Broker-Dealer Disclosures
ShipFinex FZCO is a Virtual Asset Service Provider (VASP) operating under In-Principle Approval (IPA No: IPA/26/01/002) from the Virtual Assets Regulatory Authority (VARA) to provide Broker-Dealer Services for Maritime Asset Tokens (MATs). The full operational licence is pending grant by VARA. In compliance with VARA regulations, we publish the following mandatory disclosures regarding our services, assets, and operational practices.
Entity: ShipFinex FZCO | Registered in: International Free Zone Authority (IFZA), Dubai, UAE Registration No: 23787 | Registered Office: IFZA Business Park, Dubai Silicon Oasis, Dubai, UAE | VARA IPA Reference: IPA/26/01/002 | Email: [email protected]
Permitted Activity Scope: ShipFinex FZCO is authorised under its IPA to provide Broker-Dealer Services for Maritime Asset Tokens (MATs) only. ShipFinex FZCO does not hold or maintain client fiat funds or Virtual Assets on an ongoing basis, does not provide custody services for client Virtual Assets, does not provide clearing services for third-party Virtual Asset Service Providers (VASPs), and does not offer stablecoin dealing or exchange services as a standalone product. USDC is used solely as a settlement and denomination currency in connection with MAT transactions on the Shipfinex platform.
Disclosure Architecture: The documents published on this page are issued by ShipFinex FZCO in its capacity as VARA-regulated broker-dealer (IPA/26/01/002). They cover the ShipFinex FZCO platform, services, and broker-dealer obligations. Offering-specific disclosures — including Offering Prospectuses, per-MAT risk disclosures, vessel due diligence summaries, and SPV financial information — are issued by the individual SPV issuers and are available exclusively within the ShipFinex secure investor portal following client onboarding and verification. ShipFinex FZCO reviews all issuer disclosures for compliance with VARA standards before any MAT is made available on the platform.
1. Conflicts of Interest (I.B.1.a)
ShipFinex FZCO has implemented comprehensive procedures to identify, manage, and disclose actual or potential conflicts of interest. Our conflicts of interest policy ensures that all business activities are conducted with integrity and transparency. For detailed information on how we manage conflicts, please refer to our full Conflicts of Interest Policy published on the Shipfinex website.
2. Privacy, Whistleblowing & Complaints (I.B.1.b-c)
Shipfinex is committed to protecting your privacy and maintaining confidential reporting channels for whistleblowing. We have established procedures for handling client complaints promptly and fairly. Detailed policies and procedures are available on our Privacy Policy page, Whistleblowing Policy page, and Client Complaints page.
3. Virtual Asset Information (I.B.1.d)
Detailed per-VA information will be published for each listed asset upon grant of the full operational license. For each Virtual Asset offered on the Shipfinex platform, the following information will be available on each asset’s listing page: asset name and token symbol; date of issuance; total and circulating supply; market capitalization; price history; audit status and date of most recent independent smart contract audit; underlying maritime asset details; largest price decline from high to low (absolute and percentage).
4. Pricing Methodology (I.B.1.e)
ShipFinex FZCO determines the fair market value of each maritime vessel underlying a Maritime Asset Token (MAT) using a multi-source, independent valuation methodology designed to deliver a robust and auditable fair value. The methodology operates as follows: Step 1 — Dual-Source Base Valuation: Each vessel is independently valued by (a) the VesselsValue.com automated valuation platform, which applies real-time market data, vessel-specific parameters, and comparable sale evidence; and (b) an independent, internationally recognized panel shipbroker firm. The base vessel value is the arithmetic average of these two independent values. Step 2 — Variance Trigger (Three-Broker Resolution): If the absolute variance between the VesselsValue.com value and the independent broker valuation exceeds 5%, a second independent panel shipbroker is engaged to conduct its own valuation. In such cases, the base vessel value is the arithmetic average of all three independent values. Step 3 — Extras Adjustment: The final MAT valuation adds to the Step 1/2 base vessel value the independently assessed value of on-board spares, bunkers (fuel), lubricating oils, and consumable stores. These items are excluded from automated and broker vessel valuations but represent tangible, fully paid-for assets transferred to the SPV with the vessel and carry real economic value to token holders. Final Asset Value = Base Vessel Value (Steps 1–2) + Extras Value (Step 3) Revaluations are conducted no less frequently than every six (6) months, and on an event-triggered basis following any significant market dislocation, casualty event, or material change in the vessel's trading pattern or condition. All valuations are documented and retained for regulatory audit purposes.
