Conflicts of Interest Policy

INTRODUCTION

FalconX Limited (hereinafter, "Company", “we”, “us”, “our” or “FalconX”), incorporated in Malta with company registration number C 88950, is authorised as a Crypto-Asset Services Provider by the Malta Financial Services Authority (MFSA) pursuant to Regulation 2023/1114 on Markets in Crypto-Assets as implemented in Malta by the Markets in Crypto Assets Act (Chapter 647 of the Laws of Malta).

FalconX is also licensed as a Financial Institution by the MFSA pursuant to the Financial Institutions Act (Chapter 376, Laws of Malta) to provide payment services exclusively in relation to electronic money tokens (EMTs).

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SCOPE

We are required to disclose the general nature and sources of conflicts of interest, and any steps taken to mitigate them, to enable our clients (hereinafter, “you” or “your”), to take an informed decision in the context of which a conflict of interest may arise.

Conflicts of interest arise when personal, financial, or other interests of FalconX, the Company, our employees, affiliated entities, or any related parties which could influence, or appear to influence, our ability to act objectively and in your best interests.

When actual or potential conflicts are identified, we manage them effectively and fairly to ensure that your interests are not materially affected.

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GENERAL SOURCES OF CONFLICTS OF INTEREST

Potential conflicts of interest include situations where FalconX Limited or its affiliates within the FalconX Group - including shareholders, directors, or entities linked by control - provide overlapping crypto-asset services, engage in proprietary trading, or maintain commercial arrangements that could influence the execution of your orders or the selection of liquidity venues. These conflicts are identified and managed through the Company’s Conflicts of Interest policy designed to ensure that the interests of the client are prioritized over any intragroup financial or operational incentives.

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SITUATIONS OF CONFLICT OF INTEREST

Conflicts of interest may, amongst others, arise in situations where the personal interests of an individual or organization could potentially conflict with our obligation to act in your best interest. For example when:

  • there is a conflict between our interests and/ or Connected Person and yourself;
  • there is a conflict between ourselves and our shareholders or members by control;
  • there is a conflict of interest between ourselves
  • there is a conflict between the performance of services and activities and the duty we owe to your; or
  • the differing interests of two or more of our clients, to whom we owe in each case a duty.

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IDENTIFYING CONFLICTS OF INTEREST

In identifying potential conflicts of interest that may arise while providing crypto-asset services that could adversely affect your interests, FalconX considers whether we or any related party in the following situations:

  • Could make a financial gain or avoid a financial loss, or receive any other benefit at your expense;
  • Has an interest in the outcome of a crypto-asset service provided to you, or a transaction executed on your behalf, that differs from your own interests in the outcome;
  • Has a financial or other incentive to favour the interests of another client over yours; Carries on the same business as yourself;
  • Receives, or is likely to receive, an inducement in relation to services provided to you, whether these are monetary or non-monetary benefits.

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MANAGING CONFLICTS OF INTEREST

We take all reasonable steps to prevent conflicts of interest from adversely affecting your interests.

We consider all situations which may influence or affect, or which may appear to influence or affect, our ability or the ability of any person connected to us to exercise their duties or responsibilities owed to you objectively and independently.

In order to avoid any personal conflicts, we prevent the improper use of privileged or confidential information concerning our clients through controls and procedures intended to regulate and, where appropriate, prohibit the flow of information between persons engaged in activities that may involve risk of conflict of interest.

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PERSONAL TRANSACTIONS

We have in place arrangements ensuring that employees and/or connected persons do not enter into personal transactions which meet any of the following criteria:

  • transactions which are not inline with the our market abuse and personal transactions policies and procedures;
  • transactions which involve the misuse or improper disclosure of confidential information; and
  • transactions which conflict or are likely to conflict with an obligation of our regulatory obligations.

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REMUNERATION

A potential conflict of interest may arise between you and FalconX concerning employee remuneration. To address this, we have established a Remuneration Policy applicable to all identified staff. This Policy is designed to ensure that the Company’s remuneration practices and arrangements do not create conflicts of interest or incentives that could lead our employees to prioritize their own interests, or the Company’s interests, over your interests.

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ORDER EXECUTION

We and/ or connected persons shall not receive any remuneration, discount or non-monetary benefit for routing your orders to a particular trading venue or execution venue which would infringe the requirements on conflicts of interest or inducements. We must always act in your best interest. You may access our Order Execution Policy [here] for further information.

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REVIEW OF DISCLOSURE

We regularly review our Conflicts of Interest Policy to ensure it accurately reflects any potential or actual conflicts that may affect you. Updates may occur due to changes in our business activities, corporate structure, services offered, or regulatory requirements.

Whenever significant changes arise, we will update this page promptly to maintain transparency. We encourage you to review this disclosure periodically to stay informed of any developments that could influence the services we provide.