Corporate Information Disclosure
Flowdesk Omega FZE is committed to transparency and compliance with all regulatory requirements.
- Entity Name: Flowdesk Omega FZE
- License Number: Pending
- License Issued: Pending
- Licensed Activities: Broker–Dealer Services
- Registered Address: Flowdesk Omega FZE, One Central, Office 08-162, 8th Floor, Trade Centre 2, Dubai
- Responsible Individuals:
- CEO, Flowdesk Omega FZE - Charles Tighe
- Chief Risk Officer - Romain Berry
- Compliance Officer and Money Laundering Reporting Officer, Flowdesk Omega FZE - Anwar Shareef
Privacy Policy
https://www.flowdesk.co/legal/privacy-notice
Risk Disclosure Statement
Virtual Assets Risk Disclosure & Disclaimer
IMPORTANT RISK WARNING – VIRTUAL ASSETS
Virtual Assets may lose their value in part or in full and are subject to extreme volatility. You may lose all the money you pay or contribute. Your exposure to Virtual Assets does not benefit from any form of financial protection.
- Scope and purpose
This Risk Disclosure & Disclaimer (the “Disclosure”) is provided by Flowdesk Omega FZE (“we”, “us”, “our”) for informational purposes and to describe material risks associated with Virtual Assets and Virtual Asset activities, including broker-dealer/execution and liquidity provision/market making (together, the “Services”).
This Disclosure is not exhaustive. Additional risks may arise, and you should obtain independent professional advice (legal, tax, accounting, financial) before transacting.
- No advice; your decision
Unless expressly agreed in writing, we do not provide investment advice, financial advice, legal advice, tax advice, or any recommendation regarding any Virtual Asset, strategy, timing, or transaction. Any decision to transact is made by you at your own risk.
- Core Virtual Asset risks
You acknowledge and agree that Virtual Assets:
- may lose their value in part or in full and are subject to extreme volatility;
- may not always be transferable and some transfers may be irreversible;
- may not be liquid (i.e., you may be unable to buy/sell quickly, at all, or at a desired price);
- may not be private—some transactions are recorded on public distributed ledger technology (DLT);
- may be subject to fraud, manipulation, theft, hacks and other targeted schemes and may not benefit from legal protections you may expect in other markets.
- Market, liquidity, and price formation risks (including liquidity provision)
Virtual Asset markets can be volatile and may be affected by: thin order books, fragmented liquidity, outages, forks, protocol changes, large liquidations, market abuse, and sudden changes in sentiment. Prices may gap and spreads may widen materially, including during stress. Liquidity provision/market making does not guarantee continuous liquidity, any particular spread, or orderly markets, and you may experience slippage.
- Execution, settlement, and transfer risks
Virtual Asset transactions:
- may not be finalised until recorded on the relevant DLT, which may not coincide with the time you initiate the transaction;
- may be irreversible, and losses from fraud, mistaken or unauthorised transactions may not be recoverable;
- may be impacted by technical difficulties (including blockchain congestion, network failures, validator/miner disruptions, or protocol events) that may affect your ability to access or use Virtual Assets.
- Technology and operational risks
The Services rely on technology (including DLT networks, smart contracts, APIs, trading venues, cloud services, wallets, and communications networks) that may fail, be disrupted, or be compromised. Cyberattacks, key compromise, phishing, malware, denial-of-service, and insider threats can result in delay, loss, theft, or unauthorized transactions.
- Custody / wallet and key management risks
Where Virtual Assets are held in wallets (including omnibus or third-party custody arrangements), losses may occur due to hacking, operational errors, insolvency of service providers, or key management failures. You are responsible for understanding whether you or we (or a third party) control relevant private keys and the consequences of that arrangement.
- Counterparty, venue, and third-party risks
Your transactions may involve third parties (exchanges, custodians, liquidity venues, banks, payment providers, blockchain infrastructure providers). These parties may default, suspend services, become insolvent, impose withdrawal limits, experience outages, or be subject to enforcement actions—resulting in delays or loss.
