OEX

Activity Specific Disclosures

WEB3EXCHANGE PUBLIC DISCLOSURE STATEMENT

Virtual Asset Exchange Services and Broker-Dealer Services

(Prepared in accordance with Dubai Virtual Assets Regulatory Authority (VARA) Rulebooks and Public Disclosure Requirements)

WEB3EX is committed to maintaining transparency, fair client treatment, and compliance with all applicable requirements issued by the Dubai Virtual Assets Regulatory Authority (“VARA”). The following disclosures are published to ensure clients have access to clear and accurate information regarding our licensed activities, business practices, risk framework, and client protections.

GENERAL DISCLOSURES

1. VARA Licence Information

WEB3EX has applied for authorisation from the Dubai Virtual Assets Regulatory Authority to conduct regulated Virtual Asset activities in the Emirate of Dubai.

The following information will be updated immediately upon licence issuance:

  • VARA Licence Number: To be updated upon issuance
  • Licence Effective Date: To be updated upon issuance
  • Licence Validity Period: To be updated upon issuance

2. Licensed Activities

Upon approval by VARA, WEB3EX will be authorised to conduct the following regulated Virtual Asset activities:

  • Virtual Asset Exchange Services
  • Virtual Asset Broker-Dealer Services

WEB3EX will only conduct activities expressly authorised under its VARA licence and in accordance with applicable restrictions, conditions, and operating parameters imposed by VARA.

3. Responsible Individuals

WEB3EX has appointed 2 Responsible Individuals and Approved Persons responsible for governance, compliance oversight, risk management, finance, operations, and senior management functions in accordance with VARA requirements.

The following roles are maintained within WEB3EX’s governance framework:

  • Chief Executive Officer - to be appointed
  • Compliance Officer / MLRO – to be appointed

Names and official appointments will be updated, if needed, upon final regulatory approval and onboarding completion.

4. Risk Disclosure, Terms and Client Documentation

WEB3EX makes the following documents publicly available to clients prior to onboarding and go-live:

A. Data Privacy

WebExchange applies strict privacy and data protection controls in line with the UAE PDPL and VARA Rulebooks.

  • Personal data is collected only for lawful and regulatory purposes.
  • AML/KYC data is retained for at least 8 years in line with VARA Rulebooks.
  • Cross-border transfers are subject to PDPL safeguards.
  • Breaches are reported promptly to the UAE Data Office and VARA.

Refer to WebExchange Privacy Policy for further details.

B. Complaints Handling Policy

WebExchange is committed to addressing complaints in alignment with industry standards and regulatory guidelines, with the goal of maintaining client trust and satisfaction.

  • All complaints will be acknowledged within one week of the complaint being made.
  • WEB3EX will make every effort to resolve complaints within four weeks of receiving them. However, in exceptional circumstances where resolution may take longer, the Company will notify the client of the delay, providing an explanation of the extraordinary circumstances preventing timely resolution.
  • WEB3EX will ensure that the complaint is resolved no later than eight weeks from when the complaint was originally made.

Refer to WebExchange Complaints Handling Policy for further details.

C. Conflict of Interest Policy

Web3Xechange operates effective organisational and administrative arrangements to identify, monitor, and manage conflicts of interest.

  • Conflicts are reviewed by the Board Risk & Compliance Committee.
  • Material conflicts are disclosed to clients prior to engagement.
  • Notifications are made to VARA where required.

Refer to Web3XechangeConflicts of Interest Policy for further details.

D. Whistleblowing Policy

Web3Exchange maintains a whistleblowing framework to ensure concerns may be raised in confidence and without fear of retaliation.

  • Whistleblowers are protected from dismissal or liability.
  • Reports may include concerns regarding market conduct, AML/CFT, or misuse of assets.
  • Relevant disclosures may be escalated to VARA or regulators where necessary.

Refer to WebExchange Whistleblowing Policy for further details.

E. AML/CFT and Sanctions Compliance Statement

The AML/CFT Policy sets forth the principles, procedures, and control mechanisms designed to mitigate the risks associated with money laundering, terrorist financing, sanctions breaches, and other illicit financial activities.

This document establishes a comprehensive compliance framework intended to safeguard the integrity of WEB3EX’s operations, ensure compliance with applicable laws, regulations, and regulatory expectations, and uphold the highest standards of ethical and professional conduct.

