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Greeks are very worried as a constant stream of threats have been coming from Ak Sarayi the last couple of years.There was an interesting article published on March 28, 2018, in the “The Weekly Standard” (a US conservative publication, dubbed “the in-flight magazine on Air Force One” during the Bush years).Greece vs. Turkey: Are We Headed for an Intra-NATO War?The Aegean Sea between Greece and Turkey hosts one of the world’s highest concentrations of high-tech weaponry. Sixty-seven surface ships and two dozen submarines are deployed on a body of water the size of Lake Superior. The two air forces command 448 fighter jets armed with smart bombs and guided missiles. On land, 832 heavy tanks and more than 2,500 lighter artillery vehicles—as much tank firepower as in all the rest of Europe combined—could rapidly be brought to bear along a Greek-Turkish border only 105 miles long.These arsenals, built up over decades and constantly modernized, were not merely a boon to U.S. and German defense contractors. Western policymakers wanted to believe that loyalty to NATO’s mission of containing the USSR, rather than regional rivalries, motivated this exemplary level of Greek and Turkish defense spending. After the Soviet Union collapsed, good diplomacy and Turkey’s EU aspirations made it possible, most of the time, to overlook the downsides of an arms race between uneasy neighbors. Recently, however, the Aegean has become a dangerously narrow sea.For decades, Turkish military aircraft have regularly violated Greece’s 10-mile airspace around its islands, on the grounds that Greece’s territorial waters extend only six nautical miles from shore, and that air and sea borders should match. Turkish ships also ignore the territorial waters around a number of small islands whose Greek ownership Turkey questions. These ships and planes are intercepted by their Greek counterparts, and mock dogfights result. Occasionally fatal accidents occur.Kostas Grivas, who teaches advanced weapons systems at the Hellenic Army Academy, calls it a “a unique theater of confrontation,” where “land, sea and air forces are simultaneously in use in a very confined area, and there is an enormous amount of weapons systems and men-at-arms in deployment.” In the event of war, he believes, it would be very difficult to maintain command-and-control systems because of the intensity and speed of activity, meaning heavy fratricidal losses. In such chaos, the outcome might ultimately be up to local commanders’ ability to take intelligent initiatives. An Aegean war, Grivas says, would resemble “a mini-nuclear war because there will be so much high-tech ordnance discharged it will cause a huge amount of damage.”The prospect of such hostilities has been suddenly brought closer this year, following events that are individually and as a series without parallel in recent decades.Last autumn, Greek foreign minister Nikos Kotzias expressed concern that Turkey had become an “irritable power.” What inspired this concern was a record 3,317 airspace and 1,998 territorial water violations recorded in the Aegean last year—respectively double and quadruple the previous year’s numbers. “Our job is to behave responsibly,” Kotzias declared, so he invited Recep Tayyip Erdogan to become the first Turkish president in six decades to visit Greece.Recep Tayyip Erdogan’s December 7 visit was a disaster. On its eve, Erdogan gave an interview calling for revisions of the Lausanne Treaty of 1923. This is the treaty that defines the borders of the modern Turkish state, while guaranteeing the rights of Greek and Muslim minorities in the two countries. It has kept Greece and Turkey at peace for a century and forms the bedrock of their détente. No Greek or Turkish head of state or government had ever publicly called for its revision. Greece’s President Prokopis Pavlopoulos reacted by overstepping his role as ceremonial head of state to lecture Erdogan. Lausanne, he asserted, was “non-negotiable.”"It has no gaps. It needs neither revision nor updating. It stands as it is, it covers absolutely the issues that it needs to cover, and stresses that among other things it leaves no leeway for gray zones or minority issues," Pavlopoulos said.Erdogan gave as good as he got. Greece had plunged its Muslim minority into poverty, he said, and is racially prejudiced against it. Erdogan also demanded of Prime Minister Alexis Tsipras the extradition of ten Turkish military officers who fled to Greece after the failed July 2016 coup. The Greek Supreme Court had barred their extradition on the grounds that their lives would be endangered in Turkey. The government cannot overrule the decision and there is no higher court of appeal, but Erdogan insisted: “What I told Mr. Tsipras is that these putschists may be returned to Turkey, a country that has abolished the death penalty, a country where torture does not take place.”Kotzias’s charm offensive has since collapsed. A planned February revival of the Greek-Turkish Supreme Council, a diplomatic forum, never took place, and a May visit to Athens by the Turkish foreign minister is very much in doubt. But there is worse.On February 12, a Turkish coast guard vessel rammed a Greek one while performing what the Greek coast guard called “dangerous maneuvers inconsistent with international collision avoidance practices.” Turkish Prime Minister Binali Yildirim called Tsipras to explain that the ramming was accidental; but the fact that it happened near Imia, a pair of Greek islets whose ownership Turkey has disputed for 20 years, suggests to the Greeks a territorial power play.Turkey upped the ante on the last day of February, arresting two Greek officers who apparently strayed into Turkish territory while on a routine patrol on the Thracian border. The standard practice for both sides during the last three decades has been to return wayward patrols at the nearest checkpoint after a routine procedure. Turkish authorities instead jailed the men and charged them with illegal entry. More serious charges may follow. Greek Defense minister Panos Kammenos refers to the two soldiers as “hostages,” and Greek public opinion takes for granted their seizure as connected with the ten Turkish military fugitives.Since these incidents, polls say 92 percent of Greeks believe Turkey constitutes Greece’s biggest threat. Is Turkey generating grievances as a pretext for war? Who would gain from such a war? How would America react? And why has Erdogan chosen this moment to escalate tension?Brinkmanship in 1996: preview of a far worse confrontation?“What I worry about is the risk of an unintentional confrontation,” says U.S. ambassador to Athens Geoffrey Pyatt. Greece and Turkey nearly did stumble into war two decades ago. On Christmas Day 1995, the Figen Akat, a small Turkish cargo ship, ran aground on the western twin islet of Imia. A Greek tug was dispatched to refloat her, but the Turkish captain refused Greek help, saying he was in Turkish territorial waters. He eventually accepted Greek assistance, but not before the Turkish government had voiced a claim to the Imia islets as Turkish.In the new year, the mayor of the largest nearby Greek island, Kalymnos, hoisted a Greek flag on Imia. The owners of a newly-licensed Turkish television channel CNN Turk decided to boost ratings by filming two journalists replacing the Greek flag with a Turkish one. Prime Minister Tansu Ciller fueled the fire. “We can’t let a foreign flag fly on Turkish soil. The flag will come down,” she said.“The Turkish claims have no basis at all. There is no space for negotiations in … matters which concern our sovereignty,” said Greek Premier Kostas Simitis. Greece landed special forces on one of the two islets while Turkish frogmen took the other. As many as 20 Greek and Turkish ships and submarines converged on Imia (or Kardik, as the Turks call it).On January 31, the United States intervened to avert an unintended war. “In 1996 the Americans stepped in and that sobered both sides,” says retired ambassador Christos Rozakis, one of Greece’s leading experts on international law. “We parted under the understanding, “no ships, no flags,” and reverted to the status quo ante. It wasn’t exactly that, but until the latest incident it was almost that. Greek shepherds didn’t herd their goats there any more, but neither did Turks go there.”Treaties vs. politicsImia stands as a textbook case of calculated escalation leading to the brink of an unintended war, and conditions now are even more conducive to such a war than they were in 1996, because new causes of instability have been added to older ones.The underlying tensions go back decades. “Turkey never got over the fact that the Lausanne Treaty shut them off behind a wall of Greek islands, and they are trying to overturn this incrementally,” says Rozakis. “They can’t ask for Rhodes, which is clearly inhabited by Greeks, but they are trying to create conditions to extend themselves into the Aegean, and position themselves for future talks.”Those future talks are important, because Greece and Turkey have a number of unsettled jurisdictional issues. Under international law, Greece can claim territorial waters of 12 nautical miles around each of its islands, but Turkey threatens to wage war if Greece does so, claiming the Aegean, as a semi-enclosed sea, is a special case. And the two countries have yet to apportion the continental shelf and settle rights to mineral deposits on and under the sea floor. Exploratory talks have been ongoing since 2000, but Turkey broke them off last summer.Turkey has instead escalated to questioning not the jurisdiction of islands but their very ownership. “In the 1990s, various papers started circulating from [Turkish] think-tanks that took a legalistic approach, and said that if an island or islet or rock isn’t specifically mentioned in an international treaty, then it reverts to the previous power, which is the Ottoman Empire. And as Turkey is considered the successor regime, they belong to Turkey,” says a Turkey-based expert who wishes to remain anonymous. “That is the argument … and to a large degree [Turkish] people have come to believe it. It’s a question of discourse. If populist journalists and a couple of pseudo-academics say it, that’s all it takes.”This has become known as the “grey zones” policy, which aims to cast doubt on the status of anything between a couple of dozen to a couple of hundred uninhabited or sparsely inhabited Aegean islets. Turkish claims are spread throughout the Aegean, but her frustrations focus on the Dodecanese, the island group in the southeast Aegean, which were the last to formally join Greece. The Lausanne Treaty awarded them to Italy, naming the 12 principal islands “and the islets dependent thereon.” Nine years later, Italy signed a protocol with Turkey, which included British Admiralty maps and clearly delineated territorial waters, showing which islets lie in whose sovereign area. In the Paris Treaty of 1947, Greece inherited Italy’s possessions and treaty obligations. Turkey now objects that it had never formally ratified the protocol.“There were high expectations in Turkey that at least some of the Dodecanese would not be given to Greece,” says Dr. Thanos Dokos, who directs the Hellenic Foundation for European and Foreign Policy. “By not participating in the Second World War they were spared the destruction, but they lost the remaining Aegean islands. You can see statements … over the years expressing frustration that an uninterrupted line of islands across the coast are ‘strangling’ Turkey.”As long as they remained marginal, Turkish revisionist claims did not affect the bilateral relationship, but they have now entered the Turkish political mainstream thanks to the nationalist opposition party, the CHP. “Why did you not talk about 18 occupied islands?” CHP leader Kemal Kilicdaroglu berated Erdogan when he returned from his Athens trip. Kilicdaroglu has also taken it upon himself to speak in the government’s stead. Goaded by provocative remarks the Greek Defense minister made this month, Kilicdaroglu again pushed his revanchist narrative: “The Greek Defense minister says ‘Come and get it.’ I will come and take all of those islands back.Some observers see Turkey’s hardening stance toward Greece as an attempt to counter Erdogan’s slippage in the polls. “He is very insecure right now,” says the Turkey-based expert. “It seems that there is a big qualitative decline in Turkish public opinion [towards him]. People discern fatigue. They no longer believe he is the leader who will solve Turkey’s problems.”For Erdogan, who faces re-election next year, there is more at stake than power. In 2013, a judicial investigation was launched into his family’s assets after telephone conversations were leaked suggesting that he had amassed a personal fortune of more than a billion dollars while in office. He shut the investigation down in the name of national security, then imprisoned the prosecutors. But “Erdogan needs to survive politically so he can avoid legal prosecution. That’s what it comes down to,” says the Turkey expert. “You have an explosive mix of regional or even global ambition to the point of arrogance, on the one hand, and instability on the other,” says Dokos.A deteriorating security environmentUnder Erdogan, Turkey has come to see itself very differently from the secular state forged by Kemal Ataturk, which joined NATO, applied to join the EU, and generally played by Euro-Atlantic rules. Erdogan has ruled the country for almost 16 years, and during that time its GDP has grown fourfold and its foreign policy has become increasingly Islamic and assertive.Turkey has directly challenged the United States on Syria, entering the fray to attack the Kurds, whom it sees as an existential threat but who have been America’s frontline troops against the Islamic State. In March, Turkey won its first major victory in Syria, taking the town of Afrin 20 miles from its border. It now plans to move on the town of Manbij, 60 miles to the east, creating the buffer zone it has long sought between its own restive Kurdish citizens and the heavily armed Kurdish militias in Syria and Iraq. Turkey has become the only regional power straddling the world’s two major alliances, acting both on behalf of NATO and in concert with Russia—and it is doing so within the same conflict.Turkey is also putting its foot down in the eastern Mediterranean. On February 9, five Turkish navy ships prevented a drilling platform contracted by Italian energy company ENI from reaching its intended site offshore northeast Cyprus. ENI is one of six energy multinationals—including Qatar Petroleum, France’s Total and ExxonMobil—which have signed agreements to dig exploratory wells on Cyprus’s continental shelf. Those wells are scheduled to be completed by the end of this year; early tests have confirmed deposits of 3.6 to 6 trillion cubic feet of natural gas and indicated the prospect of much more.Cyprus has been divided since a 1974 Turkish invasion created a universally unrecognized Turkish-Cypriot state in the north. Greek Cypriots say they will share the island’s newfound resource wealth when they reach a reunification settlement. Turkey counters that this wealth shouldn’t be used as ransom to extort such a settlement that disadvantages Turkish Cypriots. Turkey therefore rejects the Cypriot exclusive economic zone assertion and says it will conduct its own exploratory drilling, setting the stage for another confrontation in the eastern Mediterranean. Many experts believe it is this agenda that drives the latest belligerence in the Aegean.A regional powerTurkey’s weapons programs suggest broad strategic aspirations. It has ordered an aircraft carrier from Spanish shipyards, due in 2022, and is developing its own ballistic missiles. Neither has any defensive use close to home. “They’re symbolic weapons, great-power weapons,” says Grivas of the Hellenic Army Academy. “Turkey is proving that it aims to be a midsize power in a multipolar system.”Turkey’s defense capabilities have risen with its economy, while Greece’s have suffered as a result of its eight-year depression. Last year Turkey spent $15.8 billion on defence; Greece could manage only $5.4 billion, and almost none of that was investment in new weapons. In fact, Greece has cut its defense expenditure by 40 percent in the last decade. This means it has spent no money on procurements other than ordnance.Meanwhile, Turkey is purchasing the F-35 stealth fighter and is pouring billions into developing its own mounted cannon and armored vehicle. Greece’s domestic defense industry has suffered so much disinvestment that four years ago it nearly lost the ability to make its own bullets and service its aircraft. Thanks to previous investments, Greece is for now a formidable adversary. Its forces almost match Turkey’s numerically, and it has covered the Aegean with overlapping anti-aircraft missile defense shields. Over time, though, military experts say, Greece’s ability to mount a credible defense will erode without new investments.Given these divergent trends, some analysts wonder whether a Turkish power-play in the Aegean is only a question of time. Rozakis believes Turkey is now more assertive in the Aegean than it was 20 years ago. “Back then, the Turkish side would say that [Imia] were disputed islands, that it was unclear to whom they belonged. Now they are saying that they are Turkish. This happened now, this year. That is an escalation.”In February, Turkish construction began on what media billed an “observation post” on the mainland opposite Imia. “It’s not just an observation post,” says defense expert Efthymios Tsiliopoulos. “They’re building a slipway and an access road; they could truck in semi-rigid inflatables and from there get to Imia in five minutes. And then what does the Greek side do? It would have to wage war to get them off.”Grivas calls Turkey’s actions “hybrid operations—military power below the threshold of full war accompanied by psychological pressure.” He believes the strategy could culminate “in a measured act of war in the hope that Greece will not react.”Dokos doesn’t believe there is a specific Turkish plan for annexation of a rocky islet, but he thinks it could happen as a result of the new instability in the Aegean. “What is different today is that you have more aggressive tactics by the Turkish side. You have a higher number of incidents. You have less experienced officers on the Turkish side. You have fewer channels of communication. … The influence of the usual firefighters—the U.S., primarily NATO—is extremely limited in Ankara today. So this is an explosive mix. Statistically, the risk of an accident is higher.”David Phillips, a former diplomat who runs Columbia University’s Program on Peace Building and Rights, believes an accident or miscalculation is more likely today for yet another reason: Washington is less likely to umpire. “The last thing the U.S. wants is to intervene between Turkey and Greece where military action is involved. So Erdogan may just think he can pull a fast one and get away with it. He might unleash forces he can’t control.”Military leadership concernsAgainst the advance of hyper-nationalism, the Turkish military may no longer be a reliable barrier. Following the July 2016 coup attempt, Erdogan imprisoned an estimated 50,000 public servants, most of them from the armed forces. By some accounts, that has deprived Turkey of a fighter wing’s worth of pilots experienced in taking calculated risks, and many of its most experienced commanders at sea. Dokos believes the ramming of the Greek coastguard vessel near Imia last month was the result of those purges.“My theory is that the instructions from high command in Ankara were, ‘make them feel our presence there. Show them that we cannot be pushed around and we are the big power,’” he says. “How that was interpreted by the Turkish captain was a different story. … If you look at the mood inside the Turkish armed forces and the mood among officers not to be seen as anything other than patriotic, because that can make the difference between being promoted and being thrown in jail, I think there was too much enthusiasm on the Turkish side.”The combination of an aggressive foreign policy and an inexperienced military is made worse by the fact that the two defense ministers have such a bad relationship that they do not speak. By some accounts, the direct line between the Greek and Turkish chiefs of staff has also fallen into disuse.Appeasement isn’t workingFormer Greek premier Kostas Simitis recently called on EU leaders to put pressure on Turkey. “Peace in this area is in the interest of the entire Union. An EU candidate country cannot dispute the borders of the Union and seek to revise them. Greece must prevail on Europe’s leaders to secure measures to protect our country.” The European Council produced Europe’s boldest statement in March, saying it “strongly condemns Turkey's continued illegal actions in the Eastern Mediterranean and the Aegean Sea and underlines its full solidarity with Cyprus and Greece.” And the United States, too, says it “recognizes the right of the Republic of Cyprus to develop its resources in its Exclusive Economic Zone.”Such statements reaffirm the Greeks’ traditional belief in their NATO and EU memberships as security shields. But few Greeks expect concrete action from either the EU or the United States or NATO, should push come to shove.NATO Secretary General Jens Stoltenberg recently told the Greeks that they’d have to extricate their wayward soldiers from Turkey on their own, disappointing Greek hopes that NATO would enforce collegial norms among Alliance members. NATO has also declined to take any formal position on the Lausanne and Paris treaties—effectively encouraging Turkey’s disputatiousness. NATO’s Stoltenberg has even refrained from criticizing Turkey for attacking the Kurds. “Turkey is contributing to our collective security, to our missions and operations in many different ways. I thank Turkey for that," Stoltenberg told Anadolu Agency in March”.Turkey’s longstanding aspirations to join the European Union have all but ceased to provide meaningful leverage. Greece lifted its objections to Turkish membership in 1999, reasoning that a democratic, European Turkey would present less of a threat. That decision yielded dividends for a decade. It has become apparent, at least to Erdogan, that major European powers have no intention of letting Turkey in, so Erdogan’s strategic calculations no longer include the need for deference to the EUThe refugee crisisThe EU’s handling of the refugee crisis has further weakened Greece by isolating it from the European core and making Turkey indispensable. In February 2016, Austria prevailed on the police forces of the former Yugoslavia to close the Balkan route that allowed refugees from the Middle East and Africa to reach central Europe on foot. A barbed wire fence went up on former Yugoslav Macedonia’s border, which trapped tens of thousands of refugees in Greece. The following month, the European Union signed its “Statement” with Turkey, whereby Turkey would retain refugees seeking to leave its shores, and take those back who failed to qualify for asylum in Europe. Greece was itself trapped between these two arrangements—left outside Vienna’s Balkan security blanket but still the recipient of refugees whom Turkey could not or would not apprehend.Refugee arrivals to Europe have fallen dramatically thanks to these two actions—from more than 1 million in 2015 to 172,000 last year . Greece, however, reaps the least benefit of anyone in the EU from this. Under European rules, refugees must apply for asylum in the first EU member state they reach. Prevailing smuggling routes put the most pressure on Greece, Italy, Malta and France. Last year, Greece received more new asylum applications in proportion to its population than any other EU member. It is currently processing 57,000 asylum applications—9 percent of the EU total—whereas the European Commission has apportioned to Greece 1.6 percent on the basis of population and prosperity. Yet many EU members remain reluctant to renegotiate Europe’s asylum rules, requiring frontline states like Greece to bear the brunt.Turkey’s new usefulness to Europe has arguably given it more leverage against Brussels than the other way around. Despite his political differences with Erdogan, the Dutch premier recently praised Turkey for its implementation of the agreement, highlighting its supreme importance to Europe. “I think Turkey has adhered extremely well to the refugee agreement,” Mark Rutte told parliament on the Statement’s second anniversary. “It’s how Greece is implementing the agreement that needs looking into, not Turkey,” he added, an apparent reference to Greece’s slowness in deporting ineligible asylum applicants.For its services, Turkey has been promised $3.7 billion a year, with Europe “in a hostage situation” according to Rozakis. The Statement turned Greece’s eastern Aegean islands into a buffer zone, where most refugees are confined until their cases are heard. This has alienated Europe’s frontier from its heartland and put the eastern Aegean very much at the mercy of Turkish goodwill in enforcing the agreement.Europe’s contracting of Turkey to defend external EU borders which Ankara disputes has made Greece’s Aegean possessions a much riper target for Turkish hawks. As the post-World War One order in the Middle East begins to unravel, the order Lausanne instituted in the Aegean may follow suit.With erratic Turkish behavior spreading to the Aegean, some Greeks are beginning to wonder whether they will be forced to fight simply to preserve their present borders. Rozakis believes Greece should be prepared for anything: “We are at the pinnacle of the problem now. I fear that from now on, nothing is a given. We have Erdogan, an unpredictable man. We’ve no idea what he’ll do tomorrow.”John Psaropoulos is an independent journalist who has covered Greece and the Balkans since the fall of communism. He writes and broadcasts for, among others, the Daily Beast , the Washington Post , the American Scholar , and Al Jazeera English.

