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Conflicts of Interest
Archway Finance JSC (“Archway”) is committed to identifying, preventing and managing conflicts of interest. This page describes the general nature and sources of conflicts of interest that may arise when we provide crypto-asset services, and the measures we take to mitigate them.
Our role and services
- We provide crypto-asset exchange services (exchange of crypto-assets for funds and for other crypto-assets).
- We operate a principal dealer model: we act as the counterparty to your transaction. We earn a spread and/or fee that is reflected in the quoted exchange rate and/or fees.
Potential conflicts of interest (examples)
- Pricing and execution: as principal, we may have an incentive to set spreads/fees that increase our revenue.
- Inventory management: we maintain inventory to execute exchanges; inventory decisions could influence quotes or timing.
- Third-party relationships: we rely on banking partners and service providers (e.g., KYC/KYT, wallet technology, cloud infrastructure). Conflicts may arise in selecting, managing, or receiving benefits from such partners.
- Related-party relationships: shareholders, directors or staff may have interests in entities we work with.
- Personal interests: staff personal trading, gifts/hospitality, or outside business activities could influence decisions.
How we mitigate conflicts
- Written conflicts-of-interest policy and a Conflicts Register overseen by Compliance.
- Governance and recusals: conflicted persons do not participate in decisions; material conflicts are escalated to the Board.
- Pricing governance: pricing logic is documented; overrides are limited, logged and reviewed.
- Personal dealing controls: restricted persons must obtain pre-clearance before trading in-scope stablecoins/EMTs.
- Gifts and inducements controls: we prohibit cash/cash equivalents and apply thresholds and pre-approval rules.
- Vendor and outsourcing controls: vendor decisions follow documented approval routes and independent compliance challenge.
If a conflict cannot be fully prevented or mitigated, we will disclose it to you before proceeding or, where necessary, we will decline the activity.
Contact
If you have questions about conflicts of interest, contact: compliance@archway.finance
