Risk Disclosure Statement

We are committed to providing a secure and transparent platform for your crypto-asset endeavors. As part of our commitment to transparency and client education, we want to ensure that you are well-informed about the potential risks associated with crypto-asset services. Before you explore our services, we encourage you to review our comprehensive list of risk disclosures. These disclosures outline the material risks you should be aware of when engaging in crypto-asset transactions. Understanding these risks is crucial to making informed decisions and navigating the dynamic landscape of digital assets.

Virtual Asset Standards

We prioritize compliance with the highest regulatory standards to ensure a trustworthy and resilient environment for your virtual asset activities. In line with the guidelines set forth by the Dubai Virtual Assets Regulatory Authority (VARA), we have implemented comprehensive Virtual Asset Standards designed to promote security, market integrity, and consumer protection. These standards govern how we operate, including the custody, listing, and trading of virtual assets on our platform. We encourage all clients to familiarize themselves with these standards, as they play a critical role in supporting a safe and transparent digital asset ecosystem. By understanding and adhering to these principles, you can participate more confidently in the evolving virtual asset marketplace.

Complaints Handling

We prioritize customer satisfaction and strive to maintain a transparent and efficient complaint resolution process. We understand that concerns may arise in the course of engaging with our virtual asset services, and we are committed to addressing them promptly, fairly, and in accordance with regulatory standard.

Terms of Business

These Terms of Business outline the terms and conditions governing your use of our services, establishing a legal framework for your interactions with us. Please carefully read and understand this Agreement before proceeding.

Whistleblowing Policy

We are committed to the highest standards of ethics, integrity, and accountability. Our Whistleblower Policy provides a secure and confidential framework for employees, clients, and other stakeholders to raise concerns regarding suspected misconduct, regulatory breaches, or unethical behaviour.

This mechanism supports responsible reporting by offering multiple secure channels, including anonymous submission options. All reports are handled confidentially and investigated promptly and impartially, with appropriate corrective action taken where necessary.

We enforce a strict no-retaliation policy for good faith disclosures and aligns its procedures with applicable regulatory requirements, including those of VARA. This reinforces our commitment to transparent and ethical business conduct.

Corporate Information

XBase Virtual Assets Broker & Dealer Services LLC is licensed by the Dubai Virtual Assets Regulatory Authority (VARA) to provide broker-dealer services to Qualified and Institutional Investors, as defined by VARA.
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Licence number VL/17/03/001.
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Responsible individuals:

SEO: Zeeshan Uppal

Compliance Officer: Agim Dauti

Pricing / Billing

We use transparent, fair, and client-centric pricing models to determine execution prices. These models take into account a range of inputs, including but not limited to:

• External market data from trading venues and/or bilateral liquidity providers

• The firm’s current risk exposure and inventory positions

• Client-specific configurations, defined by XBase Digital or tailored at the client’s request

Supported Virtual Assets

As part of our commitment to transparency and regulatory compliance,  a summary of trading activity for each Virtual Asset offered through our platform can be found here.

Conflicts of Interest

We are committed to maintaining the highest standards of integrity, transparency, and ethical conduct. Our Conflict of Interest Policy is designed to protect the firm’s integrity and ensure that business decisions are made in the best interests of the company and its clients.

In the normal course of operations, individuals associated with ys may encounter situations where personal interests could potentially conflict with their professional responsibilities. All such situations must be disclosed and managed appropriately to prevent undue influence or reputational risk.

Routing

XBase Virtual Assets Broker & Dealer Services LLC uses multiple liquidity sources for the execution of client orders.Orders are routed having regard to a range of execution factors, including price, available liquidity, cost, speed of execution, reliability, historical fill data, token characteristics and prevailing market conditions.

B2C2 Overseas Ltd

B2C2 is an institutional digital asset liquidity provider offering OTC spot liquidity and execution across a range of Virtual Asset and fiat currency pairs. Its services include streaming pricing, flexible trade sizes and settlement arrangements.

XBase uses B2C2 Overseas Ltd as a liquidity and execution provider for client orders.

Twenty percent (20%) or more of client orders are routed to B2C2 Overseas Ltd.

Price Determination

The liquidity source used for a particular order may vary depending on the relevant Virtual Asset, available liquidity, market conditions, execution speed and the price available at the time of the trade.XBase seeks to obtain competitive pricing for client orders by assessing available quotes and execution conditions from its liquidity sources at the time of each trade.

Custody

We carefully select our custodians and banking partners through rigorous, industry-standard due diligence. We ensure they implement robust security protocols and advanced technologies to safeguard client assets, which are held in segregated accounts designated specifically as client money or assets. These safeguards are designed to mitigate risks such as unauthorized access, fraud, and other potential threats.

Third-Party Accounts, Funds and Virtual Assets

XBase Virtual Assets Broker & Dealer Services LLC maintains client fiat funds in account(s) held with Zand Bank PJSC.

XBase uses Fireblocks Trust Company, LLC (Fireblocks) for wallet infrastructure in connection with the management and transfer of Virtual Assets. Fireblocks provides wallet technology and infrastructure; however,

XBase remains responsible for the operation and oversight of its Virtual Asset arrangements.

XBase will update this disclosure where there are material changes to its third-party account, funds or Virtual Asset arrangements.

Data

We are committed to protecting the privacy of our clients, stakeholders, and partners. To ensure that personal data is handled with the utmost care and in compliance with applicable data protection laws, we has established comprehensive data privacy policies and procedures. These policies outline the collection, use, storage, and safeguarding of personal data, ensuring that all data is managed responsibly and securely.
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For transparency, we have published our Data Privacy Policy on the website, providing clear information about clients’ rights concerning their personal data, including how they can request access, rectification, or deletion of their data. The policy also details the security measures in place to protect data from unauthorized access or breaches. We review and update our data privacy practices regularly to maintain compliance and uphold high standards of privacy protection.

Other Disclosures

• We partner with Zand Bank, a fully licensed bank regulated by the Central Bank of the UAE, for our corporate banking needs.

• Our Board Members and Senior Managers have no past convictions or prosecutions in UAE courts nor other jurisdictions.

• XBase Virtual Assets Broker & Dealer Services L.L.C does not refer or introduce clients to other Entities including, but not limited to, other VASPs.