Binance is a cryptocurrency exchange that launched in July 2017.After its launch, Binance rapidly expanded to serving over six million users across the world. Binance’s 267 crypto/crypto trading pairs and over 6 million users make it an extremely large exchange, suited for traders looking for high liquidity and rapid trades, though only if they do not require fiat trading pairs. The addition of an API also makes it suited to traders looking for programmatic trading opportunities.BinanceURL: binance.comTotal Trading Pairs: 267Deposit Fees: NoWithdrawal Fees: YesTrading Fees: Yes, 0.1%Margin Trading: NoVerification: Yes, for higher withdrawal limitsRegistrationRegistering with Binance is rather simple, it requires an email address and a password. Note that you cannot use a ‘+’ in your email address. Once you have submitted the registration form you will receive a confirmation email that includes your IP address.Binance Signup & LoginTo use the exchange, users will first have to create an account. The process behind this is fairly simple and straight-forward and you don’t have to verify your account for level 1 which is a 2BTC daily withdrawal limit. For level 2 which allows up to 100BTC per day, you need to upload a photo ID and wait till you are approved. There are higher limits still, but you will need to contact them directly to arrange that.Supported Crypto CurrenciesBinance has often been praised for its wide variety of support coins. Traders can use the platform for multiple digital currencies, including, but not limited to Bitcoin, Bitcoin Cash, Bitcoin Gold, Ethereum, Ethereum Classic, EOS, Dash, LiteCoin, NEO, GAS, Zcash, Dash, Ripple and more. As mentioned before, Binance also supports numerous tokens, as part of ICO listings. With this in mind, traders can use the platform to trade these tokens for a profit as well.Binance is currently very quick to add new coins and tokens after their ICO which usually means you can purchase them cheaply which allows for greater profit down the road.They currently offer trading pairs in BTC, BNB, ETH and USDT.Binance offers a substantial number of coins, which are traded mostly against Bitcoin and Ethereum. On the other side the two major coins are also paird with USDT (US Dollar Tether a digital asset, backed by US dollars, which aims to keep a 1:1 price ratio). The list of coins available at Bitnancie includes, but is not limited to (especially since new ones are added frequently): BTC, ETH, LTC, BCC, OMG, IOTA, ICN, MCO, SALT, KNC, CTRm SNLS, FUN, BQX, XVG, ZRX and BQX.Minimum initial depositBinance does not provide information on the minimum deposit amount. As we cover mostly forex brokers, we are used to companies stating this information openly. The need for a minimum deposit level is associated with the legal costs of opening an account, which may exceed the potential commissions you will make with a broker, if you are trading too small. That being said several companies don’t have a required minimum, like the FCA-regulated industry leaders at IG.Transfer LimitsBinance is strictly a cryptocurrency exchange, so you’re not able to fund your account with fiat currency.You can only deposit cryptocurrency funds, but there’s no limit on the amount that you can deposit. There are also no fees on any of your deposits.The amount that you can withdraw each day is determined by your verification tier. Without submitting any verification details, you’re placed at Level 1 and can withdraw up to 2 BTC worth of cryptocurrency a day.To be classified as Level 2, you need to enable either two-factor authentication or Google Authenticator. Right now, only Chinese numbers are supported for two-factor authentication.Following that, you need to provide:First nameLast nameGenderCountryPassport IDPassport photoSelfie with passportWith Level 2 verification, your daily withdrawal limit increases to 100 BTC.LeverageMargin trading is not available at Binance. For those of you who are not familiar with the trading world – this is a system which allows you to trade with more money than you actually have in your account. Your balance is then used as a guarantee to maintain your position open. As an example, forex brokers require very little in collateral, in order to maintain massive positions. The so called leverage ratios can go as high as 1:500 or more. For instance, XM offers 1:888 in leverage.That being said the cryptocurrency space is a lot more volatile, hence the need for lower ratios. Exchanges and forex brokers alike, rarely offer more than 1:20 in leverage.FeesFor trading, Binance charges a flat 0.1% fee on all trades. Withdrawal fees differ per currency and are changed often. There are no fees for deposits.Simple and Advanced ExchangesBinance has two different interfaces for its exchange. One is a simple interface for novice traders, and the other is a more advanced interface that has more information available for those that understand it.InterfaceBinance’s interface is different depending on whether you use the simple or advanced trading platforms. For the simple one, the interface is a bright white with yellow highlights and black text. And the advanced trading platform has a dark grey background with light grey text. Both feature a chart, order submission form, trade history, and order book. Though the advanced interface has a more complex graph and a different layout. Specifically, a chart on the left with various histories below it, and an order book, trade histories and order submission form on the right.VerificationThere are three verification levels on Binance.Verification level 1 is set by default on new accounts and has a 2 BTC or equivalent withdrawal limit.You cannot start the process of gaining level 2 without having configured 2FA on your account. Otherwise, level 2 requires some personal information and a few pictures. Specifically, you must submit your full name, gender, country, the number on your government ID, a scan of the cover of your government ID, a scan of the identifying page of your government ID, and a selfie of you holding your ID and a note with the date and the phrase ‘Binance’ on it. Level 2 has increased withdrawal limits, specifically, 50 BTC or equivalent.Level three requires contacting Binance directly, and its benefits are not posted.Company TrustI’ve been increasingly interested in Binance recently after seeing it suggested time and time again on forums as a better alternative to Bittrex. Community members seem to love this exchange.Binance is one of the newest exchanges in the industry. The company raised around $15 million in an ICO this past July (2017) and immediately acquired 20,000 registered users as part of the raise.Changpeng Zhao, CEO of Binance, has an impressive resume with years of experience in cryptocurrency. He was the Head of Development at Blockchain, Co-founder and CTO of OKCoin, and the Founder and CEO of BijieTech before working on Binance.SecurityBinance’s security practices are very good. Otherwise, there is a popup explaining basic security practices that you are required to read when you log into your account for the first time. After which there are constant reminders to set up Two Factor Authentication, which is available via Google Authenticator.While Binance is one of the newest cryptocurrency exchanges available on the market, it has quickly managed to attain a high level of trust from its users and the digital currency community. However, the exchange fails to provide users with enough information on how the funds are being secured, yet we like to believe that security is taken seriously. Two-factor authentication is available and is always a nice sight. It is however known that the platform offers a multi-tier and multi-tier system architecture.The hackers tried to pull off an audacious move which was luckily caught by the automated systems in place at the exchange. For months the hackers had been accumulating people’s logins via a phishing website and secretly installing API access on the affected accounts. They then struck, converting all the victims altcoins to BTC and purchasing Viacoin, pumping the coin to a huge price and then selling their own supply of Viacoin at the high point, before trying to withdraw the BTC to their own wallets. Luckily no one lost funds as the hack was caught and the only people to lose out were the hackers, whose funds will be donated to charity.As this hack was made possible by people entering their site logins and 2FA details into a fake website, you should always make sure you are on the correct Binance url before logging in. We recommend you bookmark the site and only use that to access it, never click links from emails, Twitter, Telegram etc.This event has done a lot to instill confidence around Binance, not only did their automated processes catch the attempted hack before anyone lost any funds, they have since offered a $250,000 bounty to anyone who can help catch the hackers. Throughout this event, Binance acted exemplary and have been praised for their swift action in resolving this.Binance Customer SupportFor an exchange to be successful, it requires a great customer support team, capable of answering all user questions and requests in a timely manner. While the support area on Binance could use a little work, the team is responsive and capable of offering professional aid to traders in need. Support tickets are submitted via an online form featured on the website, and responses are made via email. There is currently no live chat support, nor a phone number where customers can get in touch with the support team.Other than the CS team, Binance offers a couple of FAQs and articles meant to help users get accustomed to the exchange and the way it works.BittrexAs we mentioned in the beginning of our Bitstamp review, after testing their services, we transferred some coins to Bittrex in order to experience more exotic coins. While Bitstamp only offers four of the major cryptocurrencies – Bitcoin, Ethereum and Litecoin, Bittrex supports over 190 digital assets.What was highly unusual at Bittrex was the vast number of wallets available. There were pages and pages, but then again all trading assets must be supported. We were very careful to transfer our recently acquired Litecoin to the appropriate address. We chose Litecoin, as the network fees (not charged by the exchange, but by the actual blockchain) for a Bitcoin transfer felt a bit too high.Once we received the coins we started trading, after going through Bitcoin several times, as most altcoins are traded against it. After a couple of days we realized we had some Bitcoin “change” left over. This was obviously due to partial executions. Here is a preview of the multiple wallets we have and the “change” left in the third one (click to zoom-in):While the 29 pages may seem scary at first, there are several filters, including the option to “hide zero balances”.Trading AccountsAccount type