS 3 and MiFID II obligations.
Any material change to Zeyro’s business model (e.g., onboarding retail clients) would trigger an immediate policy review and FCA notification if required.
How this controls our risks: Ensures Zeyro’s categorisation framework stays proportionate to its activities.
Document Control
Field
Details
Policy Code
ZYC-CLC-001
Policy Title
Client Categorisation Policy
Document Owner
Gareth Malna – MLRO (SMF 16 & 17)
Responsible Reviewer(s)
Zeyro Board
Version
v 1.1
Date Approved
October 2025
Next Scheduled Review
October 2026
Last Reviewed By
Gareth Malna
Change History
v1.0 (Oct 2025): Initial draft. v1.1 (Oct 2025): Updated to clarify business-only client base, non-applicability of COBS 3 to financial promotions, and exclusive use of professional categorisation for facilities clients.
Classification
Internal policy – distributed to all staff; available to regulators on request.
Last updated