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Client Asset Protection

How Your Assets Are Protected

ShipFinex FZCO acts as principal in USDC transactions — dealing from its own pre-funded corporate treasury — and as VARA-regulated broker-dealer in MAT transactions, facilitating issuance and secondary trading on behalf of the issuing SPV. ShipFinex FZCO does not hold, control, or have access to customer funds or virtual assets at any point. There are no omnibus wallets. All client wallets are individually assigned, self-custodied Fireblocks MPC wallets that remain exclusively under client control and are fully traceable on-chain.

Fiat On/Off-Ramping

When an investor deposits fiat via bank transfer, funds arrive at Shipfinex's Hubpay account — an operational fiat transit account, NOT a Client Money Account. On receipt of fiat, USDC is delivered from Shipfinex's pre-funded corporate treasury to the investor's self-custodied Fireblocks wallet, typically within minutes. Fiat passes through the transit account and is never held on behalf of clients. Hubpay is a UAE-licensed payment services provider used solely for fiat transit. SPV-level fiat bank accounts are maintained separately by Transfermate on a per-SPV basis.

Virtual Assets

Each investor and shipowner is assigned an individually dedicated Fireblocks MPC wallet that they self-custody. Shipfinex does not have access to, control over, or custody of client virtual assets at any time. MATs are ERC-3643 registered, identity-bound tokens — every holder is KYC-verified and registered in an on-chain identity registry. You retain full ownership and control of your tokens at all times.

Third-Party Service Providers (BD I.B.1.i)

In accordance with VARA VA Broker-Dealer Activity Rulebook Part I.B.1.i, ShipFinex FZCO discloses the following third-party service providers involved in platform operations: (1) Fireblocks — MPC wallet infrastructure providing individually assigned, self-custodied wallets for clients, shipowners, and SPVs; (2) Hubpay — UAE Central Bank licensed electronic money institution used as an operational fiat transit account for on/off-ramping only — NOT a client money account; (3) Transfermate — regulated payment institution (Central Bank of Ireland) maintaining per-SPV bank accounts for Ship-Owning Special Purpose Vehicles; (4) USDC — the sole settlement and denomination currency on the ShipFinex platform, held in ShipFinex FZCO's corporate treasury and delivered to clients' self-custodied Fireblocks wallets as part of MAT settlement activity — ShipFinex FZCO does not have a direct contractual relationship with USDC's issuer; (5) Polygon — Layer 2 blockchain network on which Maritime Asset Tokens (ERC-3643) are issued and settled. ShipFinex FZCO does not hold client funds or virtual assets. All client assets remain in self-custodied wallets under the client's own control.

Daily Reconciliation

Shipfinex performs daily reconciliation of on-chain wallet balances and platform records. These reconciliations compare internal transaction records with blockchain state to verify accuracy and identify any discrepancies immediately.

Important Disclosure: No Deposit Protection

Virtual Assets and USDC held in your self-custodied Fireblocks wallet are NOT covered by any deposit insurance, investor compensation scheme, or similar protection. Fiat funds in transit through Hubpay prior to USDC delivery are not client money deposits and are not covered by deposit protection. In the unlikely event of Shipfinex ceasing operations, your virtual assets remain in your self-custodied wallet and are immediately recoverable. Any fiat amounts in transit through Hubpay at that time would constitute an unsecured creditor claim against Shipfinex FZCO — they are not client money deposits, are not held in trust, and do not attract client asset protection rules. Typical fiat transit times are measured in minutes; Shipfinex does not hold client fiat on an ongoing basis.

Client Ownership

All Virtual Assets purchased by you through the Shipfinex platform remain your property at all times. Shipfinex does not claim any ownership interest in client Virtual Assets. Your ownership is recorded on the Polygon blockchain via ERC-3643 smart contracts and protected through cryptographic protocols and on-chain identity registry.

Monthly Account Statements

Clients can access detailed monthly account statements showing all balances and transactions. These statements provide complete visibility into your account and serve as a record of all activities conducted on your behalf.

Independent Audit

Shipfinex's operational accounts and platform transaction records are subject to independent audit conducted by Affiniax, the appointed external auditor. These audits verify the accuracy of records, the integrity of on-chain balances, and compliance with VARA regulatory requirements.

Regulatory Framework

Shipfinex operates under the Virtual Assets Regulatory Authority (VARA) regulatory framework. Our client asset protection procedures comply with the VARA Market Conduct Rulebook and the VA Broker-Dealer Activity Rulebook.

Questions or Concerns?

If you have any questions about how we protect your assets, please contact our support team at [email protected].

Published: April 7, 2026

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