Minimum deposit Leverage FeeStandard Undisclosed None 0.25%Bittrex is one of the most popular cryptocurrency exchanges. Its main advantage against major competitors, like Kraken or Bitfinex is the diversity of coins available for trading. Basically every coin you can think about is traded on Bittrex.The company, security of fundsCompany Country RegulationBittrex, INC US Applying for NY BitlicenseBittrex, INC is based in the US, more specifically in New York. It is one of the few companies which has applied for the controversial “BitLicense”. If you are not familiar with the story, the New York Department of Financial Services (NYDFS) had plans to regulate bitcoin exchanges in 2015, which one may argue backfired. A lot of companies opted not to go through the stringent regulatory process, and simply moved out of New York. While at least nine applied for a license, only three were approved for two years. The fact, reputable companies decided to back-out, combined with the slow process, makes the entire law appear to be ineffective. While the regulation may not make New York a crypto-trading hub, Bittrex is still in the application process.When it comes to the security of your funds at Bittrex, the company offers and recommends using two-factor authentication, which is a standard measure in the industry. The exchange hasn’t yet suffered a major hack, unlike others. However there are a few alleged reports by individuals, who claim their accounts were hacked. It is hard to verify their claims or if they aren’t to blame for mistakes like having a weak password or not enabling two-factor autentication.The user reviews for Bittrex are fairly positive. Traders like the feel of the actual trading platform (which we’ll cover shortly) and the diversity of altcoins. That being said, given the number of assets available for trading, one must be careful when transferring coins to Bittrex. Some of the user issues with the exchange involve the company’s policy on recovering coins transferred to the wrong wallet, which we will get to in the Methods of Payment section. The other frequent complaint people have invoves slow responses from the customer support, but the amount of negative post is nowhere near the ones for Poloniex.Update: While the majority of reviews on Bittrex were positive, the company apparently locked-out a lot of accounts in the days around the Bitcoin Cash hard fork. This prevented customers from selling their Bitcoin as the market rallied. While we had no issue, with our testing account a lot of other traders had. Check the comments section below this review for complaints. We have lowered the otherwise solid score of this exchange as a result.Trading conditionsTrading instruments (cryptocurrencies)As we mentioned in the beginning, the major advantage of Bittrex comes from the plethora of alternative coins it provides. Currently there are over 190 digital assets available for trading. There are two types of markets at Bittrex – USD and Bitcoin. As their names suggest, at one of them you are trading coins against the US dollar, while in the latter you are trading them against Bitcoin. The more exotic assets are only available in the second market type.Minimum initial depositBittrex does not provide any information on the minimum deposit level. While this is a common practice with cryptocurrency exchanges, we are used to forex brokers providing this information freely. Some even point out the low levels they have as a competiive advantage. For instance, you can open a cent-account at FXTM with only $5.LeverageThere is no margin trading at Bittrex, at the time of writing of this review. That being said, the company has announced it is working on its implementation. Forex brokers, who provide bitcoin trading (like IG) always provide margin trading. Additionally, almost all of their offers involve CFD trading, which is slightly different than exchange-based trading. For a full description of the differences between the two, read this review.FeesThe trading fee at Bittrex is 0.25%. This is in-line with the current offers provided by other exchanges, although such a flat value is not often applied. For instance, some exchanges offer a different fee for market “makers” and takers”, encouraging people to provide liquidity to their order book. A market maker (in this context, not to be confused with forex market makers) is a trade who places a bid or ask on the exchange. A “taker” is somebody who buys directly from the best available ask (or sells at the best bid). Furthermore, discounts for large traders are also provided at some exchanges, based on the monthly trading volume.Trading platformAs most other crypto-exchanges, Bitttrex offers a web-based platform. It feels fairly easy to use, while offering multiple capabilities. The charting package is average – worse than the one provided by let’s say MetaTrader4 (MT4), but a lot better than the ones which other exchanges offer. There are several technical indicators available, but again not as much, as these available at the leading forex trading platforms.The order book also feels very intuitive and as if it was developed by somebody who is familiar with trading. The “star” column on the inner-side of both the bid and ask tables fills up wit a … star, once you have placed an order. This makes it easy to visually recognize the price levels at which you are willing to buy or sell.Overall the Bittrex trading platforms is one of the better ones we have seen, with no major downside to it.Methods of paymentPayments to and from Bittrex can only be made via cryptocurrencies. Given the plethora of available wallets, one must be careful not to deposit to the wrong one. We found a comment from an individual, who mistakenly transferred his Bitcoin Cash into his regular Bitcoin wallet. The support team managed to help him, but you must be aware of the official company policy on this matter. It is to review such transactions only if they involve coins worth over $5,000 and charge a 5% fee for fixing the issue.While relatively inexperienced users will like to deposit via Credit/Debit Card or on-line solutions such as Skrill or PayPal, they will have to go through another party before trading at Bittrex.ConclusionBittrex is one of the largest cryptocurrency exchanges. Its main advantage over the competition is the availability of multiple alternative coins – over 190 and counting. That being said, the company does not accept fiat money deposits – instead they only operate in the cryptoverse. This is a limitation for inexperienced people, but if they want to venture into the assets available at Bittrex, they would have to do some research anyway. The trading platform feels solid. Overall Bittrex is a top-contender for people who are looking to trade more exotic alternative coins.BitfinexBitfinex is a cryptocurrency exchange, which also provides margin trading. The leverage ratio may seem low to experienced forex traders, but this is due to wild and unpredictable nature of cryptocurrencies. At the time of writing of this review Bitfinex is the largest Bitcoin exchange, in terms of volume.The company, security of fundsCompany Country RegulationiFinex Inc Hong Kong N/ABitfinex is operated by iFinex Inc., a Hong Kong based company. Although regulation in the cryptoverse is often times a bit shaky, this company has some history in dealing with the US Commodity Futures Trading Commission (CFTC). Despie claiming they should not fall under any dervatives regulation, Bitfinex did pay a fine to the CFTC rgarding a particular case. Of course, we are talking about the famous hacking scandal.In August of 2016, Bitcoin worth approximately $72 million was stolen from Bitfinex users, resulting in the second-largest hack in the history of cryptocurrency exchanges. The company reacted accordingly, trying to trace the villains. Simultaneously it issued the so called BFX tokens, to the victims. This represented a pledge by the exchange, to pay back the money, once it has the ability to do so.An interesting development then followed, as a secondary market for these tokens emerged. Applying a strategy, used by the aptly named “Vulture hedge funds”, the initial bidders were offering 2 cents on the dollar. Obviously the uncertainty regarding the payments was very high, as people were speculating this was the end of Bitfinex. Prices started increasing, with new developments in the story. Eventually the firm paid back the entire debt, at the full promised value (and withdrew all the tokens in the process).This story raises the credibility of Bitfinex in our eyes. The exchange had a major issue but managed to handle it well.Important Update: As of November 9 2017, Bitfinex will no longer accept US clients in any form. This is most likely the result of a SEC guideline, which suggests all crypto-exhanges will have to at least be registered in a newly created list.Trading conditionsTrading instruments (cryptocurrencies)Most of the major coins are being traded at Bitfinex. At the time of writing of this review the list includes: Bitcoin, Ethereum, Litecoin, EOS, OmiseGO, Iota, Ethereum Classic, Zcash, Ripple, Dash, Santiment, and Monero.Minimum initial depositThe minimum initial deposit, required by Bitfinex is not specified. Forex traders are used to brokers disclosing this information in advance. Some even use it as a means of attracting new traders, like FXTM, who only require $5 for the creation of a new cent account.Although small transfers can be made with cryptocurrencies, we suspect there may be a minimum, under which Bitfinex will not accept your transaction.LeverageBitfinex allows margin trading and short-selling of cryptocurrencies. The maximum leverage is 1 top 3,3. Some of the forex brokers, which provide Bitcoin trading, offer even higher leverage. For instance HYCM has set the cap at 1:10. Of course, you can only trade with cryptocurrencies at most forex brokers, without the ability to actually own and transfer them.Do keep in mind, market moves in the cryptoverse tend to be very wild. A coin can gain or lose a significant portion of its value, within a day. On the other hand traditional fiat currencies rarely register a daily change of more than 1.5 - 2%. Trading a cryptocurrency with high leverage ratios is one of the riskiest things you could do.FeesWhen it comes to fees, charged by Bitfinex they are relatively fair when compared to the competition. In order to give you a better understanding, we have to clarify exactly how they are calculated. Unlike what you may be used to with most forex brokers, fees on crypto-exchanges are charged, based on what type of order you place.If you buy from the lowest available ask, you are effectively taking away liquidity from the market, which results in you paying the higher “taker fee”. Alternatively, if you place your own bid/ask in the order book, other traders can “aggressively” make a trade with it. This is called providing liquidity, in which case you pay the lower “maker fee”.The charges at Bitfinex are percentages of the total volume of the transaction. They are 0.20% for the “takers” and 0.10% for the “makers”. Comparing this with the offers provided by forex brokers is quite tricky. You would probably get a slightly lower spread at most brokerages, but you will be trading a Contract For Differance (CFD). This means you will only be speculation on the price of the asset, without actually owning it. We must reiterate, speculative trading of cryptocurrenies can be very risky.When it comes to short-selling, there are additional borrowing fees, which vary based on Bitfinex’s internal platform’s peer-to-peer financing functionality. A key rule to note, is that when selling short, you can’t borrow more than 70% of your entire position.Trading platformBitfinex provides its services via a web-based platform and a mobile app. Although it doesn’t come near the most popular currency trading platform, MetaTrader4 (MT4), the Bitfinex offering is decent. Charting is provided by TradingView, which means you are getting a solid package, with lots of technical analysis tools, such as indicators, Fibonacci tools, trend-lines and so on.The order book at Bitfinex is also fully transparent. Although volumes occasionally go down, there is a lot of swift order movement and many transactions in the major currencies. Whether classical tape-reading works, as a predictive technique nowadays is a rather interesting topic in itself, but you can attempt to do it at Bitfinex.Methods of paymentFunding your account at Bitfinex can be done via multiple cryptocurrencies. Furthermore Bank Transfers are accepted, although they are temporary disabled. It is not clear when and if they will “old fashioned” payments will be accepted. Options such as Credit Card, PayPall or Skrill are also not available, which limits the ability to attract people who are new to the crypto-world.ConclusionBitfinex is one of the major cryptocurrency exchanges. The 2016 hack was a major blow to the company. That being said, they managed to handle the situation as best they could. This is definitely a good exchange for forex traders, willing to venture into the cryptoverse, as the platform feels intuitive. On the other hand one would need to already have a crypto currency wallet in order to make a deposit in the first place. This is a major drawback for the “uninitiated”.

