LOGIN
SIGN UP

Conflicts of Interest Disclosure

[Version: 2.0, Last updated: 03.10.2025]

(In line with Article 72 of the Markets in Crypto-Assets Regulation (MiCAR)) 

This disclosure applies to SMART VALOR AG, Liechtenstein, acting as a regulated crypto-asset service provider (CASP) under MiCAR.

1. Why this matters

At SMART VALOR, your trust is our top priority. 
Because of the way financial and crypto markets work, there are situations where our interests, or the interests of different clients, might not fully align. These are called conflicts of interest.

This document explains:

  • What conflicts of interest are
  • Where they could happen at SMART VALOR
  • What we do to prevent and manage them
  • How we keep you informed

Our commitment: no conflict will ever be allowed to harm your interests.

2. What is a conflict of interest?

A conflict of interest is when different parties, SMART VALOR, our employees, or our clients, have competing interests that could affect fair treatment.

Simple examples:

  • We act as both the platform operator and a trading counterparty (market making).
  • Two clients submit competing orders for the same token at the same time.
  • An employee trades crypto personally while having access to client information.
  • A third-party partner or affiliate has ties that could affect decision-making.

3. Where conflicts can arise at SMART VALOR

A. Between SMART VALOR and our clients

Example: When we act as a market maker, your order may be matched against SMART VALOR’s own account.

How we handle it: All orders are executed automatically using independent market prices. We hedge positions after execution, run daily reviews, and submit to external audits. We also apply our Exchange Rule Book Policy, which monitors execution quality (price, speed, and likelihood of settlement) and is reviewed regularly to ensure fair outcomes for clients.

B. Between clients

Example: Two clients place buy and sell orders for the same asset at the same time.

How we handle it: Orders are executed fairly and transparently using the First In, First Out principle. All orders are time-stamped to the millisecond.

C. Between employees and clients

Example: Employees could misuse inside knowledge or trade for themselves in a way that competes with clients.

How we handle it: Employees must request pre-approval for personal trades. Their trading activity is monitored. We also restrict access to sensitive systems, require NDAs for those handling confidential data, and keep strict logs of all activity. Breaches lead to disciplinary action, up to dismissal, and may be reported to regulators.

D. With affiliates and partners

Example: A director or employee has a personal link to a partner company, which might lead to preferential treatment.

How we handle it: All such relationships must be declared. Contracts with affiliates are reviewed independently, and anyone with a personal link steps aside from decisions.

E. With liquidity providers

Example: Relying on one liquidity provider might create dependency or affect pricing.

How we handle it: We use multiple liquidity sources where possible, check prices against the market, and review providers regularly.

F. With outsourced service providers

Example: External partners supporting our operations may have their own business interests.

How we handle it: We run due diligence before hiring, set strict contracts, and audit them regularly. If issues arise, we take corrective action or end the partnership.

G. From our group structure (past and present)

Example: In the past, SMART VALOR Liechtenstein was part of the wider SMART VALOR Group, which could have created overlaps in staff or services.

How we handle it: Since 2025, SMART VALOR Liechtenstein operates independently. Historical risks, such as shared services or related-party transactions, have been fully documented and resolved. We continue to disclose them for transparency.

H. From staff pay and incentives

Example: If staff bonuses depended on promoting certain tokens, this could bias their advice or actions.

How we handle it: Our pay structure does not reward staff based on the success of specific assets or client outcomes. Fixed and variable elements are balanced to avoid undue influence.

4. How we manage conflicts of interest

We follow a clear framework that combines rules, oversight, and training:

  • Strong governance – The Board of Directors has overall responsibility. A designated Conflicts Officer keeps a Conflicts Register, and the Compliance Officer checks independently.
  • Clear separation of duties – We apply the “four eyes” principle: no one can make important decisions alone. Access to systems is role-based, and “Chinese walls” prevent misuse of confidential information.
  • Employee obligations – All staff must disclose external roles, trading activity, or other potential conflicts.
  • Independent reviews – Contracts with affiliates or third parties undergo independent checks.
  • Audits & monitoring – We maintain a Conflicts Register, conduct regular internal and external audits, and escalate material issues directly to the Board.
  • Training – Staff receive ongoing training on conflicts, market abuse prevention, and conduct rules.
  • Disclosure – If a conflict cannot be fully removed, we will tell you in advance, explaining the nature of the conflict, how it could affect you, and the steps we’ve taken to reduce any impact, so you can make an informed choice.

5. What this means for you as a client

  • Your orders are executed fairly and transparently.
  • We keep records for at least 10 years to ensure accountability and allow regulators to check our work.
  • You will be notified if a conflict arises that cannot be fully managed internally.
  • Disclosures are available during onboarding, on our website, and before specific transactions.
  • If you have concerns about how a conflict was managed, you can use our Complaints Handling process. More information is available here: Complaint Handling Process.

6. Updates and transparency

  • This disclosure is updated regularly to reflect our business and regulatory requirements.
  • We review this disclosure at least annually and whenever our services or regulations change in a way that could affect you.
  • Clients are notified when there are important changes.
  • The disclosure is available in English and German. Please scroll bellow for the German Version of the document.

7. Our commitment

We are committed to:

  • Treating all clients fairly and equally
  • Ensuring full transparency
  • Protecting your interests at all times

If you have questions about this disclosure or our practices, please contact us at reg.comp@smartvalor.com.