Broker-Dealer Disclosure
Note:
“PRYPCO Mint” is hereby referred to as “PRYPCO FZE”
Disclosure 1
Conflicts of interest can arise in various business and personal contexts. Proactively managing these conflicts is essential to mitigate legal and regulatory risks while upholding our integrity, brand, and reputation. Conflicts of interest can be managed effectively by:
Understanding what constitutes a conflict of interest; if you have questions, please consult with your manager or the People and Compliance team.
Acting with integrity in all business activities.
Considering potential conflicts of interest in all aspects of your work.
Avoiding any activities, situations, or relationships that could compromise—or appear to compromise—your professional judgment.
Seeking approval before engaging in any outside business, financial, or personal relationships that may pose a risk of conflict.
To help identify actual, perceived, or potential conflicts of interest, consider the following questions:
Could I gain personal benefits, now or in the future, that might influence my objectivity?
Do I hold any personal or professional views that could lead others to reasonably question my impartiality on a specific matter?
Have I received a gift, benefit, or hospitality from someone who could be affected by my decisions?
Is there a significant personal, professional, or financial relationship involved?
Would I, or someone close to me, gain or suffer as a result of my decision or action?
Could the company’s reputation be positively or negatively impacted by my decision or action?
Proactively considering these questions helps ensure transparency and ethical decision-making across all aspects of our business.
Disclosure 2
PRYPCO FZE determines the price of Virtual Assets quoted to clients as follows:
Asset-Referenced Virtual Asset (ARVA)Tokens
For ARVA tokens representing fractional ownership of Dubai real estate, prices are derived from the DLD Smart Valuation Index or an independent valuation report. These valuations are conducted at least every six months and form the basis for the token price displayed on the platform.
Commodity-Backed Virtual Assets including Paxos Gold (PAXG)
Prices for PAXG are determined by reference to the prevailing mid-market price obtained from PRYPCO FZE’s liquidity counterparty, Payward Trading Ltd (BVI) trading as Kraken Prime, at the time the quote is generated.
A spread is applied to the mid-market reference price to arrive at the final client facing quote. The spread may be adjusted based on prevailing market liquidity conditions. The spread is embedded in the quoted price and is not separately itemised; however, the total price payable by the client is displayed and confirmed prior to execution.
No additional mark-ups, fees, or charges are applied to the quoted price after it is presented to the client.
Disclosure 3
PRYPCO FZE does not hold or maintain funds or Virtual Assets, nor does it provide clearing services for other Virtual Asset Service Providers (VASPs) offering Broker-Dealer services. PRYPCO FZE’s services are focused solely on providing Real World Assets (RWA) fractional ownership access to its customers and do not include custodial or clearing functions for other VASPs.
Disclosure 4
PRYPCO FZE has implemented the following legal and operational arrangements to protect clients’ ownership rights in respect of assets held on the platform:
ARVA Tokens
ARVA tokens are issued by Ctrl Alt Solutions DMCC, acting as tokenisation and custody infrastructure provider. Each ARVA token is backed by a fractional interest in a Dubai real estate asset registered with the Dubai Land Department (DLD). Clients’ ownership of ARVA tokens and the corresponding real estate interests is recorded on the DLD register, which constitutes the primary legal record of title.
Commodity-Backed Virtual Assets - Paxos Gold (PAXG)
PAXG tokens held in connection with client positions are maintained in an omnibus account with Payward Trading Ltd (BVI), trading as Kraken Prime, held in the name of PRYPCO FZE. This omnibus account is segregated from PRYPCO FZE’s own proprietary assets, ensuring that client assets are not commingled with PRYPCO FZE’s assets. Clients’ beneficial ownership of their respective positions within the omnibus account is recorded in PRYPCO FZE’s internal books and records.
Fiat Funds
Client fiat funds are held in a designated client money account, maintained separately from PRYPCO FZE’s own operating funds. This arrangement ensures that client money is protected in the event of any financial difficulty affecting PRYPCO FZE.
Disclosure 5
PRYPCO FZE may refer or introduce clients to select entities, including other Virtual Asset Service Providers (VASPs), when specific client needs align with services provided by these entities. Such referrals are made transparently, with clients fully informed of the nature and purpose of the introduction. PRYPCO FZE may receive monetary or non-monetary benefits as part of these arrangements, including reciprocation for business referrals, which are disclosed to clients in alignment with regulatory requirements.
PRYPCO FZE routes client orders in certain Virtual Assets to external liquidity sources. All client orders in PAX Gold (PAXG) are routed to Payward Trading Ltd (BVI), trading as Kraken Prime, which acts as PRYPCO FZE’s sole liquidity and custody counterparty for that asset. This represents 100% of order flow for PAXG. PRYPCO FZE does not receive payment for order flow or any equivalent arrangement from Kraken Prime.
PRYPCO FZE maintains client accounts, funds and Virtual Assets with the following third parties:
Ctrl Alt Solutions DMCC - tokenisation and custody infrastructure provider for ARVA tokens representing fractional interests in Dubai real estate assets.
Payward Trading Ltd (BVI), trading as Kraken Prime - liquidity and custody counterparty for Paxos Gold (PAXG). PAXG tokens held in connection with client positions are maintained in an omnibus account in the name of PRYPCO FZE, segregated from PRYPCO FZE’s proprietary assets.
Zand Bank - client fiat funds are held in a designated client money account, maintained separately from PRYPCO FZE’s own operating funds.
Clients’ beneficial ownership of their respective positions is unaffected by these arrangements. Further details of PRYPCO FZE’s third-party service providers are available at prypco.com/mint/third-party-providers.