Banking Regulation Governing ExportsExport of Goods and Services from India is governed by clause (a) of sub-section (1) and sub-section (3) of Section 7 of the Foreign Exchange Management Act 1999 (42 of 1999), read with Notification No. G.S.R. 381(E) dated May 3, 2000 viz. Foreign Exchange Management (Current Account Transactions) Rules, 2000, further read with 1FEMA Notification No.23(R)/2015-RB dated January 12, 2016. These Regulations are amended from time to time to incorporate the changes in the regulatory framework and published through amendment notifications.Within the contours of the Regulations, Reserve Bank of India also issues directions to Authorised Persons under Section 11 of the Foreign Exchange Management Act (FEMA), 1999. These directions lay down the modalities as to how the foreign exchange business has to be conducted by the Authorised Persons with their customers/ constituents with a view to implementing the regulations framed.Instructions issued on export of goods and services from India have been compiled in this Master Direction. The list of underlying circulars/ notifications which form the basis of this Master Direction is furnished in the Appendix. Reporting instructions can be found in Master Directions on reporting (Master Direction No. 18 dated January 01, 2016)It may be noted that, whenever necessary, Reserve Bank shall issue directions to Authorised Persons through A.P. (DIR Series) Circulars in regard to any change in the Regulations or the manner in which relative transactions are to be conducted by the Authorised Persons with their customers/ constituents. The Master Direction issued herewith shall be amended suitably simultaneously.1. Realization and repatriation of proceeds of export of goods / software / servicesIt is obligatory on the part of the exporter to realize and repatriate the full value of goods / software / services to India within a stipulated period from the date of export, as under:It has been decided in consultation with the Government of India that the period of realization and repatriation of export proceeds shall be nine months from the date of export for all exporters including Units in Special Economic Zones (SEZs), Status Holder Exporters, Export Oriented Units (EOUs), Units in Electronic Hardware Technology Parks (EHTPs), Software Technology Parks (STPs) & Bio-Technology Parks (BTPs) until further notice.For goods exported to a warehouse established outside India, the proceeds shall be realized within fifteen months from the date of shipment of goods.2. Manner of receipt and payment(i) The amount representing the full export value of the goods exported shall be received through an AD Bank in the manner specified in the Foreign Exchange Management (Manner of Receipt & Payment) Regulations, 2016 notified vide Notification No. FEMA.14 (R)/2016-RB dated May 02, 2016.(ii) When payment for goods sold to overseas buyers during their visits is received in this manner, EDF (duplicate) should be released by the AD Category – I banks only on receipt of funds in their Nostro account or if the AD Category – I bank concerned is not the Credit Card servicing bank, on production of a certificate by the exporter from the Credit Card servicing bank in India to the effect that it has received the equivalent amount in foreign exchange, AD Category – I banks may also receive payment for exports made out of India by debit to the credit card of an importer where the reimbursement from the card issuing bank/ organization will be received in foreign exchange.(iii) Processing of export related receipts through Online Payment Gateway Service Providers (OPGSPs)Authorised Dealer Category – I (AD Category – I) banks have been allowed to offer the facility of repatriation of export related remittances by entering into standing arrangements with Online Payment Gateway Service Providers (OPGSPs) subject to the following conditions –The AD Category-I banks offering this facility shall carry out the due diligence of the OPGSP.This facility shall only be available for export of goods and services of value not exceeding USD 10,000 (US Dollar ten thousand).AD Category-I banks providing such facilities shall open a NOSTRO collection account for receipt of the export related payments facilitated through such arrangements. Where the exporters availing of this facility are required to open notional accounts with the OPGSP, it shall be ensured that no funds are allowed to be retained in such accounts and all receipts should be automatically swept and pooled into the NOSTRO collection account opened by the AD Category-I bank.A separate NOSTRO collection account may be maintained for each OPGSP or the bank should be able to delineate the transactions in the NOSTRO account of each OPGSP.Under this arrangement, the permissible debits to the NOSTRO collection account are for repatriation of funds representing export proceeds to India for credit to the exporters’ account, payment of fee/commission to the OPGSP as per the predetermined rates / frequency/ arrangement; and charge back to the importer where the exporter has failed in discharging his obligations under the sale contract.The balances held in the NOSTRO collection account shall be repatriated and credited to the respective exporter's account with a bank in India immediately on receipt of the confirmation from the importer and, in no case, later than seven days from the date of credit to the NOSTRO collection account.AD Category -I banks shall satisfy themselves as to the bona-fides of the transactions and ensure that the purpose codes reported to the Reserve Bank in the online payment gateways are appropriate.AD Category -I banks shall submit all the relevant information relating to any transaction under this arrangement to the Reserve Bank, as and when advised to do so.Each NOSTRO collection account should be subject to reconciliation and audit on a quarterly basis.Resolution of all payment related complaints of exporters in India shall remain the responsibility of the OPGSP concerned.AD Category-I banks desirous of entering into such an arrangement/s should report the details of each such arrangement as and when entered into to the Foreign Exchange Department, Central Office, Reserve Bank of India, Mumbai.4A start-up can realise the receivables of its overseas subsidiary and repatriate them through Online Payment Gateway Service Providers (OPGSPs).(iv) Settlement System under ACU Mechanisma) In order to facilitate transactions / settlements, effective January 01, 2009, participants in the Asian Clearing Union will have the option to settle their transactions either in ACU Dollar or in ACU Euro. Accordingly, the Asian Monetary Unit (AMU) shall be denominated as ‘ACU Dollar’ and ‘ACU Euro’ which shall be equivalent in value to one US Dollar and one Euro, respectively.b) Further, AD Category – I banks are allowed to open and maintain ACU Dollar and ACU Euro accounts with their correspondent banks in other participating countries. All eligible payments are required to be settled by the concerned banks through these accounts.c) Relaxation from ACU Mechanism- Indo-Myanmar Trade - Trade transactions with Myanmar can be settled in any freely convertible currency in addition to the ACU mechanism.d) In view of the difficulties being experienced by importers/exporters in payments to / receipts from Iran, it has been decided that with effect from December 27, 2010, all eligible current account transactions including trade transactions with Iran should be settled in any permitted currency outside the ACU mechanism, until further notice.e) In view of the understanding reached among the members of the ACU during the 44th Meeting of the ACU Board in June, 2015, it has been decided to permit the use of the Nostro accounts of the commercial banks of the ACU member countries, i.e., the ACU Dollar and ACU Euro accounts, for settling the payments of both exports and imports of goods and services among the ACU countries.(v) Third party payments for export / import transactionsTaking into account the evolving international trade practices, it has been decided to permit third party payments for export / import transactions can be made subject to conditions as under:a) Firm irrevocable order backed by a tripartite agreement should be in place. However, it may not be insisted upon in cases where documentary evidence for circumstances leading to third party payments / name of the third party being mentioned in the irrevocable order/ invoice has been produced subject to:AD bank should be satisfied with the bona-fides of the transaction and export documents, such as, invoice / FIRC.AD bank should consider the FATF statements while handling such transaction.b) Third party payment should be routed through the banking channel only;c) The exporter should declare the third party remittance in the Export Declaration Form and it would be responsibility of the Exporter to realize and repatriate the export proceeds from such third party named in the EDF;d) It would be responsibility of the Exporter to realize and repatriate the export proceeds from such third party named in the EDF;e) Reporting of outstanding, if any, in the XOS would continue to be shown against the name of the exporter. However, instead of the name of the overseas buyer from where the proceeds have to be realized, the name of the declared third party should appear in the XOS;f) In case of shipments being made to a country in Group II of Restricted Cover Countries, (e.g. Sudan, Somalia, etc.), payments for the same may be received from an Open Cover Country; andg) In case of imports, the Invoice should contain a narration that the related payment has to be made to the (named) third party, the Bill of Entry should mention the name of the shipper as also the narration that the related payment has to be made to the (named) third party and the importer should comply with the related extant instructions relating to imports including those on advance payment being made for import of goods.(vi) Settlement of Export transactions in currencies not having a direct exchange rateTo further liberalize the procedure and facilitate settlement of export transactions where the invoicing is in a freely convertible currency and the settlement takes place in the currency of the beneficiary, which though convertible, does not have a direct exchange rate, it has been decided that AD Category-I banks may permit settlement of such export transactions (excluding those put through the ACU mechanism), subject to conditions as under:Exporter shall be a customer of the AD BankSigned contract / invoice is in a freely convertible currency,The beneficiary is willing to receive the payment in the currency of beneficiary instead of the original (freely convertible) currency of the invoice/ contract, Letter of Credit as full and final settlement,AD bank is satisfied with the bonafides of the transactions, andThe counterparty to the exporter/ importer of the AD bank is not from a country or jurisdiction in the updated FATF Public Statement on High Risk & Non Co-operative Jurisdictions on which FATF has called for counter measures.3) Exchange Earners’ Foreign Currency Account (EEFC Account)(i) A person resident in India may open with, an AD Category – I bank in India, an account in foreign currency called the Exchange Earners’ Foreign Currency (EEFC) Account, in terms of10Regulation 4 (D) of Foreign Exchange Management (Foreign Currency Accounts by a person Resident in India) Regulations, 2015 dated January 21, 2016.