VA Disclosure - 2
Market Conduct Public Disclosures
As per Market Conduct Rulebook / Part V – Public Disclosures / A. Licence Details and Authorised VA Activities
Information regarding the Shipfinex FZCO VARA license including license number, licensed activities and names of all responsible individuals.
License Number
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Licensed Activities
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Names of All Responsible Individuals
Vikas Pandey, CEO
Chief Compliance Officer (TBA)
As per Market Conduct Rulebook / Part V – Public Disclosures / B. Risk Disclosure Statement
Risk Disclosures for Shipfinex FZCO
General Risks Associated with Virtual Assets (VAs)Investing or trading in Virtual Assets (VAs) carries inherent risks due to their speculative, volatile, and evolving nature. These include:
Total Loss of Value:
VAs may lose all their value, leading to significant financial losses for investors.
Not Legal Tender:
VAs are not legal tender, are not backed by governments, and may not be accepted as a means of payment.
Price Volatility:
The prices of VAs are subject to significant fluctuations, which may lead to large swings in the value of investments over short periods.
Illiquidity:
Markets for certain VAs may become illiquid, making it difficult to buy, sell, or convert assets into fiat currency.
Market Manipulation:
VAs may be susceptible to manipulation through rumours, pump-and-dump schemes, or irrational market sentiment.
Technology Risks:
VAs rely on blockchain technology, which can face disruptions such as 51% attacks, forks, or technical failures. Users may lose access to their VAs due to lost private keys or technological issues.
Regulatory Uncertainty:
Global regulatory frameworks around VAs continue to evolve, which could restrict their use, impact pricing, or affect their legal status.
Cybersecurity Risks:
VAs are susceptible to theft or hacking due to the intangible and digital nature of the assets.
Stablecoin Risks:
Stablecoins may face challenges such as de-pegging, lack of audit transparency, or operational failures of associated custody platforms.
Public nature of blockchain transactions
Transactions are not private and may be recorded on public DLTs
Specific Risks Associated with Shipfinex’s Platform and Services
Trade Execution Risks:
Delays may occur in executing trades or processing transactions due to compliance reviews or platform issues, leading to missed opportunities or losses.
Internet Trading Risks:
Users may experience disruptions, errors, or communication failures when trading due to network connectivity or system errors.
Cybersecurity Threats:
Risks such as phishing, brute force attacks, or malware could lead to unauthorized access to user accounts or the loss of assets.
Hard Forking:
VAs undergoing "hard forks" may result in split assets, and Shipfinex may not support the forked assets, requiring users to withdraw them to external wallets.
Regulatory Risks:
Shipfinex is subject to regulatory oversight, and enforcement actions or restrictions may impact user access to VAs or platform operations.
Important Notes
Shipfinex does not provide financial, tax, or investment advice. Users should consult with independent advisors to evaluate their individual financial circumstances.
These disclosures are not exhaustive, and unforeseen risks may arise. Investors must fully understand the risks associated with VAs before participating in trading or investment activities on the Shipfinex platform.
For further details, please contact [email protected]
Shipfinex Public Disclosure for Broker-Dealer Services (Broker-Dealer Services Rulebook / Part I – Policies, Procedures and Public Disclosures / B. Public Disclosures)
As required under the VARA Broker-Dealer Services Rulebook and related regulations, the
following disclosures are made publicly available to ensure transparency and compliance
with applicable laws.
1. Conflict of Interest Management
Shipfinex FZCO identifies, mitigates, and manages conflicts of interest arising from its operations and activities.
○ At present there are no identified conflicts of interest arising out of Shipfinex FZCO’s activities
○ Details of future conflicts identified during asset assessments will be disclosed on the website as part of the Virtual Asset listing process.
2. Policies and Procedures
Summaries of key policies governing operations:
○ Data Privacy Policy: Shipfinex ensures the protection of client data through encryption, restricted access, and compliance with UAE Personal Data Protection Law. Full details are available here.
○ Whistleblowing Policy: A confidential reporting mechanism is available for employees and third parties to report unethical or unlawful activities without fear of retaliation. You can write [email protected] for a copy of our whistleblowing policy
○ Client Complaints Policy: Complaints are managed in accordance with Rule III.A and Rule VIII.A.3 of the VARA Market Conduct Rulebook. Clients can submit complaints via the website or email ([email protected]) and resolutions are tracked and reported to VARA. A copy of our Complaints Handling Policy are available here.
3. Details of Virtual Assets (VA) Offered
For each Virtual Asset (VA) listed, Shipfinex will disclose:
○ Name and Symbol.
○ Date of Issuance.
○ Market Capitalization and Fully Diluted Value.
○ Circulating Supply as a percentage of maximum total supply (if applicable).
○ Smart Contract Audit: Whether an independent audit has been conducted and the date of the most recent audit.
○ Price Performance: Largest reduction in price from high to low, stated as both an absolute amount and a percentage, along with the date of occurrence. This information will be updated regularly on the VA Listings Page
4. Pricing of Virtual Assets
Prices of Virtual Assets quoted on the Shipfinex platform are determined using:
○ Market Data Aggregation: Data from global liquidity providers and market makers (if used).
○ Pricing Algorithms: Real-time algorithms adjust prices based on trading volumes and market conditions.
○ Transparency: Any applicable fees or charges are disclosed before execution.
5. Routing Practices
○ Order Routing: Orders are routed based on best execution practices. If more than 20% of orders are routed to a single liquidity source, details of the source will be disclosed on the website.
6. Statement about other VASP’s
Shipfinex does not hold or maintain funds or Virtual Assets or provide clearing services for other VASPs providing Broker-Dealer Services
7. Client Ownership Protection
Shipfinex ensures the protection of client monies through:
○ Segregated Client Money Accounts: Assets held in segregated & clearly marked accounts distinct from company operational accounts.
○ Audits: Regular audits of client balances to ensure compliance are carried out.
○ Insurance Coverage: Assets are insured against cybersecurity breaches and other risks where applicable.
8. Introducing: Shipfinex does not introduce our clients to any other entities
9. Custody:
Under our self-custody model, Shipfinex does not hold client virtual assets (Client VAs). Instead, we provide a secure, transparent, and user-centric platform where clients maintain complete control and ownership of their digital assets at all times through their own wallets. Shipfinex adopts a transparent and secure wallet structure where each client is provided with dedicated, self-custodial hot wallets for managing their assets.
10. Updates and Accessibility
○ All disclosures are reviewed periodically and updated to reflect operational changes, new VA listings, or regulatory amendments.
○ Disclosures are prominently available on the Shipfinex website in a dedicated Legal section for ease of access.
For more information or inquiries, contact [email protected]