DISCLOSURES
Broker Dealer Disclosures
Pricing Methodology
LTP offers Direct Market Access. Clients trade on the execution venue they select, at the prices available on that venue at the time of execution. LTP does not set those prices and does not add any markup or spread to them.
LTP is remunerated by a commission charged to the client on executed trades. The commission, or the portion of any amount payable by the client that LTP retains, is disclosed to the client before execution and in the trade confirmation. LTP does not receive any payment, rebate, discount or other benefit from any execution venue or other third party in connection with client order flow.
Order Routing Practice
Liquidity Fintech FZE ("LTP") offers Direct Market Access ("DMA"). When placing an order, the client selects the execution venue. LTP does not aggregate quotes, does not select a venue on the client's behalf, and does not exercise any routing discretion; LTP transmits the client's order for execution on the venue the client has chosen. The venues available to clients are Binance FZE and OKX FZE.
Concentration of order routing. VARA requires LTP to disclose whether twenty percent (20%) or more of client orders are routed to any single liquidity source and, if so, to identify that source.
As at July 31, 2026, Liquidity Fintech FZE is not yet operational and has not executed client orders under its VARA Licence. Because the execution venue is selected entirely by the client, LTP does not route client orders to any liquidity source of its own selection, and any concentration of orders at a particular venue reflects clients' own choices rather than routing by LTP. From the commencement of client order flow, LTP will monitor the distribution of client orders across venues and will disclose here any single liquidity source that receives twenty percent (20%) or more of client orders, together with its identity.
Basis of measurement. Concentration is measured by the number of client orders executed at each venue as a proportion of all client orders, and is also monitored by notional value.
Review. LTP reviews this position quarterly and updates this disclosure within [twenty (20)] business days of any material change. This disclosure states the position as at the date shown above.
VA Specific information
Liquidity Fintech FZE (“LTP”) provides virtual asset brokerage and does not issue, control or manage any underlying virtual assets or blockchain protocols. Virtual assets made available through LTP are sourced via third-party liquidity providers, including regulated exchanges, and availability is dependent on support from such providers. Information relating to virtual assets, including pricing, market data and project-related information, is obtained from publicly available third-party sources such as CoinMarketCap, CoinGecko, TradingView and official project websites. Clients may be redirected to such external sources for further information. LTP does not independently verify or guarantee the accuracy or completeness of such information. Certain virtual assets may be associated with smart contracts deployed on public blockchains; however, smart contract audit reports are not available for all virtual assets. LTP does not conduct proprietary smart contract audits and relies on publicly available disclosures from token issuers or independent third parties where available, and where such information is not publicly available, this will be disclosed accordingly. Clients should refer to LTP's Risk Disclosure for a full description of risks associated with virtual assets.
Custody, Clearing and Safekeeping of Assets for Other VASPs
LTP does not hold, maintain or provide clearing services for other Virtual Asset Service Providers (VASPs). LTP's services are provided to its own clients and do not include custodial or clearing functions for other VASPs. LTP's own arrangements for holding client assets, and the third parties that hold assets for LTP, are described under "Protection of Client Asset Ownership" and "Third-Party Custody and Asset Holding Arrangements" below.
Protection of Client Asset Ownership
LTP has implemented robust arrangements to ensure the protection and integrity of clients' ownership of assets held on the platform. All client assets are securely held in segregated accounts, separate from LTP's proprietary holdings, to prevent any commingling. Additionally, LTP follows stringent custody protocols, enhanced security measures, and regular audits to uphold clients' ownership rights and ensure full compliance with regulatory standards. Clients can access and verify their asset holdings at any time, reinforcing our commitment to transparency and asset protection.
Client Referrals and Introduction Arrangements
LTP does not operate any client referral or introduction arrangement. LTP does not refer or introduce its clients to other entities, including other Virtual Asset Service Providers, and has no referral, introduction, or reciprocal arrangement in place with any third party.
LTP offers Direct Market Access ("DMA"). Where a client accesses an execution venue through LTP's DMA service, the client selects that venue at its own direction. LTP's provision of access is carried out on the client's instruction and does not constitute the referral or introduction of a client for which LTP receives, or is entitled to receive, any benefit.
LTP does not receive any monetary or non-monetary benefit, inducement, commission, rebate or other consideration from any third party, including any execution venue, in connection with the referral or introduction of clients or the routing of client orders.
Third-Party Custody and Asset Holding Arrangements
LTP utilises select third-party custodians, including Komainu MEA FZE, to safeguard clients' Virtual Assets. These custodians are subject to applicable regulatory requirements and industry best practices to ensure secure storage and handling of Virtual Assets.
LTP maintains Client Money Accounts with Zand Bank P.J.S.C., a Dubai, UAE-incorporated bank. Client funds are held in designated client money accounts on a segregated basis, separate from LTP's own funds, and are operated in accordance with applicable regulatory requirements.
These client money accounts function as ring-fenced accounts, whereby funds are held on behalf of clients and may only be used for the purposes of executing client instructions or returning funds to the originating client account.
LTP implements internal controls and reconciliation processes to ensure proper segregation, safeguarding, and accurate recording of all client assets held with third-party custodians and banking partners.
Other Disclosable Matters
As at the date of this disclosure, there is no additional information relating to the VASP's business or activities that VARA has required to be disclosed.
Virtual Assets Offered
This list sets out the virtual assets which are available to trade through Liquidity Fintech FZE. Our clients are invited to make enquiries in relation to other assets and these will be reviewed on a case by case basis and approved subject to our internal Virtual Asset acceptance procedures.