Conflict of Interest

Introduction

Digital Currency Services B.V. (“DCS”) provides crypto-asset services, including custody and administration of crypto-assets, exchange of crypto-assets for funds, and transfer services. In the course of these activities, conflicts of interest may arise.

A conflict of interest is a situation in which the interests of DCS, its shareholders, board members, employees, affiliated entities, or other connected persons may conflict, or appear to conflict, with the interests of a customer or with the proper and independent performance of our duties.

DCS takes reasonable steps to identify, prevent, manage, monitor and, where necessary, disclose conflicts of interest.

Situations in which conflicts of interest may arise

Conflicts of interest may arise in a variety of situations, including but not limited to the following:

  • DCS or a connected person could benefit financially, avoid a loss, or obtain another advantage at the expense of a customer.
  • DCS or a connected person may have an interest in the outcome of a service or transaction that differs from the customer’s interest.
  • DCS or a connected person may have an incentive to favour one customer over another.
  • Employees, board members or other connected persons may have personal, professional or financial interests in a customer, supplier, business partner or affiliated entity.
  • Conflicts may arise from remuneration structures, business targets or commercial arrangements.
  • Conflicts may arise from personal transactions in crypto-assets by connected persons.
  • Conflicts may arise within the group structure, including through shared resources, overlapping roles or relationships with affiliated entities.
  • Conflicts may also arise between two or more customers whose interests are not aligned.

Main categories of potential conflicts

Based on our business model and internal assessment, the main categories of potential conflicts include:

1. Remuneration and commercial incentives

A conflict may arise if employees or decision-makers would be incentivised to promote certain products, services or customer outcomes for commercial reasons rather than acting fairly and professionally in the interests of customers.

2. Relationships with business partners and third parties

Conflicts may arise where DCS works with business partners, suppliers or service providers whose interests are not fully aligned with those of DCS or its customers.

3. Group and affiliated-entity relationships

DCS is part of a group structure and has operational links with affiliated entities. Conflicts may arise where shared employees, overlapping board memberships, shared office space, shared technology, or affiliated products and services could influence decision-making.

4. Internal governance and connected persons

Conflicts may arise where board members, employees or other connected persons have outside roles, financial interests, family relationships, or other connections that may affect their independence or objectivity.

5. Personal transactions

Employees, board members and other connected persons may hold or trade crypto-assets personally. This may create conflicts where such persons are involved in DCS’s services or have access to confidential or non-public information.

How we prevent and manage conflicts of interest

To prevent and manage conflicts of interest, DCS has implemented a range of controls, including where relevant:

  • disclosure obligations for employees, board members and other connected persons;
  • internal review and escalation procedures for identified conflicts;
  • segregation of duties, functions and reporting lines;
  • restrictions on decision-making where a personal or affiliated interest exists;
  • information barriers, access controls and confidentiality requirements;
  • governance measures for related-party and intra-group situations;
  • review of remuneration structures and incentive arrangements;
  • scrutiny and monitoring of personal transactions;
  • independent compliance oversight and periodic reviews;
  • maintenance of a Conflicts of Interest Register.

Personal transactions

DCS has rules for personal transactions in crypto-assets by connected persons. These transactions are subject to notification, review and monitoring where a conflict of interest may arise.

Connected persons must not misuse confidential information or non-public information. Personal transactions that could create a conflict, involve related parties, or raise market abuse concerns are subject to enhanced scrutiny and, where necessary, restriction or escalation.

Monitoring and disclosure

DCS continuously monitors the effectiveness of its conflicts of interest framework. Identified conflicts and the measures taken are recorded in the Conflicts of Interest Register and reviewed periodically.

Where the measures taken are not sufficient to prevent a risk of harm to a customer, DCS will disclose the relevant conflict of interest to the customer concerned before providing the relevant service.

This webpage provides a summary of the general nature and sources of conflicts of interest and the steps taken to mitigate them. Customer-specific conflicts, or conflicts outside the categories described above, may be disclosed separately where required.