- Conflicts of interest; principal trading; fees
We may act as principal (dealing on our own account) and/or as agent depending on the Service and agreed terms. Our interests may differ from yours (including where we provide quotes, internalise flow, hedge, or manage inventory). Fees, spreads, commissions, mark-ups/mark-downs, funding costs, and other charges may apply as set out in your agreement and/or trade confirmation.
- Regulatory and legal risks
Virtual Asset regulation is evolving and may change rapidly in Dubai, the United Arab Emirates, and other jurisdictions. Changes in law, regulation, or regulatory expectations may restrict the Services, affect market liquidity, require additional disclosures, or result in suspension/termination of products, tokens, venues, or client relationships.
DIFC note: The Dubai International Financial Centre has its own regulatory regime; VARA’s remit is across Dubai’s free zones and mainland excluding DIFC.
- VARA licence status / non-endorsement wording
We are authorised by Dubai Virtual Assets Regulatory Authority (“VARA”) to carry out the licensed activities specified in our VARA authorisation. A VARA licence is not an endorsement of us or any Virtual Asset and must not be construed as such.
- No guarantee; no assurance of profits
We do not guarantee any outcome, return, profit, price, spread, liquidity level, execution quality, or availability of any Virtual Asset or Service. Past performance is not indicative of future results.
- Acknowledgement
By accessing our website, requesting quotes, or entering into a client agreement with us, you confirm that you have read, understood, and accepted this Disclosure and that you are solely responsible for your decisions and transactions.
VA Standards
Flowdesk Omega is committed to maintaining the highest levels of integrity, transparency, and regulatory compliance. In alignment with the standards set forth by the Virtual Assets Regulatory Authority (VARA), Flowdesk Omega adheres to the following Virtual Asset standards when providing services and products to our clients
- Market Analysis: We monitor market capitalization, fully diluted value, and liquidity, tracking whether these metrics trend downward over time.
- Design & Utility: We evaluate the design, technical features, and use cases of each asset, whether intended by the issuer or developed by the community.
- Legal Compliance: We ensure no asset features interfere with our obligations regarding AML/CFT, sanctions, securities, or intellectual property laws.
- Regulatory Status: We track the regulatory treatment of assets by VARA and international authorities, ensuring all necessary approvals are in place.
- Jurisdictional Prohibitions: We verify that no asset we support is prohibited by VARA or other relevant authorities in the jurisdictions where we operate.
- Protocol Security: We assess the security and immutability of the underlying DLT protocol to ensure technical integrity.
- Development Roadmap: We review the future development plans and roadmaps communicated by issuers and developers.
- Market Integrity: We identify assets susceptible to price manipulation and implement robust mitigations to protect our clients.
- Conflict Management: We identify and mitigate any potential or actual conflicts of interest arising from our VA activities.
- Issuer Due Diligence: We vet issuers based on their industry experience and ensure they have no history of fraud or regulatory investigations.
- Rights Enforceability: For assets representing rights to other assets, we confirm that such rights are legally enforceable.
- Obligation Fulfillment: We ensure sufficient assets are available at all times to satisfy our obligations toward our clients.
- Physical Market Alignment: We ensure that VA terms and conditions reflect existing physical markets where applicable to avoid adverse market impacts.
- Periodic Reviews: We regularly review asset terms to ensure they remain correlated and conform to the standards of the relevant physical markets.
Product Terms & Conditions
To be provided by Legal
Docsend link to T&Cs to include: https://docsend.com/view/vbpsahqxq63n7cnt
Complaint Handling
At Flowdesk, we are committed to handling every client concern fairly, transparently, and without delay. Our Complaints Handling Policy sets out clear standards for how complaints are received, investigated, and resolved across our regulated activities.
Clients can raise a complaint at any time through our dedicated email at complaints-omega@flowdesk.co, via through our online form, or in person at our registered office.
