Conflicts of Interest Disclosure.
Pursuant to Art 72 para 2 MiCAR, Cryptonow GmbH ("Cryptonow") as Crypto-asset service provider shall, disclose to their clients and prospective clients the general nature and sources of conflicts of interest and the steps taken to mitigate them.
Conflicts of Interest at Cryptonow may arise in various circumstances, particularly in relation to the provision of crypto-asset services, partnerships, internal decision-making, and interactions with Clients. These conflicts may occur directly within Cryptonow’s operations or indirectly through relationships with consultants, advisers, delegates, or outsourced service providers.
A conflict of interest is any situation in the financial, personal, or other interest may interfere with the ability to act impartially and in the best interest of clients and other stakeholders. Conflicts of Interest at Cryptonow may arise in various circumstances, particularly in relation to the provision of crypto-asset services, partnerships, internal decision-making, and interactions with Clients. These conflicts may occur directly within Cryptonow’s operations or indirectly through relationships with consultants, advisers, delegates, or outsourced service providers.
The following table sets out the services, activities or circumstances giving rise, or which may give rise, to conflicts of interest by Cryptonow, the risks identified in relation to them as well as the steps and measures taken by Cryptonow to mitigate the identified conflicts of interest.
| Risk category | Risks Identified | Measures and Controls | Persons involved / nature of the conflict |
|---|---|---|---|
| Financial Interests and Personal Gains | Employees, management, or shareholders have a direct or indirect financial interest in a crypto-asset, transaction, or business relationship that may influence their decision-making. Example: An employee holds personal investments in a crypto-asset offered by Cryptonow, affecting impartiality. | • Cryptonow offers its exchange services on an automated basis with practically no manual interference • A comprehensive market surveillance system monitors trading activity to preserve integrity • Cryptonow has specific rules and close monitoring of personal transactions of employees, management and shareholders of Cryptonow | • Employees, management, or shareholders • Clients |
| Dual Roles and External Affiliations | Employees or management hold positions or financial interests in external companies, partners, or competitors, leading to potential conflicts in decision-making. Example: A management board member of Cryptonow is a shareholder in the company itself as well as in other companies. | • The management board of Cryptonow follows distributed decision-making rules ensuring that any potential conflict can not materialize • Where and if necessary, the respective individual may be restricted in participating in certain decision processes | • Employees and management |
| Client-Related Conflicts | Business or personal relationships between Cryptonow employees and Clients that could lead to preferential treatment or biased service. Example: A staff member prioritizes a Client’s interests due to personal connections, disadvantaging others. | • Cryptonow charges fees based on transparent fee schedules taking into consideration objective criteria • Services provided by Cryptonow are vastly automated, non-discriminatory and do not allow for biased service provisioning | • Employees and management • Clients |
| Group-Level Conflicts | Business interests within a broader Group structure that may impact Cryptonow’s decisions, potentially compromising Client interests. Example: Cryptonow could refer Clients to affiliated entities without full disclosure. | • Cryptonow, in line with its internal policies, maintains full transparency with regards to group related interactions and to the degree required discloses such to clients • As regulated CASP Cryptonow maintains full decision-making independence with regard to its services | • Cryptonow and the Group • Clients |
| Preferential Treatment in Partnerships | Cryptonow may prioritize business partnerships or suppliers due to personal relationships or financial interests, rather than merit or Client benefit. Example: Selecting a technology provider due to a prior business connection rather than performance. | • All potential business partners undergo a comprehensive due diligence process which based on objective criteria scores the suitability of said firm • To the degree that relationships may exist, in line with internal policies, such are disclosed to the management | • Cryptonow • Client |
Risk category
Financial Interests and Personal Gains
Risks Identified
Employees, management, or shareholders have a direct or indirect financial interest in a crypto-asset, transaction, or business relationship that may influence their decision-making.
Example: An employee holds personal investments in a crypto-asset offered by Cryptonow, affecting impartiality.
Example: An employee holds personal investments in a crypto-asset offered by Cryptonow, affecting impartiality.
Measures and Controls
• Cryptonow offers its exchange services on an automated basis with practically no manual interference
• A comprehensive market surveillance system monitors trading activity to preserve integrity
• Cryptonow has specific rules and close monitoring of personal transactions of employees, management and shareholders of Cryptonow
• A comprehensive market surveillance system monitors trading activity to preserve integrity
• Cryptonow has specific rules and close monitoring of personal transactions of employees, management and shareholders of Cryptonow
Persons involved / nature of the conflict
• Employees, management, or shareholders
• Clients
• Clients
Risk category
Dual Roles and External Affiliations
Risks Identified
Employees or management hold positions or financial interests in external companies, partners, or competitors, leading to potential conflicts in decision-making.
Example: A management board member of Cryptonow is a shareholder in the company itself as well as in other companies.
Example: A management board member of Cryptonow is a shareholder in the company itself as well as in other companies.
Measures and Controls
• The management board of Cryptonow follows distributed decision-making rules ensuring that any potential conflict can not materialize
• Where and if necessary, the respective individual may be restricted in participating in certain decision processes
• Where and if necessary, the respective individual may be restricted in participating in certain decision processes
Persons involved / nature of the conflict
• Employees and management
Risk category
Client-Related Conflicts
Risks Identified
Business or personal relationships between Cryptonow employees and Clients that could lead to preferential treatment or biased service.
Example: A staff member prioritizes a Client’s interests due to personal connections, disadvantaging others.
Example: A staff member prioritizes a Client’s interests due to personal connections, disadvantaging others.
Measures and Controls
• Cryptonow charges fees based on transparent fee schedules taking into consideration objective criteria
• Services provided by Cryptonow are vastly automated, non-discriminatory and do not allow for biased service provisioning
• Services provided by Cryptonow are vastly automated, non-discriminatory and do not allow for biased service provisioning
Persons involved / nature of the conflict
• Employees and management
• Clients
• Clients
Risk category
Group-Level Conflicts
Risks Identified
Business interests within a broader Group structure that may impact Cryptonow’s decisions, potentially compromising Client interests.
Example: Cryptonow could refer Clients to affiliated entities without full disclosure.
Example: Cryptonow could refer Clients to affiliated entities without full disclosure.
Measures and Controls
• Cryptonow, in line with its internal policies, maintains full transparency with regards to group related interactions and to the degree required discloses such to clients
• As regulated CASP Cryptonow maintains full decision-making independence with regard to its services
• As regulated CASP Cryptonow maintains full decision-making independence with regard to its services
Persons involved / nature of the conflict
• Cryptonow and the Group
• Clients
• Clients
Risk category
Preferential Treatment in Partnerships
Risks Identified
Cryptonow may prioritize business partnerships or suppliers due to personal relationships or financial interests, rather than merit or Client benefit.
Example: Selecting a technology provider due to a prior business connection rather than performance.
Example: Selecting a technology provider due to a prior business connection rather than performance.
Measures and Controls
• All potential business partners undergo a comprehensive due diligence process which based on objective criteria scores the suitability of said firm
• To the degree that relationships may exist, in line with internal policies, such are disclosed to the management
• To the degree that relationships may exist, in line with internal policies, such are disclosed to the management
Persons involved / nature of the conflict
• Cryptonow
• Client
• Client