Regulatory Disclosures

AXEN LIFE DMCC is incorporated in Dubai Multi Commodities Centre (DMCC) and is a Virtual Asset Service Provider (VASP) currently in the process of obtaining a license from the Dubai Virtual Asset Regulatory Authority (VARA). Upon issuance, our VARA license number and licensed activity details will be published here.

1. RESPONSIBLE INDIVIDUALS

The following individuals are responsible for the management and operations of AXEN LIFE DMCC:

• Dante Eludier Vargas Caro (Director)

• Jonathan Elioenai Torres Soto (Manager)

• Sadi Ahmad (Compliance Officer / MLRO)

The agreement and applicable services depend on the regulatory scope under which the Client is onboarded.

2. VIRTUAL ASSET STANDARDS

AXEN LIFE DMCC is committed to the following standards in the conduct of its Virtual Asset activities:

• Market Integrity: AXEN LIFE DMCC does not engage in, facilitate, or permit market manipulation, insider trading, or any other conduct that could undermine the integrity of Virtual Asset markets.
• Fair Treatment of Clients: All clients are treated fairly and with transparency. Services are provided in the best interests of clients, with clear disclosure of risks, fees, and conflicts of interest.
• Best Execution: For Broker-Dealer and trading activities, AXEN LIFE DMCC takes all reasonable steps to achieve the best possible outcome for clients, taking into account price, costs, speed, and likelihood of execution.
• Client Asset Protection: Client funds and Virtual Assets are held separately from AXEN LIFE DMCC’s own assets in dedicated segregated accounts and wallets. Daily reconciliations are performed to ensure accuracy.
• AML/CFT Compliance: AXEN LIFE DMCC maintains robust Anti-Money Laundering and Counter-Terrorist Financing controls in accordance with UAE Federal Law and VARA requirements, including KYC procedures, transaction monitoring, and suspicious activity reporting.
• Data Protection: Client data is handled in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data.
• Regulatory Cooperation: AXEN LIFE DMCC cooperates fully with VARA and other competent authorities and maintains open, transparent reporting in accordance with all applicable regulations.

3. SERVICES & ACTIVITIES

3.1. Broker-Dealer Services
AXEN LIFE DMCC provides Broker-Dealer Services in Virtual Assets, acting as principal in the buying and selling of Virtual Assets. In connection with these services, clients should be aware of the following:

• Nature of Service: AXEN LIFE DMCC may act as counterparty to client transactions, buying or selling Virtual Assets on its own account. This means AXEN LIFE DMCC may have interests that differ from those of the client in any given transaction.
• Best Execution: AXEN LIFE DMCC applies a best execution policy to ensure clients receive competitive pricing and timely execution. Details of our best execution approach are available in our Terms and Conditions.
• Fees and Charges: All applicable fees, spreads, and charges are disclosed to clients prior to execution of any transaction. Fees may vary by transaction type, volume, and Virtual Asset. A current fee schedule is available upon request and within the platform.
• Conflicts of Interest: As a principal in transactions, AXEN LIFE DMCC may hold positions in Virtual Assets it facilitates for clients. Our Conflicts of Interest policy governs how such conflicts are identified and managed.
• Risks: Virtual Asset prices are highly volatile. Broker-Dealer transactions carry the risk of significant financial loss. Please read our Risk Notice in full before engaging in any transactions.
• Referrals and Introductions: AXEN LIFE DMCC does not refer or introduce clients to other entities, VASPs, or third-party service providers in connection with Broker-Dealer Services in exchange for any monetary or non-monetary benefit, remuneration, or reciprocal arrangement.
• Policies: Our policies and procedures relating to data privacy, whistleblowing, and handling of client complaints are available at axenbroker.com/privacy-policy and axenbroker.com/complaints.
• Virtual Assets Offered: AXEN LIFE DMCC currently supports the following Virtual Assets for Broker-Dealer transactions. Current market data including market capitalization, circulating supply, price ranges, and drawdown history is updated dynamically in the Client Portal. Smart contract audit status for each supported asset is reviewed on a periodic basis and available upon request.
  – Bitcoin (BTC) on Bitcoin network
  – Ethereum (ETH) on Ethereum network
  – Tether (USDT) on Ethereum & Tron networks
  – USD Coin (USDC) on Ethereum network
• Price Determination: AXEN LIFE DMCC determines the prices it quotes to clients by reference to prices received from its approved liquidity providers (B2Prime, Equiti Brokerage Limited, Scope Markets Ltd, Thunder Markets), applying a spread or markup as disclosed in the fee schedule. Clients are quoted a single executable price inclusive of all applicable charges.
• Order Routing: Client orders are routed to AXEN LIFE DMCC’s approved liquidity providers on the basis of best execution. Where 20% or more of client orders are routed to a single liquidity source in any given period, the identity of that source will be disclosed to clients in the periodic transaction report available through the Client Portal.
• Client Asset Protection: Client Virtual Assets are held in segregated wallets with B2BinPay UK Ltd, separate from AXEN LIFE DMCC’s proprietary assets. Client Money is held at Mashreq Bank PSC in a designated Client Money Account. AXEN LIFE DMCC does not hold funds or Virtual Assets on behalf of other VASPs and does not provide clearing services to other VASPs.

