Third-Party Service Provider Register
ShipFinex FZCO publishes this register in accordance with VARA VA Broker-Dealer Activity Rulebook Part I.B.1.i (Referrals and Third-Party Arrangements) and Market Conduct Rulebook Part V.A (Conflicts of Interest Disclosure). This register identifies material third-party service providers engaged by ShipFinex FZCO in connection with platform operations and client-facing services. It is reviewed and updated no less frequently than annually, and following any material change to a provider relationship.
Custody & Wallet Infrastructure
Fireblocks Inc.
MPC Wallet Infrastructure — client MATs are held in individually assigned, non-custodial Fireblocks MPC vaults under client control.
Nature of Relationship
Technology partner. ShipFinex FZCO does not hold or access client wallet credentials. Material dependency — core platform infrastructure.
Regulatory Status
SOC 2 Type II certified. New York Department of Financial Services (DFS) BitLicense holder. Recognised by major regulated custodians globally.
Polygon Labs (Polygon PoS Network)
Public blockchain network providing the settlement layer for MAT token issuance, transfer, and on-chain transaction records.
Nature of Relationship
Infrastructure dependency. ShipFinex FZCO deploys and operates smart contracts on the Polygon network. Settlement is irreversible once confirmed on-chain.
Regulatory Status
Decentralised public protocol. Not a regulated entity. Polygon PoS is an established, EVM-compatible Layer 2 network with significant institutional adoption.
Banking & Payment Infrastructure
Hubpay
UAE fiat on/off-ramp transit — facilitates client fiat deposits and withdrawals in connection with MAT settlement.
Nature of Relationship
Operational transit account only. Not a client money account. Fiat amounts transiting Hubpay are not held in trust and do not attract client asset protection rules. Typical transit time is measured in minutes.
Regulatory Status
Licensed Electronic Money Institution regulated by the Central Bank of the UAE.
Valuation & Data Providers
VesselsValue Ltd
Automated maritime vessel valuation platform — provides API-based vessel valuations using real-time market data, comparable sale evidence, and vessel-specific parameters. One of two primary inputs to the ShipFinex MAT valuation methodology.
Nature of Relationship
Valuation data input (one of dual sources). VesselsValue output is averaged with an independent broker valuation to determine base vessel value. Not sole or determinative valuation source.
Regulatory Status
UK-based commercial data provider. Used by major ship finance banks, P&I clubs, and institutional investors. Not a regulated valuation body.
Independent Panel Shipbroker(s)
Independent vessel valuation opinion — one or more internationally recognised, Baltic Exchange member S&P shipbroker firms provide written valuation opinions for each MAT-underlying vessel.
Nature of Relationship
Independent valuation counterparty. Panel broker is rotated periodically to maintain independence. Where variance between VesselsValue and broker opinion exceeds the internal threshold, a second independent broker is engaged. Full details in the MAT Valuation Methodology Policy.
Regulatory Status
Baltic Exchange member firms with recognised Sale & Purchase (S&P) desks. Subject to Baltic Exchange Code of Ethics.
Compliance & KYC/AML Technology
Sumsub
Client onboarding KYC/AML verification platform — automated identity verification, document authentication, liveness checks, sanctions screening, and PEP/adverse media monitoring for all ShipFinex clients and counterparties.
Nature of Relationship
Technology partner for client onboarding. Sumsub processes personal data under a Data Processing Agreement consistent with UAE PDPL and applicable privacy law. ShipFinex FZCO retains data ownership and regulatory responsibility for KYC decisions.
Regulatory Status
UK-registered compliance technology provider. ISO 27001 certified. SOC 2 Type II.
Audit & Assurance
Affiniax Partners
Independent External Auditor — statutory annual audit of ShipFinex FZCO and SPV financial statements.
Nature of Relationship
Independent statutory auditor. Reports to the Board Audit Committee. No management or advisory role.
Regulatory Status
UAE-licensed audit firm, registered with the UAE Ministry of Economy.
Nexdigm
Co-source Internal Auditor — independent internal audit engagements including risk-based audits, VARA compliance reviews, and controls testing.
Nature of Relationship
Co-source partner to Head of Internal Audit. Reports to Board Audit Committee. Operationally independent of management.
Regulatory Status
UAE-licensed professional services firm with international affiliations.
ShipFinex FZCO does not hold or maintain client funds or Virtual Assets on behalf of any third party and does not provide clearing services for other Virtual Asset Service Providers. None of the third-party relationships listed above constitute a referral arrangement involving monetary or non-monetary benefit to ShipFinex FZCO from the referral of clients.
This register was last reviewed: April 2026. Next scheduled review: April 2027 or upon any material change, whichever is earlier.