(ii) Resident individuals are permitted to include resident close relative(s) as defined in the Companies Act 2013 as a joint holder(s) in their EEFC bank accounts on former or survivor basis.(iii) This account shall be maintained only in the form of non-interest bearing current account. No credit facilities, either fund-based or non-fund based, shall be permitted against the security of balances held in EEFC accounts by the AD Category – I banks.(iv) All categories of foreign exchange earners are allowed to credit 100% of their foreign exchange earnings to their EEFC Accounts subject to the condition thatThe sum total of the accruals in the account during a calendar month should be converted into Rupees on or before the last day of the succeeding calendar month after adjusting for utilization of the balances for approved purposes or forward commitments.The facility of EEFC scheme is intended to enable exchange earners to save on conversion/transaction costs while undertaking forex transactions. This facility is not intended to enable exchange earners to maintain assets in foreign currency, as India is still not fully convertible on Capital Account.(v) The eligible credits represent –Inward remittance received through normal banking channel, other than the remittance received pursuant to any undertaking given to the Reserve Bank or which represents foreign currency loan raised or investment received from outside India or those received for meeting specific obligations by the account holder.Payments received in foreign exchange by a 100 per cent Export Oriented Unit or a unit in Export Processing Zone, Software Technology Park or Electronic Hardware Technology Park for supply of goods to similar such unit or to a unit in Domestic Tariff Area and also payments received in foreign exchange by a unit in Domestic Tariff Area for supply of goods to a unit in Special Economic Zone (SEZ);(vi) AD Category – I banks may permit their exporter constituents to extend trade related loans/ advances to overseas importers out of their EEFC balances without any ceiling subject to compliance of provisions of Notification No. FEMA 3/2000-RB dated May 3, 2000 as amended from time to time.(vii) AD Category – I banks may permit exporters to repay packing credit advances whether availed in Rupee or in foreign currency from balances in their EEFC account and / or Rupee resources to the extent exports have actually taken place.(viii) Where a part of the export proceeds are credited to an EEFC account, the export declaration (duplicate) form may be certified as: “Proceeds amounting to …… representing ….. percent of the export realization credited to the EEFC account maintained by the exporter with……”4. Exports to neighboring countries by road, rail or riverThe following procedure should be adopted by exporters for filing original copies of EDF where exports are made to neighboring countries by road, rail or river transport:In case of exports by barges/country craft/road transport, the form should be presented by exporter or his agent at the Customs station at the border through which the vessel or vehicle has to pass before crossing over to the foreign territory. For this purpose, exporter may arrange either to give the form to the person in charge of the vessel or vehicle or forward it to his agent at the border for submission to Customs.As regards exports by rail, Customs staff has been posted at certain designated railway stations for attending to Customs formalities. They will collect the EDF for goods loaded at these stations so that the goods may move straight on to the foreign country without further formalities at the border. The list of designated railway stations can be obtained from the Railways. For goods loaded at stations other than the designated stations, exporters must arrange to present EDF to the Customs Officer at the Border Land Customs Station where Customs formalities are completed.5. Border trade with MyanmarIn supersession of instructions contained in A.P. (DIR Series) Circular No. 17 dated October 16, 2000, barter system of trade at the Indo-Myanmar border has been discontinued and replaced with normal trade with effect from December 1, 2015. Accordingly, all trade transactions with Myanmar, including those at the Indo-Myanmar border with effect from December 1, 2015 shall be settled in any permitted currency in addition to the Asian Clearing Union mechanism.6. Project Exports and Service Exports(i) Export of engineering goods on deferred payment terms and execution of turnkey projects and civil construction contracts abroad are collectively referred to as ‘Project Exports’. Indian exporters are required to obtain the approval of the AD Category – I banks/ Exim Bank at post-award stage before undertaking execution of such contracts. Regulations relating to ‘Project Exports’ and ‘Service Exports’ are laid down in the revised Memorandum of Instructions on Project and Service Exports (PEM-July 2014).(ii) Accordingly, AD banks / Exim Bank may consider awarding post-award approvals without any monetary limit and permit subsequent changes in the terms of post award approval within the relevant FEMA guidelines / regulations. Project and service exporters may approach AD banks / Exim Bank based on their commercial judgment. The respective AD bank / Exim Bank should monitor the projects for which post-award approval has been granted by them.(iii) In order to provide greater flexibility to project & service exporters in conducting their overseas transactions, facilities have been provided as under:Inter-Project transfer of machinery - The stipulation regarding recovery of market value (not less than book value) of the machinery, etc., from the transferee project has been withdrawn. Further, exporters may use the machinery / equipment for performing any other contract secured by them in any country subject to the satisfaction of the sponsoring AD Category – I bank(s) / Exim Bank and also subject to the reporting requirement and would be monitored by the AD Category – I bank(s) / Exim Bank.Inter-Project transfer of funds - AD Category – I bank(s) / Exim Bank may permit exporters to open, maintain and operate one or more foreign currency account/s in a currency/currencies of their choice with inter-project transferability of funds in any currency or country. The Inter-project transfer of funds will be monitored by the AD Category – I bank(s) / Exim Bank.Deployment of temporary cash surpluses - Subject to monitoring by the AD Category – I bank(s) / Exim Bank, Project / Service exporters may deploy their temporary cash surpluses, generated outside India investments in short-term paper abroad including treasury bills and other monetary instruments with a maturity or remaining maturity of one year or less and the rating of which should be at least A-1/AAA by Standard & Poor or P-1/-AAA by Moody’s or F1/AAA by Fitch IBCA etc., and as deposits with branches / subsidiaries outside India of AD Category – I banks in India.Repatriation of funds in case of On-site Software Contracts - The requirement of repatriation of 30 per cent of contract value in respect of on-site contracts by software exporter company / firm has been dispensed with. They should, however, repatriate the profits of on-site contracts after completion of the contracts.7. Export of goods through Customs ports(i) Customs shall certify the value declared and give running serial number on the two copies of Export Declaration Form (EDF), submitted by exporter at Non- Electronic Data Interchange (EDI) port.(ii) Customs shall retain the original EDF for transmission to the Reserve Bank and return the duplicate copy to the exporter.(iii) At the time of shipment of goods, exporters shall submit the duplicate copy of the EDF to Customs. After examining the goods, Customs shall certify the quantity in the form and return it to the exporter for submission to AD for negotiation or collection of export bills.(iv) Within 21 days from the date of export, exporter shall lodge the duplicate copy together with relative shipping documents and an extra copy of the invoice to the AD named in the EDF.(v) After the documents have been negotiated / sent for collection, the AD shall report the transaction through Export Data Processing and Monitoring System (EDPMS) to the Reserve Bank and retain the documents at their end.(vi) In case of exports made under deferred credit arrangement or to joint ventures abroad against equity participation or under rupee credit agreement, the number and date of the Reserve Bank approval and/or number and date of the relative RBI circular shall be recorded at the appropriate place on the EDF.(vii) Where duplicate copy of EDF is misplaced or lost, AD may accept copy of duplicate EDF duly certified by Customs.8. Export of goods/ software done through EDI ports(i) The shipping bill shall be submitted in duplicate to the authority concerned (Commissioner of Customs or the SEZ, if the export is made through it).(ii) After verifying and authenticating, the authority concerned shall hand over to the exporter, one copy of the shipping bill marked ‘Exchange Control (EC) Copy’ for being submitted to the AD bank within 21 days from the date of export for collection/negotiation of shipping documents. However, in cases where EC copy of shipping bill is not printed in terms of CBEC’s Circular No. 55/2016-Customs dated November 23, 2016 and data of shipping bill is integrated with EDPMS, requirement of submission of EC copy of shipping bill with the AD bank would not be there.(iii) The manner of disposal of EC copy of Shipping Bill shall be the same as that for EDF. The duplicate copy of the form together with a copy of invoice etc. shall be retained by ADs and may not be submitted to the Reserve Bank. The question of disposal of EC copy of shipping bill will, however, not arise where EC copy of shipping bill is not printed in terms of CBEC’s Circular No.55/2016-Customs dated November 23, 2016 and data of shipping bill is integrated with EDPMS.Note: - In cases where ECGC/private insurance companies regulated by Insurance Regulatory and Development Authority (IRDA) initially settles the claims of exporters and the export proceeds are subsequently received from the buyer/buyer’s country, the share of exporters in the amount so received is disbursed through the AD which had handled the shipping documents post receipt of certificate issued by ECGC/ private insurance companies. The certificate will indicate the number of declaration form, name of the exporter, name of the AD, date of negotiation, bill number, invoice value and the amount actually received by ECGC/private insurance company.9. Export of goods through PostPostal Authorities shall allow export of goods by post only if the original copy of the EDF has been countersigned by an AD. Therefore, EDF which involve sending goods by post should be first presented by the exporter to an AD for countersignature. The procedure is as under:(i) AD shall countersign EDF after ensuring that the parcel has been addressed to their branch or correspondent bank in the country of import and return the original copy to the exporter, who shall then submit the EDF to the post office with the parcel.(ii) The duplicate copy of EDF shall be retained by the AD to whom the exporter shall submit relevant documents together with an extra copy of invoice for negotiation/collection, within the prescribed period of 21 days.(iii) The concerned overseas branch or correspondent shall be instructed to deliver the parcel to consignee against payment or acceptance of relative bill.(iv) AD may, however, countersign EDF covering parcels addressed direct to the consignees, provided:An irrevocable letter of credit for the full value of export has been opened in favor of the exporter and has been advised through the AD concerned OrThe full value of the shipment has been received in advance by the exporter through an AD. OrThe AD is satisfied, on the basis of the standing and track record of the exporter and the arrangements made for realization of the export proceeds.In such cases, particulars of advance payment/letter of credit / AD’s certification of standing, etc., of the exporter should be furnished on the form under proper authentication.