Order Execution 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).
SCOPE
Our execution policy applies to all clients of FalconX to whom the following services are provided:
- Execution of orders on behalf of clients; and
- Exchange of crypto-assets for funds or other crypto-assets.
The purpose of our policy is to explain how we obtain best execution when executing our clients orders, by taking all sufficient steps to obtain the best possible outcome when executing orders. The Policy also forms part of the User Agreement of FalconX Limited. The User Agreement constitutes a legally binding agreement between you, whether acting personally or on behalf of an entity and FalconX. By accepting the terms of the User Agreement, you also acknowledge and consent to the terms of our Execution Policy.
EXECUTION FACTORS
We ensure the prompt, fair and expeditious execution of your orders with all necessary controls to prevent the misuse of any information related to those orders.
When executing orders we prioritize and consider the following factors in determining the best possible outcome:
- Price and Cost - to ensure competitive pricing we consider the total cost of the transaction including any applicable costs..
- Speed - we consider the significance of completing the transaction quickly and whether speed is of equivalent importance to, or more important than, achieving the most efficient possible price.
- Likelihood of Execution and Settlement - we consider the possibility that an order is executed, and once executed, is successfully delivered.
- Size - we consider the size of the transaction. Large orders may have to be dealt with differently from smaller orders, particularly when large orders could have a potential impact on the market, and market price for the crypto-asset concerned.
- Nature - we consider the nature of the transaction and the type of market in which the crypto-assets/instruments are traded.
- Any other consideration which is relevant to the execution of the orders, which may include but are not limited to market conditions such as low liquidity and/or high volatility.
We may, in our absolute discretion and in light of available market information/conditions at the relevant time, decide that one or more of the Execution Factors listed above are more important, or not applicable at all, and act accordingly.
In certain instances, whether as a result of system failures, disrupted markets, or otherwise, it may be necessary to execute orders in a different manner than set out in the Policy. In such circumstances, we will seek to achieve the best possible result under the prevailing conditions.
Orders are executed at the available terms on the basis of the information available at the time. During times of high demand, delays in processing an order may impact the price and speed at which the order is executed. Furthermore, in the case of any communication or technical failure, as well as any incorrect reflection on the quoted feed, we reserve the right not to execute an order or change the opening and/or closing price of a particular order.
SPECIFIC CLIENT INSTRUCTIONS - WARNING
You may ask for orders to be executed in accordance with specific instructions, either on a standing basis, or on a case-by-case basis. In such instances, we accommodate any such requests, if and to the extent possible.
You should be aware that providing specific instructions may limit our ability to take the steps as described in our policy to achieve the best possible result in respect of the factors covered by those instructions. In such circumstances, we will be deemed to have satisfied our obligation to take all reasonable steps to obtain the best possible result, to the extent that we execute the order, or the relevant aspect of the order, in accordance with your instructions.
We execute orders in line with other comparable orders sequentially and promptly, unless the characteristics of the order or prevailing market conditions make this impracticable or your interests require otherwise. We have, among other things, in place effective systems,
procedures, and arrangements to reject or notify you of orders that exceed predetermined credit limits, price limits, volume limits or are clearly erroneous.
When exchanging crypto-assets for funds or other crypto-assets we execute your orders at the prices displayed at the time when the order for exchange is final. We inform you of the conditions for their order to be deemed final.
We obtain prior consent from each client regarding our execution policy. By signing the User Agreement, you are deemed to have provided such prior consent in respect of the services to be provided by us. If you make any reasonable and proportionate requests for information (including additional information about the policy), we shall answer clearly and within a reasonable time.
CLIENT ORDER HANDLING
At your request, we are able to demonstrate that we have executed your orders in accordance with our execution policy.
EXECUTION VENUES
Orders may be executed outside of a trading platform. The selection of a trading venue at the time of trade is influenced by a variety of dynamic factors, including asset availability, liquidity, market depth, settlement efficiency, transaction size limits, among others. These factors will subsequently guide the selection of the liquidity provider once you confirm your decision to proceed with execution.
We maintain, in our Execution Procedures, the updated list of trading venues for crypto-assets on which we rely on significantly to meet our obligations to take all necessary steps to obtain the best possible results for the execution of your orders.
We will not receive any remuneration, discount, or non-monetary benefit for directing your orders to a specific trading or execution venue, as doing so would violate the requirements regarding conflicts of interest or inducements. Furthermore, we shall not structure or charge commissions in such a way as to discriminate unfairly between execution/trading venues or exchanges.
All applicable quote and trading information is available to you for download over both the UI as well as the API.
CONFLICTS OF INTEREST
We have established and maintained a Conflicts of Interest Policy to identify, prevent, manage, and disclose any conflicts of interest. We ensure that your interests always take precedence in the order execution processes. You can access further information on our Conflicts of Interest Policy [here].
MONITORING AND REVIEW
We, through the Head of Markets and the General Manager, monitor the effectiveness of our Execution Arrangements in order to identify and, where appropriate, correct any deficiencies in that respect. In particular, we assess, on a regular basis, whether the execution venues included in the Execution Procedures provide for the best possible result for you or whether there is a need to make changes in the Execution Arrangements.
NOTIFICATION OF CHANGES
Our execution policy may be amended from time to time to reflect changes in regulatory requirements, market conditions, or our operational strategies. Where such changes are of a material nature affecting the order execution arrangements we will notify you accordingly as well as request you confirm your understanding and consent.
RECORD KEEPING
We maintain comprehensive records of all executed and transmitted orders, including details of the execution factors considered. These records are retained for five (5) years, in accordance with applicable legal and regulatory requirements.