The Policy further outlines WEB3EX’s approach to risk-based customer onboarding and ongoing monitoring measures, including Know Your Customer (“KYC”), Customer Due Diligence (“CDD”), Enhanced Due Diligence (“EDD”), sanctions screening, transaction monitoring, suspicious activity identification and reporting, FATF Travel Rule compliance, record-keeping obligations, and governance and escalation procedures. WEB3EX is committed to implementing robust internal controls, maintaining effective AML/CFT systems and oversight mechanisms, promoting a strong culture of compliance across the organisation, and cooperating fully with relevant regulatory and competent authorities in the prevention and detection of financial crime.

Refer to WebExchange AML/CFT Policy for further details.

F. Anti-Bribery and Corruption Policy

WEB3EX upholds a zero-tolerance approach to bribery and corruption, as outlined in this anti-bribery and corruption policy. This stance is disclosed publicly and communicated clearly at the initiation of all business relationships, aligning with relevant requirements in the VARA Market Conduct Rulebook. This transparent approach reinforces the company’s commitment to ethical practices while fostering trust with clients, partners, and other stakeholders.

By embedding robust training and awareness initiatives into its operations, WEB3EX ensures that all personnel are well-informed and actively contribute to maintaining a culture of integrity and compliance.

Refer to WebExchange Anti-Bribery and Corruption Policy for further details.

G. VA Standards

WEB3EX takes all reasonable steps, including conducting thorough due diligence, to ensure that all Virtual Assets associated with its activities comply with these established VA Standards. The Company is committed to maintaining the highest level of oversight and ensuring that any Virtual Assets involved in VA Activities meet the required security, regulatory, and operational standards. Furthermore, WEB3EX transparently discloses its VA Standards on its official website, providing clients, stakeholders, and regulators with access to the Company's practices and criteria, promoting accountability, transparency, and trust in all of its operations.

Refer to WebExchange VA Standards Policy for further details.

VA EXCHANGE SERVICES DISCLOSURES

WEB3EX is licensed by Virtual Assets Regulatory Authority to provide VA Exchange Services.

At present, WEB3EX has not yet admitted any Virtual Assets for live trading. Prior to the admission of any Virtual Asset to the platform, WEB3EX will publish and maintain asset-specific disclosures on its website and client platform for each admitted asset.

For each listed Virtual Asset, WEB3EX will disclose, where applicable:

  • 1) Virtual Asset name, symbol/ticker, protocol/network, and issuance details;
  • 2) Description of the asset, intended use case, and relevant functionalities;
  • 3) Circulating supply, total supply, market capitalization, and fully diluted valuation sourced from reputable market data providers;
  • 4) Historical price performance, including largest historical price decline (absolute and percentage basis);
  • 5) Confirmation of independent smart contract, protocol, or security audits where applicable;
  • 6) Material technology, governance, cybersecurity, liquidity, concentration, and operational risks associated with the asset;
  • 7) Supported blockchain networks and transfer standards.

Pricing Methodology Applied on Exchange Venue

Prices displayed and executed on the WEB3EX Exchange platform are determined using aggregated market data, executable liquidity, and pricing feeds obtained from approved third-party liquidity providers and recognised trading venues.

Pricing is subject to:

  • prevailing market conditions;
  • liquidity availability;
  • spread considerations;
  • execution timing and order book conditions.

WEB3EX applies internal pricing governance controls, monitoring, and exception review procedures to support fair and orderly pricing and does not arbitrarily manipulate client pricing outside approved pricing methodologies.

Client Asset Protection and Safeguarding Arrangements

WEB3EX does not treat client assets as proprietary assets and maintains operational arrangements to ensure segregation and safeguarding of client fiat and virtual assets.

Client virtual assets deposited to the platform are initially received through dedicated client deposit wallet addresses and subsequently transferred into pooled omnibus cold wallet custody arrangements maintained exclusively by WEB3EX’s appointed VARA-regulated custodian, Hex Trust.

Client fiat funds are maintained in segregated Client Money accounts with appointed banking partners and remain operationally separated from WEB3EX corporate funds.

Client assets are subject to:

WEB3EX has no unilateral authority to move client virtual assets outside approved governance and custodian control frameworks.