Every complaint is acknowledged within one week of receipt, with resolution aimed within four weeks and no later than eight weeks in complex cases ,at no cost to the client.
Complaints are investigated impartially by appropriately skilled staff, with root cause analysis performed on upheld cases to drive continuous improvement across our services.
All complaint records are maintained confidentially in accordance with applicable data protection laws and retained for a minimum of eight years, in line with policy.
ABC Policy
At Flowdesk, zero tolerance for bribery and corruption is not a statement ,it is an operational reality embedded in how we conduct business across every market and jurisdiction in which we operate. Our Anti-Bribery and Corruption Policy sets out the standards we hold ourselves, our people, and everyone who acts on our behalf to, without exception.
The policy applies to all Board members, employees, contractors, and associated persons, as well as all third parties and intermediaries acting for or on behalf of Flowdesk ,across all business activities including market making, OTC trading, and related operations.
No person acting for Flowdesk may offer, promise, give, request, or accept any bribe, directly or indirectly, or seek any improper advantage. This prohibition covers all interactions, whether with private sector counterparties or government officials and public bodies, and applies regardless of whether the conduct is routed through a third party or structured to appear otherwise. Specific conduct that is strictly prohibited includes:
- Bribes and kickbacks in any form
- Facilitation payments, however small
- Improper gifts, hospitality, travel, or entertainment intended to influence a decision
- Sham invoices, off-book arrangements, or falsified records
- Political contributions made on behalf of the company
- Retaliation against anyone who raises a concern in good faith
Where gifts or hospitality are exchanged for legitimate business purposes, they must be reasonable, proportionate, and recorded. Monetary thresholds and prior approval requirements apply, and any item involving a government official is subject to stricter controls regardless of value.
All third parties and intermediaries are subject to risk-based due diligence before engagement and ongoing oversight throughout the relationship. Contracts must include anti-bribery warranties, audit rights, and clear obligations to comply with applicable law. Payments are made only to verified accounts in the name of the contracted entity, and cash or cash-equivalent payments are not permitted.
Concerns about suspected bribery or corruption can be reported confidentially through our whistleblowing channels. All reports are investigated promptly and impartially, and whistleblowers are protected from retaliation. Investigation records and all books and records connected to this policy are retained for a minimum of eight years and are made available to regulators upon request.
Breaches of this policy are treated seriously and may result in disciplinary action up to and including termination, as well as referral to competent authorities where required by law, in line with policy.
Whistleblowing Policy
At Flowdesk, integrity is not just a compliance requirement , it is a core part of how we operate. Across all our global subsidiaries, we are committed to maintaining the highest standards of ethical conduct and transparency, and we recognise that this commitment only holds if people feel safe to speak up when something is wrong.
Our Whistleblowing Policy provides a clear, confidential, and protected framework for anyone connected to Flowdesk ,employees, contractors, partners, or third parties to raise concerns about conduct that falls short of our standards or the law.
Concerns can be raised on any matter relating to Flowdesk's activities, including financial crime such as fraud, bribery, corruption, market abuse, insider trading, or AML/CTF breaches; breaches of regulatory obligations or internal policies including our Code of Conduct, Anti-Bribery Policy, and data protection standards; unethical behaviour, serious misconduct, or gross negligence; discrimination, harassment, bullying, or workplace safety concerns; and any activity likely to cause significant legal, regulatory, or reputational harm to Flowdesk or its clients.
Flowdesk offers several reporting channels, designed to accommodate different preferences while maintaining confidentiality:
Concerns can be raised anonymously. Where contact details are provided, the Whistleblowing Officer will acknowledge receipt within five working days.
Flowdesk strictly prohibits any form of retaliation against anyone who raises a concern in good faith or participates in an investigation. This protection applies regardless of whether the concern is ultimately substantiated. The identity of every whistleblower is protected throughout the process, and information is shared only with those who genuinely need it for investigative or legal purposes.
