DISCLOSURES

Regulatory disclosures:

Identity of the competent supervisory authority (e.g. Bank of Spain, CNMV)

Banco de España (Bank of Spain):

Supervisory authority for credit institutions, payment institutions, and electronic money institutions. Responsible for prudential supervision, operational resilience, conduct of business, and compliance with payment services regulations.

CNMV (Comisión Nacional del Mercado de Valores):

Supervisory authority for investment firms, collective investment schemes, market infrastructures, and crypto-asset service providers (CASPs) under Regulation (EU) 2023/1114 (MiCA). Focuses on investor protection and market integrity.

SEPBLAC (Servicio Ejecutivo de la Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias):

Financial Intelligence Unit (FIU) and supervisory authority for AML/CFT compliance. Monitors and enforces obligations under Law 10/2010 and Royal Decree 304/2014 across all obliged entities, including banks, fintech firms, crypto-asset providers, and other regulated entities.

Dispute Resolution

Customers may file complaints through the company's internal procedure. If not satisfied, they may contact the Bank of Spain Complaints Service, and once authorised under MiCA, the CNMV Complaints Service.

Legal disclaimer

Crypto-asset services are not covered by deposit guarantee schemes or investor compensation schemes.

Geographic restrictions

Certain products or services offered by Liquidity Technology S.L.U. may not be available in specific jurisdictions due to legal or regulatory restrictions.

Complaints and Claims Procedure

Whistleblowing channel details (with confidentiality guarantees)
Liquidity Technology Spain provides a secure whistleblowing channel for employees and persons with a professional connection, in compliance with Law 2/2023.

Description of Services Offered – Liquidity Technology Spain (LTP Spain)

Business Definition:

Liquidity Technology S.L.U. (LTP) is a registered Virtual Asset Service Provider (VASP) under the Bank of Spain and will operate as a regulated entity offering reception and transmission of orders in relation to virtual assets and providing custody services strictly for transaction facilitation purposes. LTP Spain focuses on servicing institutional clients with a high standard of regulatory compliance and operational transparency.

Core Services:

Agency OTC Execution Service:

LTP Spain offers a white glove OTC execution service for institutional clients such as asset managers, family offices, and SMEs. Clients are typically long-term investors focused on high-quality digital assets held for investment purposes.

EUR Fiat On/Off Ramp:

LTP Spain provides an agency-based OTC on-ramp and off-ramp service, exclusively in EUR, allowing clients to convert between fiat and cryptoassets in a secure and compliant manner.

Short-Term Custody for Execution Facilitation:

LTP Spain offers short-term custody of digital assets, solely to facilitate execution of customer instructions. Custody is not provided as a standalone service.

Operational Caveats and Limitations:

All transactions are executed strictly under client instructions. LTP Spain does not provide discretionary portfolio management services.

LTP Spain may offer agnostic, non-promotional research on digital assets but does not issue investment advice or recommendations.

Transactions are executed exclusively on Spanish domestic venues (e.g., BBVA, ).

Custody of digital assets is conducted via top-tier, outsourced custodians operating in Spain. LTP does not hold client assets directly.

LTP Spain, as a registered CASP (Crypto Asset Service Provider), may offer services related to stablecoins such as USDC, subject to final confirmation of regulatory position.

Organizational Structure and Staffing:

LTP Spain is supported by a lean but capable operational team, composed of internal resources and trusted outsourced providers:

Management: Led by Leopoldo as the local Administrator and Jack as Global Managing Director.

Finance: David Wong (Global CFO) oversees financial operations; Contalia provides local accounting services.

Compliance: Miguel Moreno has been appointed as the local Chief Compliance Officer to ensure alignment with AML/CFT and MiCA regulations.

Legal/Regulatory: Subcontracted to ATH21.

Operations & Recordkeeping: Delegated to Contalia, supported by oversight from the Legal and Finance teams.

IT and Security: Use of Lark Suite to maintain transaction integrity, documentation, and audit trail. A CTO will be appointed to manage technical infrastructure, ensuring robust cybersecurity and compliance with local IT standards.

LTP Spain maintains a service-driven, compliance-led approach to delivering digital asset execution and custody solutions for sophisticated institutional clients in Spain.

