Strowz Ltd

Limits on what they may do

• Restriction on Activities

  Restriction on Activities 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. 2. The Firm must not accept any further client money (from the Firm’s clients or any other third party) into any of the Firm’s bank accounts. Should the Firm receive further client money from its own clients following the imposition of the Requirements: (i) the Firm must notify the Authority of this by email within 48 hours of receipt of such money; and (ii) the Firm must take all reasonable steps to return such money as soon as is reasonably practicable. 3. The Firm must not move or facilitate the movement of client assets, client money or clients, including onboarding, off-boarding or transfer(s), without the prior written consent of the Authority. 4. The Firm must notify the Authority about any additional bank account(s) it intends to open. 5. The Firm must, by 4:00pm on 4 April 2025, disclose to the Authority all bank account held or previously held in the Firm’s name or in the Firm’s previous name.

• Asset Requirement

  6. Save as set out in paragraphs 7 and 8 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 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. 7. 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). 8. For the avoidance of doubt, for the purposes of paragraph 7 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. 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. 9. For the avoidance of doubt, for the purposes of sub-paragraph 7 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 paragraph 8(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 the entry into any financial reconstruction, sale of any part of the Firm (whether share or asset based) or reorganisation.

• Retention and Notification Requirements

  11. The Firm must secure all books and records and preserve all information, including both physical material and that held via online/cloud-based systems to which the Firm has access. 12. These books, records and information must be retained in a form and at a location within the UK to be notified to the Authority within 24 hours of the receipt of this notice. The records must be retained in a form and at a location such that they can be provided to the Authority, or to a person named by the Authority, promptly upon its request. 13. The Firm must publish in a prominent place on all websites and social media accounts in its name (or that it operates including but not limited to https://marketsflow.com/ and https://strowz.com/) notices setting out the terms and effects of these Requirements, with the content of the notice(s) to be agreed in advance with the Authority. 14. A Senior Management Function holder of the Firm must provide written confirmation to the Authority by email weekly by 2:00pm each Friday, until such time as it is notified in writing by the Authority that it may cease to do so, that it is in compliance with these Requirements.