Client ownership rights over Virtual Assets and fiat balances are maintained in accordance with contractual arrangements, custody structures, and applicable regulatory requirements.

Conflicts of Interest

WEB3EX maintains a Conflict of Interest framework designed to identify, manage, mitigate, monitor, and disclose actual or potential conflicts that may arise between:

  • WEB3EX and its clients;
  • employees and clients;
  • different groups of clients;
  • liquidity providers, listing counterparties, and clients.

Potential conflicts may arise in relation to:

  • order execution and routing decisions;
  • fee or commercial arrangements with liquidity providers or service providers;
  • admission or delisting decisions for Virtual Assets;
  • referral or commercial arrangements with third parties.

Mitigation measures include:

  • segregation of duties across business, operations, and compliance functions;
  • compliance oversight and escalation procedures;
  • approval governance for asset admission and third-party onboarding;
  • periodic conflict reviews and disclosures where required.

Third-Party Operational Arrangements

WEB3EX currently relies on approved third-party service providers for operational support functions, including:

  • custody and wallet infrastructure;
  • blockchain analytics and transaction monitoring;
  • KYC/AML verification services;
  • banking and payment infrastructure;
  • liquidity provision and pricing support;
  • technology infrastructure and security services.

WEB3EX conducts due diligence, onboarding reviews, contractual assessment, and ongoing monitoring of all material third-party providers.

Where client assets, operational dependencies, or critical services rely on third parties, such arrangements are subject to contractual safeguards, oversight controls, contingency planning, and ongoing monitoring.

Referral and Introduction Arrangements

Where WEB3EX enters into referral or introduction arrangements, relevant fees, commissions, rebates, or commercial benefits associated with such arrangements will be disclosed to clients where applicable.

VA Broker-Dealer Activity Services

Virtual Asset Information and Trading Arrangements

For each Virtual Asset admitted for trading under WEB3EX’s VA Broker-Dealer Services, WEB3EX will publish and maintain asset-specific disclosures on its website and client platform, including relevant operational, risk, and market information.

Client assets are held by WEB3EX strictly on behalf of clients and for their sole benefit. Legal and beneficial ownership of client virtual assets remains with the client at all times. Client assets do not constitute the property of WEB3EX, are not recognised as assets of the Company, and do not form part of the Company’s balance sheet or proprietary estate. For each listed Virtual Asset, WEB3EX will disclose, where applicable:

  • Virtual Asset name, ticker/symbol, protocol/network, and issuance date;
  • Description of the Virtual Asset, intended use case, and key functionalities;
  • Circulating supply, total supply, and market capitalization data sourced from reputable market data providers;
  • Historical price performance, including material volatility metrics and largest historical drawdown (absolute and percentage basis);
  • Material technology, protocol, governance, concentration, liquidity, or cybersecurity risks associated with the asset;
  • Confirmation of whether the Virtual Asset has undergone independent smart contract or protocol security audits, where applicable;
  • Blockchain network and supported transfer standards.

Pricing Methodology

WEB3EX obtains executable price quotations from approved liquidity providers and market sources. Pricing displayed to clients is determined based on aggregated market pricing, available liquidity, spread considerations, and applicable execution parameters.

Order Routing and Execution

Client orders submitted under Broker-Dealer Services are routed by WEB3EX to approved liquidity providers for execution. WEB3EX monitors routing arrangements to ensure fair execution outcomes. Where 20% or more of routed orders are directed to a single liquidity provider, this concentration will be disclosed accordingly.

Liquidity providers act solely for pricing and trade execution purposes and do not hold, control, or access client assets, client wallets, or custody infrastructure at any stage.

Order Execution Standards and Client Interests

WEB3EX prioritizes the accurate and efficient execution of all client orders to buy or sell Virtual Assets. The Company adopts a systematic approach to order execution, focusing on delivering the best possible results for its clients based on prevailing market conditions.

To fulfill this commitment, WEB3EX considers a range of factors during the execution of client orders, including but not limited to:

  • 1. The prevailing market price and its impact on achieving the best possible price for the client.
  • 2. Associated costs, ensuring that transaction expenses are minimized where feasible.
  • 3. The speed of execution, particularly in fast-moving markets.
  • 4. The likelihood of execution and settlement to ensure reliability and reduce potential delays.
  • 5. The size and nature of the order, tailoring execution strategies to accommodate specific client needs.
  • 6. Other relevant considerations that may influence the successful and optimal execution of the client’s order.

