Flowdesk Europe

EU Regulatory Disclosures

Last updated: 8th September 2026

This Regulatory Disclosure & Disclaimer (the “Disclosure”) is provided by Flowdesk Europe SAS, LEI: 984500AB011S3AEF6706 (“Flowdesk Europe,” “we,” “us” or “the Company”) for informational purposes and to describe material risks associated with Crypto-Assets and Crypto-Asset activities.  

Flowdesk Europe is committed to operating in full compliance with the Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) (“MiCA”) and with the requirements of the French Autorité des marchés financiers (“AMF”). 

This page sets out key regulatory information about our authorisation, how we safeguard your Crypto-Assets, and the risks associated with Crypto-Asset services. This Disclosure is not exhaustive. Please read it carefully.  Additional risks may arise, and you should obtain independent professional advice (legal, tax, accounting, financial) before transacting.

*This notice relates solely to Flowdesk Europe and the services it provides under its MiCA authorisation.  Where services are provided through other Flowdesk entities, separate regulatory disclosures apply in the relevant jurisdiction. 

1. Our authorisation

Flowdesk Europe is authorised as a Crypto-Asset Service Provider (CASP) under the Markets in Crypto-Assets Regulation (MiCA) by the French Autorité des marchés financiers (AMF) under the registration number: A2026-022.

Our authorisation covers the following Crypto-Asset services:

  • Providing custody and administration of Crypto-Assets on behalf of clients
  • Exchange of Crypto-Assets for funds
  • Exchange of Crypto-Assets for other Crypto-Assets
  • Execution of orders for Crypto-Assets on behalf of clients
  • Providing transfer services for Crypto-Assets on behalf of clients
    ‍

You can verify our authorisation at any time on ESMA’s Crypto-Asset Service Providers Register or the AMF’s public register of authorised Crypto-Asset service providers, at the entry for Flowdesk Europe SAS: amf-france.org — FLOWDESK EUROPE SAS.  

This authorisation is a regulatory status, not an endorsement. It does not mean that the AMF, or any other competent authority in the European Union, approves of, guarantees, or is otherwise responsible for Flowdesk Europe’s products, services or marketing communications, and it does not guarantee the value, liquidity or safety of any Crypto-Asset.

2. Risk warning: Crypto-Assets

IMPORTANT RISK WARNING: Crypto-Assets are highly volatile and speculative in nature and may lose their value in part or in full. Their value may fluctuate significantly over short periods due to market conditions, changes in supply and demand, technological developments, regulatory changes, and other factors.

By using our services, you acknowledge that transactions involving Crypto-Assets involve a high degree of risk and that you may lose all or part of the money or Crypto-Assets you pay, transfer, or hold. Your exposure to Crypto-Assets does not benefit from any deposit guarantee scheme or investor compensation scheme.  We do not provide investment advice, financial advice, legal advice, tax advice, or any recommendation regarding any Crypto Asset, strategy, timing, or transaction. Any decision to transact is made by you at your own risk.

You acknowledge that we do not guarantee any outcome, return, profit, price, spread, liquidity level, execution quality, or availability of any Crypto-Asset or Service. Past performance is not indicative of future results.

Crypto-Assets are generally not suitable for all persons. Before acquiring, disposing of, or otherwise transacting in Crypto-Assets, you should carefully assess whether such activities are appropriate in light of your investment objectives, financial circumstances, risk tolerance, and level of experience. You should not invest funds that you cannot afford to lose.

You may not be entitled to compensation in the event of losses arising from market movements, the failure of a Crypto-Asset, the insolvency of a service provider, or other adverse events.

In addition to market risk, transactions involving Crypto-Assets may be exposed to liquidity risk, counterparty risk, operational risk, technological risk, cybersecurity risk, fraud, network or protocol failures, and risks associated with distributed ledger technology, including the irreversible nature of blockchain transactions. Regulatory or legislative changes may also materially affect the availability, legality, taxation, transferability, or value of Crypto-Assets.