3.2. Advisory Services

AXEN LIFE DMCC provides Virtual Asset advisory services to clients, offering guidance on Virtual Asset strategies, portfolio composition, and market developments.

• Nature of Service: Advisory services provided by AXEN LIFE DMCC are non-independent. Advice is based on analysis of Virtual Asset markets and the client’s stated objectives and risk tolerance. AXEN LIFE DMCC does not consider the full range of products available in the market.
• Suitability: Before providing advice, AXEN LIFE DMCC will assess the client’s knowledge, experience, financial situation, and investment objectives to ensure any recommendation is suitable. Clients must provide accurate and complete information to support this assessment.
• Fees: Advisory service fees are agreed with the client prior to the commencement of services and are set out in the client agreement.
  Conflicts of Interest: AXEN LIFE DMCC may have relationships with Virtual Asset issuers or other service providers that could influence advisory outputs. All material conflicts are disclosed to clients prior to the provision of advice.
• No Guarantee of Outcome: Advisory services do not guarantee any particular investment outcome. Clients remain responsible for all investment decisions.
• Third-Party Accounts: AXEN LIFE DMCC does not itself hold client Virtual Assets in connection with Advisory Services. Where a client also holds a Broker-Dealer account, Virtual Assets are maintained by B2BinPay UK Ltd as custodian.
• Referrals and Introductions: AXEN LIFE DMCC does not refer or introduce clients to other entities, VASPs, or third-party service providers in connection with Advisory Services in exchange for any monetary or non-monetary benefit, remuneration, or reciprocal arrangement.
• Policies: Our policies and procedures relating to data privacy, whistleblowing, and handling of client complaints are available at axenbroker.com/privacy-policy and axenbroker.com/complaints.

3.3. Management and Investment Services
AXEN LIFE DMCC provides Virtual Asset portfolio management and investment services, managing Virtual Asset holdings on behalf of clients in accordance with agreed mandates.

• Nature of Service: AXEN LIFE DMCC manages client Virtual Asset portfolios on a discretionary or non-discretionary basis, as agreed in the client mandate. Discretionary management allows AXEN LIFE DMCC to make investment decisions on the client’s behalf within agreed parameters without prior approval for each transaction.
• Investment Objectives and Strategy: Each client mandate sets out the investment objectives, risk profile, permitted asset classes, and any restrictions. AXEN LIFE DMCC manages the portfolio in accordance with this mandate.
• Reporting: Clients receive regular reporting on portfolio performance, holdings, and material transactions. Reporting frequency and format are agreed at the outset of the relationship.
• Fees: Management fees are set out in the client agreement and may include a fixed management fee, performance fee, or both. All fees are disclosed in advance.
• Conflicts of Interest: AXEN LIFE DMCC’s management and investment activities may give rise to conflicts of interest, including where AXEN LIFE DMCC manages portfolios for multiple clients with competing interests. Our Conflicts of Interest policy governs how such conflicts are identified, managed, and disclosed.
• Risks: The management of Virtual Asset portfolios carries significant risk, including the risk of total loss. Past performance is not indicative of future results.
• Client Access in Extreme Volatility: Clients retain the right to access and withdraw their Virtual Assets at any time, including during periods of high uncertainty or extreme market volatility, subject to the terms of the client mandate and any applicable operational processing times. AXEN LIFE DMCC will take all reasonable steps to facilitate withdrawal requests promptly and will notify clients of any delay and the reason for it.
• Third-Party Accounts: Client Virtual Assets held in managed portfolios are maintained by approved third-party custodians. Currently, custody services are provided by B2BinPay UK Ltd. Client funds held in fiat are maintained at Mashreq Bank PSC.
• Referrals and Introductions: AXEN LIFE DMCC does not refer or introduce clients to other entities, VASPs, or third-party service providers in connection with Management and Investment Services in exchange for any monetary or non-monetary benefit, remuneration, or reciprocal arrangement.
• Policies: Our policies and procedures relating to data privacy, whistleblowing, and handling of client complaints are available at axenbroker.com/privacy-policy and axenbroker.com/complaints.