Buyer transaction fee: 1.25% of transaction value
Seller transaction fee: 1.25% of transaction value
5. Order Routing (I.B.1.f)
Shipfinex operates a single-venue peer-to-peer matching platform. All client orders are executed on the Shipfinex platform without routing to external venues. We do not maintain payment-for-order-flow arrangements with third parties. The entire trading process occurs on our regulated platform, ensuring full transparency and client control.
6. Clearing & Settlement (I.B.1.g)
Transactions on the ShipFinex platform are settled on the Polygon blockchain. Settlement is typically completed within minutes of trade execution. On-chain settlement provides immutable, transparent, and cryptographically secured transaction records that are independently verifiable. ShipFinex FZCO does not hold or maintain funds or Virtual Assets on behalf of clients or third parties, nor does it provide clearing services for other Virtual Asset Service Providers (VASPs).
7. Client Asset Protection (I.B.1.h)
ShipFinex FZCO does not hold or maintain client fiat funds or Virtual Assets on an ongoing basis, does not provide custody services, and does not provide clearing services for third-party Virtual Asset Service Providers. ShipFinex FZCO operates a non-custodial broker-dealer model. Client virtual assets are held in individually assigned, self-custodied Fireblocks MPC wallets under the client's own control — ShipFinex FZCO never holds, controls, or has access to client funds or virtual assets. Fiat on/off-ramping is facilitated through Hubpay (UAE-regulated electronic money institution), which acts as an operational transit account only — it is not a client money account and fiat amounts in transit are not held in trust. For detailed information, please refer to our Client Asset Protection page.
8. Referrals & Third-Party Arrangements (I.B.1.i)
ShipFinex FZCO does not hold or maintain funds or Virtual Assets on behalf of clients, nor does it provide clearing services for other VASPs. ShipFinex does not operate a referral program to other Virtual Asset Service Providers. Third-party service providers engaged by ShipFinex FZCO in connection with platform operations include: Hubpay (UAE-regulated fiat transit) and Fireblocks (MPC wallet infrastructure and custody technology). A full list of third-party service providers, including the nature of each relationship and any associated material dependencies, is published in our Third-Party Service Provider Register on the ShipFinex website. No monetary or non-monetary benefits are received from third-party referrals of clients.
9. Senior Management Criminal History (I.B.2)
In accordance with VARA VA Broker-Dealer Activity Rulebook Part I.B.2, Shipfinex FZCO confirms that all members of senior management and the Board of Directors have undergone Fit & Proper assessments as required by VARA. To the best of Shipfinex’s knowledge and as declared to VARA through the Fit & Proper process, no member of senior management or the Board of Directors has been convicted of any criminal offence relevant to the provision of Virtual Asset services.
10. Client Agreement Structure
Shipfinex operates a two-tier agreement model. All clients sign the Terms of Service upon onboarding. Prior to each Maritime Asset Token (MAT) purchase, clients are required to review and sign a bilateral MAT Purchase Agreement specific to the offering. The platform will not permit a purchase to proceed without execution of the bilateral agreement. This ensures informed consent for each investment decision.
Regulatory Disclosure & Risk Warning
Maritime Asset Risk: The value of MATs is directly linked to the market value of the underlying maritime vessel. Vessel values are influenced by global shipping market conditions, charter rates, vessel age and technical condition, commodity cycles, trade routes, and geopolitical events. Values may decline materially and without warning.Unlike speculative Virtual Asset tokens with no underlying asset, MATs are backed by a physical maritime vessel held within an SPV. The vessel retains intrinsic market value — including, at minimum, scrap and salvage value — at all times. However, this floor may be insufficient to recover your initial investment, particularly if the vessel is older, carries outstanding SPV liabilities, or is sold in distressed market conditions. In the event of a vessel total loss, recovery depends on the insurance proceeds of the SPV — hull and machinery insurance is maintained by each SPV as the registered vessel owner, not by ShipFinex FZCO.
Before investing, please read the full Risk Disclosure Statement published on the ShipFinex website. If you are uncertain whether investing in MATs is appropriate for your circumstances, you should seek independent financial advice.
Regulatory Notice: This document is published by ShipFinex FZCO in compliance with VARA VA Broker-Dealer Activity Rulebook Part IV.B.5. ShipFinex FZCO operates under VARA IPA/26/01/002. The full operational licence is pending grant by VARA. Nothing in this document constitutes an offer to sell or a solicitation to buy any Virtual Asset.