Legal and Regulatory Disclosures

Entity Information

The following information will be reflected on the website here:

https://www.bitgo.com/legal/legal-regulatory

BitGo MENA FZE

BitGo MENA FZE is a Free Zone Establishment with its registered office at Unit 108, Level 1, The Offices 4 – One Central, Dubai World Trade Centre.

Registration Number: L-3375, Free Zone Entity (FZE), providing Broker-Dealer Services, regulated by VARA under license number VL/25/09/001.

The responsible individuals for this entity are: Benjamin Choy, Karam Albsharat.

Disclosures/Disclaimers

The following information will be reflected on the website here: https://www.bitgo.com/legal/disclaimers

For customers located in the UAE, please note the following disclosures associated with virtual asset:

(1) Virtual assets not legal tender, is not backed by the government, and accounts and value balances are not subject to any investor protections; (2) Legislative and regulatory changes or actions may adversely affect the use, transfer, exchange, and value of virtual assets; (3) Transactions in virtual assets may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable; (4) Some virtual asset transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that the customer initiates the transaction; (5) The value of virtual asset may be derived from the continued willingness of market participants to exchange fiat asset for virtual asset, which may result in the potential for permanent and total loss of value of a particular virtual asset should the market for that virtual asset disappear; (6) Virtual Assets may not always be transferable and could, at times, be subject to limitations on movement or restrictions on their availability. (7) Virtual Assets may have limited or no liquidity, making them difficult to exchange, convert, or dispose of when needed. (8) Certain transactions are not private and may be permanently recorded on public distributed ledger technologies (DLTs), remaining accessible indefinitely. (9) There is no assurance that a person who accepts a virtual asset as payment today will continue to do so in the future; (10) The volatility and unpredictability of the price of virtual asset relative to fiat asset may result in significant loss over a short period of time; (11) The nature of virtual asset may lead to an increased risk of fraud, manipulation, theft or cyber attack and other targeted schemes and may not benefit from legal protections; (12) The nature of virtual asset means that any technological difficulties experienced by BitGo may prevent the access or use of a customer’s virtual asset; and (13) Any bond or trust account maintained by BitGo for the benefit of its customers may not be sufficient to cover all losses incurred by customers. (14) BitGo intends to offer an E-trading platform, whereby clients can trade their virtual assets directly from their custody account. Clients can press on the Request For Quote widget on the E-trading platform app that displays a valid price for size, direction and crypto asset as per the client’s request. Clients can place market or limit orders via BitGo's trading platform or APIs. The trading platform’s matching engine routes client orders to liquidity providers (via a back to back trade with Liquidity Providers (LPs)) with a goal to obtain market-leading pricing for its clients. Pricing is determined based on executable quotes sourced in real time from multiple independent LPs. The trading platform’s matching engine automatically selects the best available price for execution at the time of order placement, taking into account factors such as available liquidity, quoted spreads, and order size. This ensures that clients receive competitive pricing aligned with prevailing market conditions. BitGo generates revenue through transaction fees on executed trades, charged as a percentage of the trade value. Additional fees may apply for fiat deposits or withdrawals, depending on costs imposed by banking partners. (15) BitGo will route client orders to an appropriate BitGo affiliate including but not limited to BitGo Prime LLC or BitGo Hong Kong Ltd. Routing practices are determined solely on the basis of best available price and liquidity at the time of execution. BitGo does not maintain any arrangements or established practices to route any specific proportion (i.e. 20% or more) of client orders to a single liquidity provider. Should order flow concentration to any provider exceed this threshold, BitGo will monitor and disclose this in accordance with the VARA Broker-Dealer Services Rulebook, if required. (16) Clearing and settlement is provided by BitGo Custody MENA FZE and not BitGo MENA FZE (which is providing Broker-dealer services). (17) BitGo MENA FZE does not hold client assets. Client assets are held by BitGo Custody MENA FZE. (18) BitGo MENA FZE requires trading clients to sign up a Custodial Account with BitGo Custody MENA FZE for the safekeeping of client assets, and trading related services such as clearing and settlement (19) BitGo’s MENA FZE will not hold any Virtual Assets as it is providing broker-dealer services on a riskless principal basis. (20) BitGo conducts multiple levels of due diligence and reference checks on prospective employees. (21) BitGo MENA FZE provides services exclusively to Qualified Investors and Institutional Clients, as defined under VARA regulations. Retail clients are not serviced. (22) BitGo MENA FZE's proprietary assets are maintained in accounts with third parties. Proprietary Virtual Assets are held by BitGo Custody MENA FZE and funds are held by Zand Bank P.J.S.C.

If you have any questions or complaints, please first contact BitGo support at support@bitgo.com

Virtual Asset Standards

The following will be published on website here: https://www.bitgo.com/legal/

BitGo UAE Virtual Asset Standards

The following set out the factors on which BitGo will evaluate each Virtual Asset before making it available to our clients. These standards have been prepared in accordance with Rule VIII.A.1 of the Market Conduct Rulebook (the “VARA Market Conduct Rulebook”) which is issued pursuant to and forms part of the Virtual Assets and Related Activities Regulations 2023 (as may be amended from time to time) issued by VARA (the “Regulations”). Additionally, these standards are published on BitGo’s website in accordance with Rule VIII.A.3 of the VARA Market Conduct Rulebook.

Market metrics

Assessing its market capitalisation, fully diluted value and liquidity, and whether such metrics have trended downwards over time.

Design system

Reviewing its design, features and use cases, both intended and unintended by the issuer or relevant developers.

Legal compliance and prohibitions

Evaluating whether there are features which may materially affect BitGo’s compliance with applicable laws, Regulations, Rules (as defined in Schedule 4 (Definitions) of the Regulations) or Directives (as defined in Schedule 4 (Definitions) of the Regulations), including but not limited to those relating to AML/CFT (as defined in Schedule 4 (Definitions) of the Regulations), sanctions, securities, intellectual property.

Reviewing regulatory treatment by VARA and other appropriate authorities, including those outside of the Emirate (as defined in Schedule 1 (Definitions) of the VARA Market Conduct Rulebook), in particular whether the issuance of the Virtual Asset has received any regulatory approvals.

Reviewing whether a Virtual Asset is prohibited by VARA or any other appropriate authorities, both inside or outside the UAE, in jurisdictions in which BitGo will provide VA Activities as specified in Schedule 1 (VA Activities) of the Regulations, or equivalent activities, in relation to such Virtual Asset.

Security

Assessing the security and immutability of the underlying Digital Ledger Technology protocol.

Future Development

Considering its future development (e.g. “roadmap”) as communicated by the issuer and/or relevant developers.

Risk of market manipulation

Evaluating whether it may be susceptible to price manipulation for any reason and relevant mitigations that will be implemented by BitGo.

Conflicts of interest

Assessing whether potential or actual conflicts of interest may arise should BitGo provide any VA Activities in relation to the Virtual Asset and relevant mitigations.

Issuer background

Investigating the background of its issuer including, but not limited to, relevant experience in the Virtual Asset sector and whether it has been subject to any investigations or claims in relation to fraud or deceit.

Asset rights and availability

Considering if the Virtual Asset represents rights to any other assets, the enforceability of such rights.

Evaluating whether sufficient assets are available to satisfy any obligation with respect to any VA Activities.

Market correlation

Ensuring that the Virtual Asset terms and conditions reflect, to the extent possible, the operation of any existing underlying physical market and avoid adverse impacts to such market (if applicable).

Periodic review

Reviewing the Virtual Asset terms and conditions on a periodic basis for appropriate correlation with any physical market to ensure such terms and conditions conform to standards and practices in that physical market (if applicable).