Platform Risk Disclosure
ShipFinex FZCO | VARA IPA: IPA/26/01/002 | Version: 1.0 | April 2026
IMPORTANT | This document covers risks specific to the ShipFinex FZCO broker-dealer platform. Risks specific to individual Maritime Asset Token (MAT) offerings — including vessel valuation risk, charter market risk, and SPV-level risks — are disclosed in the Offering Prospectus for each MAT, which is available exclusively within the ShipFinex secure investor portal following completion of client verification and onboarding. |
1. Introduction
ShipFinex FZCO operates under In-Principle Approval (IPA/26/01/002) issued by the Virtual Assets Regulatory Authority (VARA) in Dubai, UAE. The full operational licence is pending grant by VARA. ShipFinex FZCO provides Broker-Dealer Services — it facilitates the purchase and sale of Maritime Asset Tokens (MATs) issued by foreign Special Purpose Vehicles (SPVs) that own individual maritime vessels.
ShipFinex FZCO is the broker-dealer intermediary. It is not the issuer of MATs. Each MAT is issued by an independent SPV. Asset-specific risk disclosures are the responsibility of the issuing SPV and are provided in the per-offering Prospectus. This document covers only platform-level risks arising from the use of the ShipFinex FZCO brokerage platform and services.
2. Nature of Maritime Asset Tokens
MATs are Real World Asset (RWA) tokens representing fractional equity ownership in SPVs that hold maritime vessels. Unlike speculative Virtual Asset tokens with no underlying asset, MATs derive their value from the market value of an operating vessel. Vessel values may decline materially and you may not recover the full amount invested. MATs are not deposits, not guaranteed instruments, and not equivalent to listed securities.
MATs are not traded on any public exchange. Resale is subject to finding a willing buyer on the ShipFinex secondary marketplace. There is no guarantee of liquidity at any particular time or price.
3. Platform & Technology Risks
3.1 Trade Execution
During periods of high trading volume, the ShipFinex platform may experience delays in executing transactions. You may be unable to execute at the prices or times you intend. Market conditions may change materially between the time you place and the time your transaction is confirmed.
3.2 Platform Availability
The ShipFinex platform may experience temporary unavailability due to maintenance, upgrades, technical failures, or force majeure events. ShipFinex FZCO does not guarantee uninterrupted access. Periods of unavailability may prevent you from accessing or transacting with your MATs.
3.3 Blockchain Network Risk
MAT transactions settle on the Polygon blockchain. Network congestion, protocol errors, validator failures, or network forks may delay, prevent, or reverse the intended outcome of transactions. Blockchain transactions once confirmed are irreversible. ShipFinex FZCO has no ability to reverse confirmed on-chain transactions.
3.4 Smart Contract Risk
Smart contracts governing MAT issuance and transfer may contain bugs, vulnerabilities, or produce unintended outcomes. Errors in smart contract code could result in permanent loss of assets or inability to transfer MATs. Smart contracts are audited prior to deployment; however, audits do not guarantee the absence of all vulnerabilities.
3.5 Wallet & Access Risk
Client MATs are held in non-custodial Fireblocks MPC wallets. ShipFinex FZCO does not hold or control client wallet credentials. Clients are solely responsible for maintaining secure access to their wallets. Permanent loss of wallet access credentials may result in permanent loss of access to your MATs. ShipFinex FZCO cannot recover lost wallet credentials on your behalf.
4. Regulatory & Compliance Risks
4.1 In-Principle Approval Status
ShipFinex FZCO currently operates under a VARA In-Principle Approval (IPA/26/01/002). The full operational licence is pending grant. VARA may impose conditions on, modify, or decline to grant the full licence. If the full licence is not granted, ShipFinex FZCO may be unable to continue providing broker-dealer services.
4.2 Evolving Regulatory Framework
The regulatory framework for Virtual Assets in the UAE and globally is evolving. Future regulatory changes may restrict, expand, or alter the services ShipFinex FZCO is permitted to provide, impose additional requirements on investors, or affect the legal status of MATs in specific jurisdictions. ShipFinex FZCO cannot guarantee that its regulatory status will remain unchanged.
4.3 Geo-Restriction & Eligibility
Access to the ShipFinex platform and MAT offerings is restricted by jurisdiction. Certain categories of investor may be ineligible to invest in MATs under applicable law. It is your responsibility to confirm that investing in MATs is permitted in your jurisdiction and that you meet the eligibility criteria set out in the Client Categorisation & Eligibility Policy.
5. Cybersecurity Risks
Hacking, phishing, malware, and unauthorised access to platform accounts or private keys could result in loss of or inability to access your MATs. ShipFinex FZCO implements security controls consistent with its VARA obligations and Fireblocks MPC architecture; however, no security system is impenetrable. You are responsible for maintaining the security of your login credentials, two-factor authentication, and device security.
6. No Client Money or Deposit Protection
ShipFinex FZCO does not hold client fiat funds or Virtual Assets on an ongoing basis. Virtual Assets held in non-custodial Fireblocks MPC wallets are under client control and are not covered by any deposit insurance, investor compensation scheme, government guarantee, or similar protection. Fiat amounts in transit through Hubpay are not held in trust and do not attract client asset protection rules.
7. No Investment Advice
ShipFinex FZCO does not provide investment, financial, tax, or legal advice. Nothing on the ShipFinex platform or in this document constitutes a personal recommendation or advice to invest in any MAT or Virtual Asset. You should seek independent professional advice before making any investment decision.
8. VARA Regulatory Disclaimer
ShipFinex FZCO operates under VARA IPA/26/01/002. The full operational licence is pending grant by VARA. Maritime Asset Tokens are Real World Asset tokens backed by physical maritime vessels. Their value may decline significantly and you may not recover your initial investment. Past performance is not indicative of future results. ShipFinex FZCO does not guarantee any returns on investment.
This document is published by ShipFinex FZCO in compliance with VARA VA Broker-Dealer Activity Rulebook Part IV.B.5. Nothing herein constitutes an offer to sell or a solicitation to buy any Virtual Asset. Last updated: April 2026.
9. Acknowledgment
By using the ShipFinex platform or investing in Maritime Asset Tokens, you acknowledge that you have read and understood this Platform Risk Disclosure, and that you have separately reviewed the Offering Prospectus for any specific MAT you wish to invest in. For questions: [email protected] | VARA: www.vara.ae