(v) Any alteration in the name and address of consignee on the EDF form should also be authenticated by AD under its stamp and signature.10. Third party export proceedsRealization of export proceeds in respect of export of goods / software from third party should be duly declared by the exporter in the appropriate declaration form11. Grant of EDF waiverAD Category – I banks may consider requests for grant of EDF waiver from exporters as under:Status holders shall be entitled to export freely exportable items (excluding Gems and Jewellery, Articles of Gold and precious metals) on free of cost basis for export promotion subject to an annual limit of Rupees One Crore or 2% of average annual export realisation during preceding three licensing years, whichever is lower. For export of pharma products by pharmaceutical companies, the annual limit would be 2% of average annual export realisation during preceding three licensing years. In case of supplies of pharmaceutical products, vaccines and lifesaving drugs to health programmes of international agencies such as UN,WHO-PAHO and Government health programmes, the annual limit shall be upto 8% of the average annual export realisation during preceding three licensing years. Such free of cost supplies shall not be entitled to Duty Drawback or any other export incentive under any export promotion scheme.Exports of goods not involving any foreign exchange transaction directly or indirectly requires the waiver of EDF procedure from the Reserve Bank.12. Receipt of advance against exports(1) In terms of Regulation 15 of Notification No. FEMA 23 (R)/2015-RB dated January 12, 2016, where an exporter receives advance payment (with or without interest), from a buyer outside India, the exporter shall be under an obligation to ensure that the shipment of goods is made within one year from the date of receipt of advance payment; the rate of interest, if any, payable on the advance payment does not exceed London Inter-Bank Offered Rate (LIBOR) + 100 basis points; and the documents covering the shipment are routed through the AD Category – I bank through whom the advance payment is received.Provided that in the event of the exporter’s inability to make the shipment, partly or fully, within one year from the date of receipt of advance payment, no remittance towards refund of unutilized portion of advance payment or towards payment of interest, shall be made after the expiry of the said period of one year, without the prior approval of the Reserve Bank.EDPMS will capture the details of advance remittances received for exports in EDPMS. Henceforth, AD Category – I banks will have to report all the inward remittances including advance as well as old outstanding inward remittances received for export of goods/ software to EDPMS. Further, AD Category – I banks need to report the electronic FIRC to EDPMS wherever such FIRCs are issued against inward remittances.The quarterly return being submitted for delay in utilization of advances received for export stands discontinued.(2) AD Category- I banks can also allow exporters having a minimum of three years’ satisfactory track record to receive long term export advance up to a maximum tenor of 10 years to be utilized for execution of long term supply contracts for export of goods subject to the conditions as under:(i) Firm irrevocable supply orders and contracts should be in place. The contract with the overseas party/ buyer should be vetted and the same shall clearly specify the nature, amount and delivery timelines of the products over the years and penalty in case of non-performance or contract cancellation. Product pricing should be in consonance with prevailing international prices.(ii) Company should have capacity, systems and processes in place to ensure that the orders over the duration of the said tenure can actually be executed.(iii) The facility is to be provided only to those entities, which have not come under the adverse notice of Enforcement Directorate or any such regulatory agency or have not been caution listed.(iv) Such advances should be adjusted through future exports.(v) The rate of interest payable, if any, should not exceed LlBOR plus 200 basis points.(vi) The documents should be routed through one Authorized Dealer bank only.(vii) Authorised Dealer bank should ensure compliance with AML / KYC guidelines(viii) Such export advances shall not be permitted to be used to liquidate Rupee loans classified as NPA.(ix) Double financing for working capital for execution of export orders should be avoided.(x) Receipt of such advance of USD 100 million or more should be immediately reported to the Trade Division, Foreign Exchange Department, Reserve Bank of India, Central Office, Mumbai.(xi) In case Authorized Dealer banks are required to issue bank guarantee (BG) / Stand by Letter of Credit (SBLC) for export performance, then the issuance should be rigorously evaluated as any other credit proposal keeping in view, among others, prudential requirements based on board approved policy.BG / SBLC may be issued for a term not exceeding two years at a time and further rollover of not more than two years at a time may be allowed subject to satisfaction with relative export performance as per the contract.BG / SBLC should cover only the advance on reducing balance basis.BG / SBLC issued from India in favor of overseas buyer should not be discounted by the overseas branch / subsidiary of bank in India.Note: AD Category – I banks may also be guided by the Master Circular on Guarantees and Co-acceptances issued by Department of Banking Regulation.(xii) AD Category – I banks may allow the purchase of foreign exchange from the market for refunding advance payment credited to EEFC account only after utilizing the entire balances held in the exporter’s EEFC accounts maintained at different branches/banks.(3) AD Category- I banks may allow exporters to receive advance payment for export of goods which would take more than one year to manufacture and ship and where the ‘export agreement’ provides for shipment of goods extending beyond the period of one year from the date of receipt of advance payment subject to the following conditions:-(i) The KYC and due diligence exercise has been done by the AD Category – I bank for the overseas buyer;(ii) Compliance with the Anti-Money Laundering standards has been ensured;(iii) The AD Category-I bank should ensure that export advance received by the exporter should be utilized to execute export and not for any other purpose i.e., the transaction isa bonafide transaction;(iv) Progress payment, if any, should be received directly from the overseas buyer strictly in terms of the contract;(v) The rate of interest, if any, payable on the advance payment shall not exceed London Inter-Bank Offered Rate (LIBOR) + 100 basis points;(vi) There should be no instance of refund exceeding 10% of the advance payment received in the last three years;(vii) The documents covering the shipment should be routed through the same authorised dealer bank; and(viii) In the event of the exporter's inability to make the shipment, partly or fully, no remittance towards refund of unutilized portion of advance payment or towards payment of interest should be made without the prior approval of the Reserve Bank.(4) (i) As it has been observed that there is substantial increase in the number and amount of advances received for exports remaining outstanding beyond the stipulated period on account of non-performance of such exports (shipments in case of export of goods), AD Category –I banks are advised to efficiently follow up with the concerned exporters in order to ensure that export performance (shipments in case of export of goods) are completed within the stipulated time period.(ii) It is further reiterated that AD category –I banks should exercise proper due diligence and ensure compliance with KYC and AML guidelines so that only bonafide export advances flow into India. Doubtful cases as also instances of chronic defaulters may be referred to Directorate of Enforcement (DoE) for further investigation. A quarterly statement indicating details of such cases may be forwarded to the concerned Regional Offices of RBI within 21 days from the end of each quarter.13. EDF Approval for Trade Fair/Exhibitions abroadFirms / Companies and other organizations participating in Trade Fair/Exhibition abroad can take/export goods for exhibition and sale outside India without the prior approval of the Reserve Bank. Unsold exhibit items may be sold outside the exhibition/trade fair in the same country or in a third country. Such sales at discounted value are also permissible. It would also be permissible to 'gift’ unsold goods up to the value of USD 5000 per exporter, per exhibition/trade fair. AD Category – I banks may approve EDF of export items for display or display-cum-sale in trade fairs/exhibitions outside India subject to the following:(i) The exporter shall produce relative Bill of Entry within one month of re-import into India of the unsold items.(ii) The exporter shall report to the AD Category – I banks the method of disposal of all items exported, as well as the repatriation of proceeds to India.(iii) Such transactions approved by the AD Category – I banks will be subject to 100 per cent audit by their internal inspectors/auditors.14. Delay in submission of shipping documents by exportersIn cases where exporters’ present documents pertaining to exports after the prescribed period of 21 days from date of export, AD Category – I banks may handle them without prior approval of the Reserve Bank, provided they are satisfied with the reasons for the delay.15. Direct dispatch of documents by the exporter(i) AD Category – I banks should normally dispatch shipping documents to their overseas branches/correspondents expeditiously. However, they may dispatch shipping documents direct to the consignees or their agents resident in the country of final destination of goods in cases where:Advance payment or an irrevocable letter of credit has been received for the full value of the export shipment and the underlying sale contract/letter of credit provides for dispatch of documents direct to the consignee or his agent resident in the country of final destination of goods.The AD Category – I banks may also accede to the request of the exporter provided the exporter is a regular customer and the AD Category – I bank is satisfied, on the basis of standing and track record of the exporter and arrangements have been made for realization of export proceeds.(ii) AD Category – I banks may also permit 'Status Holder Exporters’ (as defined in the Foreign Trade Policy), and units in Special Economic Zones (SEZ) to dispatch the export documents to the consignees outside India subject to the terms and conditions that:The export proceeds are repatriated through the AD banks named in the EDF.The duplicate copy of the EDF is submitted to the AD banks for monitoring purposes, by the exporters within 21 days from the date of shipment of export.(iii) AD Category – I banks may regularize cases of dispatch of shipping documents by the exporter direct to the consignee or his agent resident in the country of the final destination of goods, up to USD 1 million or its equivalent, per export shipment, subject to the following conditions:The export proceeds have been realized in full.The exporter is a regular customer of AD Category – I bank for a period of at least six months.The exporter’s account with the AD Category – I bank is fully compliant with the Reserve Bank’s extant KYC / AML guidelines.The AD Category – I bank is satisfied about the bonafides of the transaction.In case of doubt, the AD Category – I bank may consider filing Suspicious Transaction Report (STR) with FIU_IND (Financial Intelligence Unit in India).16. Change of buyer/consigneePrior approval of the Reserve Bank is not required if, after goods have been shipped, they are to be transferred to a buyer other than the original buyer in the event of default by the latter, provided the reduction in value, if any, involved does not exceed 25 per cent of the invoice value and the realization of export proceeds is not delayed beyond the period of 9 months from the date of export. Where the reduction in value exceeds 25%, all other relevant conditions stipulated in paragraph C.17 should also be satisfied.17. Export of goods by Special Economic Zones (SEZs)(i) Units in SEZs are permitted to undertake job work abroad and export goods from that country itself subject to the conditions that:Processing / manufacturing charges are suitably loaded in the export price and are borne by the ultimate buyer.The exporter has made satisfactory arrangements for realization of full export proceeds subject to the usual EDF procedure.