SUMMARY OF THE EXECUTION POLICY
This is a summary of Coinmotion's Execution Policy, which ensures the best possible result for their customers when providing execution of orders for crypto-assets in accordance with the EU Regulation on Markets in Crypto-Assets (MiCA). The purpose of this summary is to provide customers with easily understandable information on the appropriate and clear information on how customers’ orders are going to be executed by Coinmotion.
1. BEST EXECUTION OBLIGATION
Coinmotion provides OTC Service which involves execution of orders for crypto-assets on behalf of customers. In the OTC Service, Coinmotion is obligated to execute all orders by taking all necessary steps to obtain the best possible result for the customers.
At the request of the customer, Coinmotion will always demonstrate that Coinmotion has executed customer’s orders in accordance with Coinmotion's execution policy.
However, Coinmotion shall not be required to take the necessary steps as referred above, where Coinmotion executes customer orders for crypto-assets following specific instructions given by the customer.
2. ARRANGEMENTS FOR EFFECTIVE EXECUTION OF ORDERS
To achieve the best possible outcome for the customer, Coinmotion has (i) implemented execution arrangements; and (ii) conducts a case-by-case analysis of certain factors, prioritizing them based on the specific circumstances of each order.
(i) Execution arrangements:
● Execution Policy
○ Coinmotion has established an execution policy to ensure that all orders are executed effectively and in accordance with its standards
● Multi-Venue Trading
○ Coinmotion prioritizes multi-venue trading and uses multiple counterparties, based on factors like liquidity, pricing, and execution speed, to enhance execution quality, find the best prices, and reduce slippage, particularly for large orders
● Major CASPs
○ When the Multi-Venue Trading is not feasible, Coinmotion uses major CASPs as counterparties
● Cold Storage of Crypto-Assets
○ Until the execution of the order, Coinmotion will store crypto-assets in cold storage, enhancing security and protecting customers assets from potential cyber threats. In cases where immediate access is required for trading (by the customer), or when access to cold storage is not available or reasonable, CASP hot wallets or exchanges may be used as a last resort.
(ii) Factors used in case-by-case analysis:
● Price
● Costs
● Speed of Execution
● Execution and Settlement
● Order Size and Nature
● Custody Conditions for Crypto-Assets
● Client-Specific Instructions
● Additional Considerations (e.g. characteristics of the trading venue, market volatility, potential conflicts of interest, and any applicable legal or regulatory constraints)
3. EXECUTION OF ORDERS OUTSIDE OF THE COMPANY’S SYSTEMS
Due to the service model of Coinmotion’s OTC Service, Coinmotion has the possibility to execute customer orders outside a trading platform and its own systems (i.e. ‘over-the-counter’).
Coinmotion is required to, and has, obtained the customer’s prior explicit consent for executing their orders over-the-counter by informing them of this possibility and securing their express consent in the additional contract terms of the OTC Service (“OTC Terms”).
4. PREVENTION OF MISUSE BY THE COMPANY’S EMPLOYEES
Coinmotion has taken necessary steps to prevent the misuse by the Coinmotion’s employees of any information relating to customers orders, by taking following steps:
● Confidentiality
○ All Coinmotion’s employees handling customer order information have signed non-disclosure agreements, which require them to maintain strict confidentiality and prohibit the use of this information for personal gain or any unauthorized purposes
● Limited access
○ Coinmotion has implemented robust access controls to ensure that only authorized personnel have access to customer order information
● Training and awareness
○ Coinmotion provides regular training to all relevant employees on the importance of confidentiality and the specific protocols for handling customer order information
● Monitoring
○ Coinmotion continuously monitors employee access to and use of customer order information, conducts regular audits to detect any unauthorized access or misuse, and takes appropriate disciplinary action if any suspicious activity is identified
● Reporting
○ Coinmotion encourages employees to report any suspected misuse of customer order information through its whistleblowing channels
5. ACCOUNTABILITY OF THE EXECUTION POLICY
To ensure accountability for the execution policy, Coinmotion has implemented robust record-keeping and monitoring procedures, which include following measures:
● Record-keeping
○ Coinmotion maintains comprehensive records of all customer orders executed
● Audit trails
○ Coinmotion has established audit trails that allow for the tracking of the entire execution process
● Retention period
○ Coinmotion retains the record of the executed orders for at least five (5) years from the fulfillment of the order
● Monitoring
○ Coinmotion is monitoring and assessing the effectiveness of its order execution arrangements and execution policy (see section 6. below)
6. MONITORING EXECUTION ARRANGEMENTS AND NOTIFYING OF POSSIBLE CHANGES
Coinmotion is obligated to monitor the effectiveness of its order execution arrangements and execution policy. Hence, Coinmotion is assessing on a regular basis, whether the execution venues included in the execution policy provide for the best possible result for customers.
If any ineffectiveness is identified, Coinmotion shall make changes to their order execution arrangements and update the execution policy. In such a situation, Coinmotion will notify customers of any material changes to execution policy.
7. QUESTIONS?
Do you have questions about the execution of orders for your crypto-assets?
Please contact [email protected]