  • ‍Safeguarding of your Crypto-Assets. Where Flowdesk Europe provides custody and administration of Crypto-Assets, your Crypto-Assets are safeguarded in accordance with applicable MiCA requirements and segregated from Flowdesk Europe’s own assets and, where applicable, those of other clients. Your holdings are separately identifiable in our records. We use institutional-grade wallet infrastructure and multi-party computation (MPC) technology to protect access to Crypto-Assets.
  • If your assets are held with a third party. We may use third-party providers, including custodians, exchanges, trading venues, banks, payment providers and blockchain infrastructure providers. These providers may experience insolvency, outages, cyber incidents, service interruptions or other failures that could delay access to or result in the loss of your Crypto-Assets. We conduct appropriate due diligence and oversight of relevant providers, with the allocation of liability determined by the applicable contractual and regulatory framework.
  • We do not use your assets. We do not lend, pledge, encumber or otherwise use your Crypto-Assets for our own account or for the benefit of others without your prior consent and unless permitted by contractual arrangements or applicable law. Your Crypto-Assets remain your property.
  • Technology and operational risks.  Crypto-Asset 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. If an incident affects your Crypto-Assets, we will notify you promptly according to our incident response and applicable DORA requirements, explaining the nature of the incident, its impact (if any) on your holdings, and the steps we are taking to remediate the situation immediately.

Any information made available through this website is provided for general information purposes only and does not constitute investment advice, financial advice, tax advice, legal advice, a personal recommendation, or an offer or solicitation to buy, sell, or hold any Crypto-Asset.

Although our services are provided in accordance with applicable regulatory requirements, including Regulation (EU) 2023/1114 on markets in Crypto-Assets ("MiCA"), regulatory authorisation does not eliminate the risks associated with Crypto-Assets or guarantee the performance or value of any Crypto-Asset or related service.

3. How we safeguard your Crypto-Assets

Where Crypto-Assets are held in wallets, losses may occur due to hacking, operational errors, insolvency of service providers, or key management failures. You are responsible for understanding whether you, we, or a third party, control relevant private keys and the consequences of that arrangement.

In accordance with Article 70(1) to (3) of MiCA and Article 10(1)(f) of Commission Delegated Regulation (EU) 2025/305, we set out below, the main aspects of the systems, policies and procedures we use to safeguard your Crypto-Assets. This information will be updated whenever we make a material change to our custody arrangements.

For more information, our Custody and Administration Policy is available upon request, in accordance with Article 75(3) of MiCA.

4. Protection of your assets if Flowdesk Europe becomes insolvent

Flowdesk Europe holds your Crypto-Assets on trust for you. Under our standard client agreements, you are entitled to recover your Crypto-Assets in the event of Flowdesk Europe’s insolvency. Your Crypto-Assets are legally and operationally segregated from Flowdesk Europe’s own assets and are not available to our creditors.

5. Conflicts of interest

In accordance with Article 72 of MiCA, Flowdesk Europe maintains and operates a Conflicts of Interest Policy, available upon request, setting out the organisational and administrative arrangements we use to identify, prevent and manage a range of potential conflicts of interest, including:

  • Trading conflicts, including conflicts between proprietary trading positions and client orders, activities relating to price discovery, and access to confidential information concerning client order flow;
  • Client-related conflicts, including those arising from order allocation, differentiated fee structures and information asymmetries between clients;
  • Financial conflicts, including personal dealing by members of the management body or employees, outside business interests, relationships with vendors and material holdings of Crypto-Assets; and
  • Governance conflicts, including matters relating to the independence of the management body, related-party transactions, and potential tensions between regulatory obligations and commercial objectives.

We maintain a range of preventive and mitigating measures designed to identify and manage such conflicts effectively. These measures include information barriers, pre-trade conflict checks, segregation of client Crypto-Assets from proprietary Crypto-Assets, and regular independent oversight by our Compliance function.  In accordance with Article 92 of MiCA, we also maintain systems and procedures to prevent and detect market abuse and report any reasonable suspicion concerning an order or transaction to the AMF without delay.

Where a conflict cannot reasonably be prevented, we note this in our internal register and where appropriate, provide any affected client with timely written disclosure setting out the general nature and sources of the conflict, the risks it may create for the client, and the measures implemented to mitigate those risks. All such disclosures are subject to review and approval by Compliance prior to issuance.

6. Whistleblowing

At Flowdesk, integrity 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, via email: whistleblowing@flowdesk.co, 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.

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.

7. Price Determination

The Company determines prices of Crypto-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.  Details of our pricing, costs and fees are available as part of your client agreement.