(ii) AD Category – I banks may permit units in DTAs to purchase foreign exchange for making payment for goods supplied to them by units in SEZs. Authorised Dealer Banks are permitted to sell foreign exchange to a unit in the DTA for making payment in foreign exchange to a unit in the SEZ for the services rendered by it (i.e. a unit in SEZ) to a DTA unit. It must be ensured that in the Letter of Approval (LoA) issued to the SEZ unit by the Development Commissioner(DC) of the SEZ, the provisions pertaining to the goods / services supplied by the SEZ unit to the DTA unit and for payment in foreign exchange for the same should be mentioned.18. Extension of time(i) The Reserve Bank of India has permitted the AD Category – I banks to extend the period of realization of export proceeds beyond stipulated period of realization from the date of export, up to a period of six months, at a time, irrespective of the invoice value of the export subject to the following conditions:The export transactions covered by the invoices are not under investigation by Directorate of Enforcement / Central Bureau of Investigation or other investigating agencies,The AD Category – I bank is satisfied that the exporter has not been able to realize export proceeds for reasons beyond his control,The exporter submits a declaration that the export proceeds will be realized during the extended period,While considering extension beyond one year from the date of export, the total outstanding of the exporter does not exceed USD one million or 10 per cent of the average export realizations during the preceding three financial years, whichever is higher.In cases where the exporter has filed suits abroad against the buyer, extension may be granted irrespective of the amount involved / outstanding.(ii) Cases which are not covered by the above instructions would require prior approval from the concerned Regional Office of the Reserve Bank.(iii) Reporting should be done in EDPMS.19. Write-off of unrealized export bills(i) An exporter who has not been able to realize the outstanding export dues despite best efforts, may either self-write off or approach the AD Category – I banks, who had handled the relevant shipping documents, with appropriate supporting documentary evidence. The limits prescribed for write-offs of unrealized export bills are as under:Self “write-off” by an exporter(Other than Status Holder Exporter)5%*Self “write-off” by Status Holder Exporters10%*‘Write-off” by Authorized Dealer Bank-10%**of the total export proceeds realized during the previous calendar year.(ii) The above limits will be related to total export proceeds realized during the previous calendar year and will be cumulatively available in a year.(iii) The above write-off will be subject to conditions that the relevant amount has remained outstanding for more than one year, satisfactory documentary evidence is furnished in support of the exporter having made all efforts to realize the dues, and the case falls under any of the undernoted categories:The overseas buyer has been declared insolvent and a certificate from the official liquidator indicating that there is no possibility of recovery of export proceeds has been produced.The overseas buyer is not traceable over a reasonably long period of time.The goods exported have been auctioned or destroyed by the Port / Customs / Health authorities in the importing country.The unrealized amount represents the balance due in a case settled through the intervention of the Indian Embassy, Foreign Chamber of Commerce or similar Organization;The unrealized amount represents the undrawn balance of an export bill (not exceeding 10% of the invoice value) remaining outstanding and turned out to be unrealizable despite all efforts made by the exporter;The cost of resorting to legal action would be disproportionate to the unrealized amount of the export bill or where the exporter even after winning the Court case against the overseas buyer could not execute the Court decree due to reasons beyond his control;Bills were drawn for the difference between the letter of credit value and actual export value or between the provisional and the actual freight charges but the amounts have remained unrealized consequent on dishonor of the bills by the overseas buyer and there are no prospects of realization.(iv) The exporter has surrendered proportionate export incentives if any, availed of in respect of the relative shipments. The AD Category – I banks should obtain documents evidencing surrender of export incentives availed of before permitting the relevant bills to be written off.(v) In case of self-write-off, the exporter should submit to the concerned AD bank, a Chartered Accountant’s certificate, indicating the export realization in the preceding calendar year and also the amount of write-off already availed of during the year, if any, the relevant EDF to be written off, Bill No., invoice value, commodity exported, country of export. The CA certificate may also indicate that the export benefits, if any, availed of by the exporter have been surrendered.(vi) However, the following would not qualify for the write off facility:Exports made to countries with externalization problem i.e. where the overseas buyer has deposited the value of export in local currency but the amount has not been allowed to be repatriated by the central banking authorities of the country.EDF which are under investigation by agencies like, Enforcement Directorate, Directorate of Revenue Intelligence, Central Bureau of Investigation, etc. as also the outstanding bills which are subject matter of civil / criminal suit.vii) AD banks should report write off of export bills through EDPMS to the Reserve Bank.viii) AD banks are advised to put in place a system under which their internal inspectors or auditors (including external auditors appointed by authorised dealers) should carry out random sample check / percentage check of write-off outstanding export bills.ix) Cases not covered by the above instructions / beyond the above limits, may be referred to the concerned Regional Office of Reserve Bank of India.20. Export claims(i) AD Category – I banks may remit export claims on application, provided the relative export proceeds have already been realized and repatriated to India and the exporter is not on the caution list of the Reserve Bank.(ii) In all such cases of remittances, the exporter should be advised to surrender proportionate export incentives, if any, received by him21. Write off in cases of payment of claims by ECGC and private insurance companies regulated by Insurance Regulatory and Development Authority (IRDA(i) AD Category – I banks shall, on an application received from the exporter supported by documentary evidence from the ECGC and private insurance companies regulated by IRDA confirming that the claim in respect of the outstanding bills has been settled by them, write off the relative export bills17in EDPMS.(ii) Such write-off will not be restricted to the limit of 10 per cent indicated above.(iii) Surrender of incentives, if any, in such cases will be as provided in the Foreign Trade Policy.(iv) The claims settled in rupees by ECGC and private insurance companies regulated by IRDA should not be construed as export realization in foreign exchange.22. Write-off – relaxationAs announced in the Foreign Trade Policy (FTP), 2015-20, realization of export proceeds shall not be insisted upon under any of the Export Promotion Schemes under the said FTP, subject to the following conditions:The write off on the basis of merits is allowed by the Reserve Bank or by AD Category – I bank on behalf of the Reserve Bank, as per extant guidelines;The exporter produces a certificate from the Foreign Mission of India concerned, about the fact of non-recovery of export proceeds from the buyer; andThis would not be applicable in self write off cases.23. Exporters’ Caution List1) Caution Listing/ de-caution Listing of exporters is automated in EDPMS. The updated list of caution listed exporters can be accessed through EDPMS on a daily basis. Criteria laid down for cautioning/ de-cautioning of exporters in EDPMS are as under:The exporters would be caution listed if any shipping bill against them remains open for more than two years in EDPMS provided no extension is granted by AD Category –I bank / RBI. Date of shipment will be considered for reckoning the realisation period.Once related bills are realised and closed or extension for realisation is granted, the exporter will automatically be de-caution listed.The exporters can also be caution listed even before the expiry of two years period based on the recommendation of AD banks. The recommendation may be based on cases where exporter has come to adverse notice of the Enforcement Directorate (ED)/ Central Bureau of Investigation (CBI)/ Directorate of Revenue Intelligence (DRI)/ any such other law enforcement agency or the case where exporter is not traceable or not making any serious efforts for realisation of export proceeds. In such cases, AD may forward its findings to the concerned regional office of RBI recommending inclusion of the name of the exporter in the caution list.Reserve Bank will caution / de-caution the exporters in such cases based on the recommendation of AD Category – I banks.2) AD Category – I banks should follow the procedure mentioned below while handling shipping documents in respect of caution listed exporters:(a) They will intimate the exporters about their caution listing, giving the details of outstanding shipping bills. When caution listed exporters submit shipping documents for negotiation / purchase/ discount/ collection, etc. the AD Category – I bank may accept the documents subject to following conditions:-The exporters concerned should produce evidence of having received advance payment or an irrevocable letter of credit in their favour covering the full value of the proposed exports;In case of usance bills, the relative letter of credit should cover full export value and also permit such drawings. Besides, the usance bills should also mature within prescribed realisation period reckoned from date of shipment.Except under the above mentioned conditions given in 2 (a) (i) and (ii), AD banks should not handle the shipping documents of caution listed exporters.(b) AD Category – I banks should obtain prior approval of the Reserve Bank for issuing guarantees for caution-listed exporters.24. Issue of Guarantees by an Authorised Dealer(i) AD Category – I banks may allow payment of commission, either by remittance or by deduction from invoice value, on application submitted by the exporter. The remittance on agency commission may be allowed subject to conditions as under:Amount of commission has been declared on EDF/SOFTEX form and accepted by the Customs authorities or Ministry of Information Technology, Government of India / EPZ authorities as the case may be. In cases where the commission has not been declared on EDF/SOFTEX form, remittance may be allowed after satisfying the reasons adduced by the exporter for not declaring commission on Export Declaration Form, provided a valid agreement/written understanding between the exporters and/or beneficiary for payment of commission exists.The relative shipment has already been made.(ii) AD Category – I banks may allow payment of commission by Indian exporters, in respect of their exports covered under counter trade arrangement through Escrow Accounts designated in US Dollar, subject to the following conditions:The payment of commission satisfies the conditions as at (a) and (b) stipulated in paragraph (i) above.The commission is not payable to Escrow Account holders themselves.The commission should not be allowed by deduction from the invoice value.(iii) Payment of commission is prohibited on exports made by Indian Partners towards equity participation in an overseas joint venture / wholly owned subsidiary as also exports under Rupee Credit Route except commission up to 10 per cent of invoice value of exports of tea & tobacco.