LTP Risk Warnings

The following risk warnings are provided to ensure that Clients of Liquidity Technology S.L.U. (LTP) understand the inherent risks associated with engaging in digital asset-related services:

Market Volatility

Digital assets, including but not limited to cryptocurrencies and stablecoins such as USDC, are subject to extreme price volatility. Prices may fluctuate significantly within short periods, and past performance is not indicative of future results.

Risk of Capital Loss

The value of digital assets may decrease sharply or become worthless. Clients may incur partial or total loss of their invested capital, and LTP Spain does not guarantee the preservation of principal or returns on any transaction.

Lack of Regulatory Protections

While LTP Spain is registered as a Virtual Asset Service Provider (VASP) with the Bank of Spain under registration number CRIPTO-2023-044, certain protections applicable to regulated financial instruments under EU financial services law may not apply to digital assets. Clients should understand that there may be no deposit guarantee scheme or investor compensation scheme available for losses related to digital asset transactions.

Counterparty and Custody Risks

LTP Spain operates on an agency model and outsources custody of digital assets to regulated third-party financial institutions. Although due diligence is conducted on all custodial partners, the Client bears the risk of loss arising from insolvency, technical failure, or misconduct of custodians or banking partners.

Operational and Cybersecurity Risks

There is a risk of disruption to services due to system failures, cyberattacks, or other operational incidents. While LTP Spain adopts robust security measures, there is no guarantee that technical vulnerabilities or external attacks will not impact the availability, confidentiality, or integrity of its services.

Regulatory Change

The regulatory landscape for crypto-assets is evolving rapidly. Future regulatory developments, including full implementation of Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), may impact the availability, legality, or economic viability of LTP Spain's services.

No Investment Advice

LTP Spain does not provide investment advice or portfolio management services. Any Information, research, or commentary made available by LTP Spain is for informational purposes only and should not be construed as a recommendation to buy, sell, or hold any digital asset.Important: By engaging in digital asset transactions with LTP Spain, the Client confirms thatthey understand and accept the above risks. Clients should assess their risk tolerance, financial situation, and investment objectives carefully before transacting.

Legal and compliance notices:

Liquidity Technology Spain maintains a Conflict of Interest Policy. Further details are available to clients upon request at [email protected]

AML/CFT Disclaimer

Liquidity Technology S.L.U. (LTP Spain) is fully committed to preventing money laundering and the financing of terrorism, in accordance with applicable Spanish and European legislation, including: Law 10/2010, of 28 April, on the prevention of money laundering and terrorist financing
Royal Decree 304/2014, approving the Regulation of Law 10/2010
Relevant provisions of the Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA)
Guidelines issued by SEPBLAC and the Bank of Spain

Customer Due Diligence (CDD)

LTP Spain applies robust Know Your Customer (KYC) procedures prior to establishing any business relationship. These include:

• Identification and verification of clients and beneficial owners
• Understanding the purpose and nature of the business relationship
• Ongoing monitoring of transactions and client activity
• Enhanced due diligence (EDD) is applied for high-risk clients or jurisdictions.

Transaction Monitoring

All client transactions are subject to real-time and post-trade monitoring to detect suspicious activity or unusual patterns, including:

• Large or structured transactions
• Use of anonymity-enhancing technologies
• Activity inconsistent with the client profile

Reporting Obligations

Suspicious transactions or behaviors will be promptly reported to SEPBLAC (Servicio Ejecutivo de la Comisión de Prevención del Blanqueo de Capitales e Infracciones Monetarias), as required by law.Record Keeping In compliance with AML/CFT obligations, LTP Spain maintains all client and transactional records for a minimum of ten (10) years, in line with applicable regulations.

Staff Training

LTP Spain ensures that its employees receive regular AML/CFT training and are fully aware of their duties and responsibilities to detect and report suspicious activity.

Contact Us

For information regarding LTP, please contact our Madrid office at:
Liquidity Technology S.L.U, C. de Guzmán el Bueno, 133, Chamberí, 28003 Madrid, Spain
For general inquiries and global media contact information, please visit our Global Contacts