VA Broker-Dealer Disclosure

Atremo Digital FZE is licensed and supervised by the Dubai Virtual Assets Regulatory Authority to provide Virtual Asset Broker-Dealer Services. Atremo Digital FZE may provide these services to Qualified Investors and Institutional Investors, subject to applicable regulatory requirements and client eligibility.

Atremo Digital FZE does not provide Virtual Asset custody services. No other entity using the Atremo name should be understood as licensed or supervised by VARA unless that entity and its regulatory status are expressly identified.

Pricing and Quotes
Atremo Digital FZE solicits quotes from multiple liquidity providers and, upon receipt, selects a provider to route the order. This automated selection process considers factors such as latency, quote expiration time, historical fill data, token characteristics, volatility, and additional relevant metrics. Atremo Digital FZE applies a markup to the quote received from the chosen liquidity provider.

Routing Practices
Atremo Digital FZE collaborates with multiple liquidity providers to execute client transactions. When selecting a liquidity provider for execution, Atremo considers a range of factors, including pricing, available liquidity, execution quality, latency, historical execution performance, token-specific characteristics and prevailing market conditions.
Atremo currently maintains relationships with several liquidity providers, including Infinity Bravo DMCC and Zodia Markets (UK) Limited.
In accordance with applicable regulatory requirements, Atremo discloses that, as of the date of this disclosure, the following liquidity providers have each received 20% or more of Atremo's client order flow:

Infinity Bravo DMCC
Zodia Markets (UK) Limited

Atremo periodically reviews its order routing practices and liquidity provider relationships. This disclosure will be updated where there are material changes to the concentration of client order flow.

Maintaining Funds / Virtual Assets / Clearing Services

Atremo Digital FZE does not provide Virtual Asset custody services and does not provide clearing services for other Virtual Asset Service Providers.

Where Virtual Asset custody is required in connection with Atremo Digital FZE’s Broker-Dealer Services, Virtual Assets are held by Hex Trust MENA FZE, its only appointed third-party Virtual Asset custodian.

Any banking services used in connection with Atremo Digital FZE’s operations are provided separately by the relevant banking providers and should not be understood as Virtual Asset custody services provided by Atremo Digital FZE.

Protection of Clients’ Ownership of Assets

Atremo Digital FZE has implemented arrangements designed to protect clients’ ownership interests in Virtual Assets used in connection with its Broker-Dealer Services.

Atremo Digital FZE does not provide Virtual Asset custody services. Where custody is required, clients’ Virtual Assets are held by Hex Trust MENA FZE, Atremo Digital FZE’s only appointed third-party Virtual Asset custodian, in accordance with the applicable custody arrangements, regulatory requirements and client agreements.

Atremo Digital FZE maintains appropriate records and reconciliation arrangements to support the accurate identification of clients’ ownership interests.

Third-Party Virtual Asset Custodian

Atremo Digital FZE does not provide Virtual Asset custody services. Hex Trust MENA FZE is Atremo Digital FZE’s only appointed third-party Virtual Asset custodian.

Where custody is required in connection with Atremo Digital FZE’s Broker-Dealer Services, Virtual Assets are held by Hex Trust MENA FZE in accordance with the applicable custody arrangements, regulatory requirements and client agreements.

Zand and Singapore Gulf Bank provide banking services and are not Virtual Asset custodians.