Liquidity Fintech FZE ("LTP") establishes and maintains standards for the virtual assets in relation to which it provides broker-dealer services (the "VA Standards"), published in accordance with Part VIII of the VARA Market Conduct Rulebook.
LTP is a VARA-licensed broker-dealer. It does not issue virtual assets and does not operate a trading venue. LTP provides Direct Market Access: at the client's direction, it transmits client orders for execution on the eligible third-party venues it uses. At launch these are Binance FZE and OKX FZE, each licensed by VARA. LTP serves Qualified Investors and Institutional Investors only and does not provide services to Retail Investors.
Venue-led availability
LTP operates a client-directed model. A client may instruct LTP to transmit an order in any virtual asset available for execution on an eligible venue LTP uses, subject to these VA Standards.
LTP does not operate an investment-merit list. LTP does not exclude a virtual asset simply because it is emerging, speculative, low-market-capitalisation, or a meme, fan, gaming or utility token. Which assets to trade is the client's decision. Our VA Standards are not a judgement on investment merit — they are a financial-crime, legal, regulatory and operational filter that every asset must pass before LTP will deal in it.
Availability is not, by itself, a decision by LTP to accept an order. An asset may be dealt in through LTP only while it remains eligible under these VA Standards, LTP's policies, its licence conditions and applicable law. The venues and assets available through LTP may change at any time, and availability may be restricted by jurisdiction, client classification, or technical, liquidity, custody or settlement considerations.
How we rely on our venues
Binance FZE and OKX FZE are each licensed by VARA and are each required to establish, apply and publish their own VA Standards. As part of our assessment, LTP relies on each venue's VARA-mandated listing and screening controls, and applies its own standards and the exclusions below on top of them. LTP does not rely on any venue that is not subject to an equivalent regulatory standard without applying its own enhanced assessment of the relevant assets.
Assets we will not deal in
LTP will not transmit an order in a virtual asset where:
- it is prohibited by VARA or another competent authority in a relevant jurisdiction;
- dealing in it would breach applicable law, regulation, sanction, court order or licence condition;
- it is, or is reasonably likely to be, a security or other regulated instrument that LTP is not licensed to deal in — this includes tokenised equities and other tokenised securities;
- it is an anonymity-enhanced ("privacy") virtual asset whose features prevent effective transaction monitoring, sanctions screening or Travel Rule compliance — LTP does not deal in such assets;
- the asset, its issuer, a relevant developer or an associated person or entity is subject to sanctions or other restrictive measures;
- it presents money-laundering, terrorist-financing, proliferation-financing or sanctions-evasion risk that LTP cannot adequately mitigate or monitor;
- LTP cannot obtain sufficient reliable information to assess it; or
- LTP cannot support it safely and lawfully through its execution, settlement, custody, wallet, blockchain-analytics or transaction-monitoring arrangements.
What we assess
Before we deal in an asset, and on an ongoing basis afterwards, LTP assesses relevant information — proportionate to the asset, the venue and the risks identified — including:
| Market and liquidity | Market capitalisation, fully diluted value and liquidity, and whether these have trended downwards over time |
|---|---|
| Design and purpose | The asset's design, features and use cases, including uses not intended by its issuer or developers |
| Legal and regulatory | Features that may affect our compliance with applicable law — including AML/CFT, sanctions, securities and intellectual property; the regulatory treatment of the asset by VARA and other authorities; and whether it has received any regulatory approval |
| Technology | The security and immutability of the underlying distributed ledger protocol; smart contract audit status and date; upgradeability and administrative controls |
| Development | The asset's roadmap as communicated by its issuer or developers, and delivery against it |
| Market integrity | Susceptibility to price manipulation, including supply and holder concentration, and the mitigations we apply |
| Conflicts | Any actual or potential conflict of interest arising from our dealing in the asset, and how we manage it |
| Issuer | The background and experience of the issuer, and whether it has been subject to investigation or claims relating to fraud or deceit |
| Rights and backing | Where the asset represents rights to other assets, whether those rights are enforceable, and whether sufficient assets exist to satisfy the related obligations |
| Underlying markets | Where an asset relates to a physical market, whether its terms reflect the operation of that market and avoid adverse impact on it |
| Operational readiness | Custody and wallet support, analytics coverage, and availability of at least two independent price sources |
| Client suitability | Suitability for our client base. LTP serves Qualified Investors and Institutional Investors only, and does not provide services to Retail Investors |
How we apply these standards
LTP applies a documented, risk-based process, drawing on the venue controls described above, blockchain-analytics tools, market data, publicly available information and other reliable sources. LTP's Virtual Asset Committee oversees these VA Standards; the Committee includes LTP's Compliance Officer, who may veto any asset, category of assets, venue or arrangement where LTP's legal, regulatory, financial-crime, operational or client-protection requirements are not met.
No asset is dealt in through LTP unless LTP has a documented basis for concluding that it meets these VA Standards at the relevant time. LTP maintains a record of the assets available through it and of its exclusions, and retains records relating to its assessments and decisions for at least eight years, making them available to VARA on request.
The fact that an asset is available through LTP means only that LTP has determined, at the relevant time, that it may provide its authorised services in relation to that asset. It is not a representation that the asset is a good investment, low-risk, suitable for any client, or approved or endorsed by LTP or VARA.
Ongoing review, restriction and suspension
LTP monitors relevant information on an ongoing basis and re-assesses assets periodically. LTP may immediately refuse, restrict or suspend dealing in an asset where it no longer meets these VA Standards — for example following regulatory action, a sanctions designation, a security incident, exploit, fork, airdrop, contract migration or redenomination, withdrawal of venue or analytics coverage, a sustained material decline in liquidity, credible allegations of fraud or manipulation, or, for fiat-referenced or asset-referenced tokens, loss of peg or suspension of redemptions.
On suspension, LTP will stop accepting new orders as appropriate, determine the treatment of open orders with due regard to client interests, notify affected clients as soon as reasonably practicable, notify VARA as soon as possible, and comply with any direction VARA gives. VARA may also require LTP to suspend dealing in any asset.
Important notice
Virtual assets are high-risk and may lose value in part or in full. The availability of an asset through LTP, or the acceptance or execution of an order, is not investment advice, a personal recommendation, or an endorsement or approval by LTP or VARA. Clients remain responsible for their own investment decisions and for understanding the risks of each asset, including highly speculative assets such as low-market-cap, meme, fan, gaming and utility tokens.
Related information
Virtual Assets Offered · Broker-Dealer Disclosures · Risk Disclosures