Every report is reviewed, triaged by risk and urgency, and investigated impartially — with outcomes reported to senior management and, where required, to regulators. All records are maintained securely in line with applicable data protection laws for a minimum of eight years.
Conflict of Interest
At Flowdesk, maintaining objectivity and fair treatment in everything we do is fundamental to how we operate as a Virtual Asset Service Provider. Our Conflicts of Interest Policy establishes a comprehensive framework for identifying, managing, disclosing, and resolving actual or potential conflicts that may arise across our operations, whether in OTC trading, liquidity provision, or any other licensed activity.
The policy applies to everyone connected to Flowdesk, including all directors, Board members, employees, contractors, consultants, and interns.
Flowdesk uses all reasonable efforts to avoid conflicts of interest arising in the first place. Where avoidance is not possible, conflicts are managed, disclosed, and resolved in a way that protects the integrity of the market and the fair treatment of clients. The types of conflicts we actively identify and manage include:
- Trading conflicts, such as those arising between proprietary positions and client orders, price discovery activities, and access to confidential order flow information
- Client-related conflicts, including order allocation, differentiated fee structures, and information asymmetry between clients
- Financial conflicts, such as personal trading by Board members or staff, outside business interests, vendor relationships, and material token holdings
- Governance conflicts, including Board independence, related party transactions, and tensions between regulatory obligations and commercial interests
Preventive measures include strict information barriers, a personal dealing regime, pre-trade conflict checks, segregation of client and proprietary assets, and independent governance oversight. Client virtual assets are always held separately from Flowdesk proprietary assets.
Where a conflict cannot be avoided, Flowdesk provides timely written disclosure to affected clients, describing the nature and extent of the conflict and its potential impact. All disclosures are reviewed by the Compliance function before distribution.
Board members and staff are required to obtain prior written approval before taking up external positions, opening or modifying personal virtual asset holdings, or increasing shareholdings in other entities. annual notifications of all such positions are submitted to the Company, and a comprehensive Conflicts of Interest register is maintained as the central record of all identified conflicts throughout their lifecycle.
Offered Virtual Assets
A summary containing the following information pertaining to each Virtual Asset offered by the VASP shall be published on website.
Pricing & Routing Policy
1. Price Determination
The Company determines prices of Virtual Assets quoted to clients based on proprietary models which include inputs from (but are not limited to):
- External price sources such as exchanges, liquidity providers and bilateral venues
- Company risk position
- Market depth and volatility
- Standard or client-specific configurations, which may be requested by the client
The prices are reflective of client-specific terms and market conditions.
2. Order Routing
The Company does not operate a proprietary exchange or central limit order book. Client orders are routed to external liquidity venues including digital asset exchanges and market makers, with a majority (> 20%) of client orders are routed to our affiliate, Limitless Frontier, Corp, to optimize execution speed and market depth.
Statement & Disclosures
3. Holding of Client Assets and Clearing Services
The Company may hold Virtual Assets on behalf of its clients in the ordinary course of providing Broker-Dealer Services. The Company does not provide clearing services to other VASPs in connection with their own Broker-Dealer Services.
4. Protection of Clients' Ownership of Assets
Client assets are held segregated from the Company's own assets at all times and are not used for proprietary purposes. Client Virtual Assets are held in a Fireblocks MPC workspace, which provides multi-party computation key management ensuring no single point of failure for warm wallet storage. Client assets would not form part of the Company's estate in the event of insolvency.
5. Referral and Introduction Arrangements
The Company does not currently operate any standing arrangement to refer or introduce clients to other entities.
6. Third-Party Accounts
The Company maintains accounts, funds and Virtual Assets with the following third-party service providers: (i) Fireblocks Ltd, which provides MPC wallet infrastructure through which client Virtual Assets are held in warm storage via the Flowdesk group’s Fireblocks workspace; and (ii) various external exchanges, where assets are held temporarily to support active trading activities, or as directed by the client.
By continuing, you acknowledge that you have read and agree to the UAE Disclosures.