Execution

WEB3EX conducts detailed pre-trade assessments to identify execution venues or counterparties that offer the most favorable conditions for trade execution. These assessments take into account factors such as market liquidity, price consistency, and reliability of the counterparty to ensure optimal trading conditions.

The execution process is continuously monitored and documented to ensure adherence to best execution standards. This includes tracking each order from initiation to settlement, verifying that the execution strategy aligns with the most favorable price, and assessing the timeliness and costs associated with the transaction.

Regular reviews and audits of the execution process ensure ongoing compliance with the best execution policy.

Order Routing Controls

The Company will implement controls to ensure that client orders are routed through venues or systems designed to achieve the best possible outcome. These controls include:

  • Assessing and maintaining a list of approved trading venues based on reliability, liquidity, and pricing transparency.
  • Periodic reviews of the routing systems and algorithms to ensure they are calibrated to optimize execution quality.

Client Asset Protection and Custody Arrangements

WEB3EX does not hold client fiat or virtual assets as principal assets.

Client fiat funds are maintained in segregated Client Money accounts with appointed banking partners. Client virtual assets are safeguarded through dedicated deposit wallet structures and subsequently maintained in omnibus cold wallet custody arrangements with VARA-regulated custodians.

WEB3EX currently utilizes only VARA-regulated custodians, including Hex Trust, for custody and safeguarding of client virtual assets.

Client assets are operationally segregated from WEB3EX corporate assets and subject to reconciliation controls, ledger monitoring, and safeguarding oversight.

Conflict of Interest Management

To prevent and mitigate conflicts of interest, WEB3EX has established written policies that identify and address conflicts between competing client orders or between client orders and the interests of the Company. A compliance monitoring system is in place to oversee potential conflicts and ensure that order handling does not unduly favor any party.

Monitoring and Evaluation

WEB3EX will deploy a robust monitoring framework to evaluate execution quality and compliance with best execution standards, including:

  • Regular post-trade reviews to assess whether executed orders met the best possible outcome under the prevailing conditions.
  • Periodic testing of order execution systems to ensure accuracy and reliability.
  • Benchmarking performance against market standards to identify potential improvements.

Clearing and Settlement

WEB3EX does not provide clearing services to other Virtual Asset Service Providers and does not permit third parties to access or utilize client assets.

Settlement is reflected through WEB3EX internal ledger infrastructure and corresponding custody/accounting reconciliations.

Referral and Introduction Arrangements

Where WEB3EX engages in referral or introduction arrangements, the nature of such arrangements, including applicable fees, commissions, rebates, or other benefits, will be clearly disclosed to clients prior to onboarding or transaction activity.

Third-Party Dependencies

WEB3EX relies on approved third-party service providers for custody, banking, liquidity, and infrastructure support. Relevant third-party operational dependencies are subject to due diligence, contractual controls, ongoing oversight, and contingency arrangements.

OTHER DISCLOSURES

Regulatory and Legal Matters

As of publication date:

  • WEB3EX confirms whether any material regulatory actions, criminal prosecutions, or relevant convictions involving senior management, board members, or key personnel exist, where disclosure is legally required.

If any such matters arise requiring disclosure under applicable regulations, WEB3EX will update this disclosure accordingly.

Additional Information

Custody Partner: Hex Trust, a custody provider regulated by the Dubai Virtual Assets Regulatory Authority (VARA).

Banking Partner: Zand Bank, a financial institution licensed by the UAE Central Bank.

Referral Arrangements: Any monetary or non-monetary benefits arising from referral arrangements are fully disclosed to clients in accordance with applicable regulatory requirements.

Governance & Fit and Proper Standards: The Board of Directors and Senior Management of Web3Exchange have confirmed that they have no history of criminal convictions, regulatory sanctions, or ongoing prosecutions in the UAE or any other jurisdiction.

Market Conduct Compliance: WEB3EXmaintains strict controls to prohibit insider trading, market manipulation, and any abusive or misleading practices, in full compliance with VARA’s Market Conduct Rulebook.

Contact Us

For more information, please email: info@web3exchange.com