8. Approved and Restricted Jurisdictions

Flowdesk Europe’s services are made available only to clients established, registered and/or located in jurisdictions approved for the provision of such services, subject to the successful completion of Flowdesk Europe’s KYC/KYB and jurisdictional screening procedures.

Flowdesk Europe does not provide its services to clients established, registered and/or located in jurisdictions subject to applicable sanctions or restrictions, or those identified as high-risk or non-cooperative by the Financial Action Task Force (FATF), the European Commission or other competent authorities, where such designation restricts the provision of the relevant services.To enforce these jurisdictional restrictions at the point of access, Flowdesk Europe applies appropriate technical and operational controls, including restrictions on access to its website and platform from sanctioned, prohibited or otherwise restricted countries, territories and jurisdictions, in accordance with its applicable jurisdictional screening framework.

9. Complaints

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.  If you are unhappy with any aspect of our service, a complaint can be filed and handled free of charge, using our complaints form below. We investigate all complaints fairly and promptly and will communicate the outcome to you within a reasonable period, in accordance with Article 71 of MiCA.


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, in line with our policy.

10. Sustainability 

Crypto-Assets involved in any service provided by Flowdesk Europe are determined by client instruction.  Certain Crypto-Assets use consensus mechanisms (such as proof-of-work or proof-of-stake) that may have associated climate and other environment-related impacts, including energy consumption, greenhouse gas emissions and electronic waste. Flowdesk Europe has regard to such factors, where relevant information is made available by Crypto-Asset issuers or other reliable public sources. They provide information on the principal adverse climate and other environment-related impacts of the consensus mechanism used and reflect the best information available. These documents are used for compliance purposes and are not endorsements or representations of the environmental performance of any Crypto-Asset.

11. How to contact us

If you have any questions about these Terms, please contact us at:  Flowdesk Europe SAS, 231 Rue Saint-Honoré, 75001 Paris, France.  SIREN: 998951883.  Email: legal@flowdesk.co. 

For the purposes of formal legal notices, any notice or communication under these Terms must be made in writing and sent either to the registered address above or by email to legal@flowdesk.co. Unless otherwise required by applicable law, such notices will be deemed received on the next Business Day following transmission.

12. Governing law

This notice, and any dispute or claim arising out of or in connection with it or its subject matter (including non-contractual disputes or claims), shall be governed by and construed in accordance with French law. The courts of Paris, France shall have exclusive jurisdiction to settle any such dispute or claim, subject to any mandatory consumer-protection or other rules that cannot be excluded or varied by agreement.

13. Regulatory and Legal Risks

Changes in law, regulation, or regulatory expectations may restrict the Services, affect market liquidity, require additional disclosures, or result in suspension/termination of services, venues, or client relationships.

14. Acknowledgment 

By accessing our website, requesting quotes, or entering into a client agreement with us, you confirm that you have read, understood, and accepted these terms and that you are solely responsible for your decisions and transactions.

15. Updates to this Disclosure

We reserve the right to amend or update this Disclosure at any time. The most current version will be made available on this website. For all other terms, conditions, and policies applicable to your use of the website and services, please refer to our: Privacy Policy, Cookies Policy, Disclosures, and Terms of Use.  

Important information for visitors in the UAE

Corporate Information Disclosure

Flowdesk Omega FZE is committed to transparency and compliance with all regulatory requirements.

  • Entity Name: Flowdesk Omega FZE
  • License Number: VL/26/08/001
  • License Issued On: 7th August 2026
  • Licensed Activities: Broker–Dealer Services
  • Registered Address: Flowdesk Omega FZE, One Central, Office 08-162, 8th Floor, Trade Centre 2, Dubai
  • Responsible Individual
    • General Manager - Charles Tighe
    • Chief Risk Officer - Romain Berry
    • Compliance Officer and Money Laundering Reporting Officer - Anwar Shareef

Privacy Policy

The privacy policy can be accesssed through this link.

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.

  1. 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.

  1. 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.

  1. 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. 
  1. 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.

  1. 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. 
  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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 FZE 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 FZE 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

Terms and conditions can be accessed through this link.

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 information pertaining to each Virtual Asset offered by Flowdesk Omega FZE is published on our 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 Regulatory Disclosures.

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Disclaimer