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LUNARARK DMCC (“Lunarark”) provides ‘Broker Dealer Services’ for virtual assets and is licensed by the Virtual Assets Regulatory Authority (“VARA”) in Dubai, United Arab Emirates. These public disclosures (“Public Disclosures”) have been developed for Lunarark. These Public Disclosures are reviewed annually, unless there is a change in regulation or Lunarark’s business that requires to implement an earlier update.

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LICENSE DETAILS

Lunarark has been granted a Virtual Asset Service Provider (“VASP”) license by VARA to operate as a ‘Broker-Dealer’ in the emirate of Dubai, United Arab Emirates. Lunarark’s license number is as follows: [to be inserted once license is issued] and is valid for the period starting from [insert start date] to [insert end date].

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CONFLICT OF INTEREST 

Lunarark is committed to conducting its business according to the principle that it must manage any conflicts of interest appropriately.At present there are no actual or potential, identified conflicts of interest arising out of Lunarark’s Broker Dealer Services. Lunarark has and will continue to identify potential conflicts of interest on all fronts, including those arising out of its outsourcing arrangements with group entities. 

Lunarark shall adopt certain controls and measures to manage any actual or potential

conflicts of interest identified which include but are not limited to:

  ·    Policies, procedures, systems and controls implemented by the Company including but not limited to the implementation of information barriers between different business activities where the exchange of that information may impact/harm the interests of clients;

   ·    Segregation of duties for persons engaged in business operations and a maker checker process to be followed;

   ·    Provision of conflicts of interest training to all Employees on joining the Company and periodically thereafter;

   ·    Provision of conflicts of interest training to all directors on joining the Board and periodically thereafter;

   ·    Regular reporting of findings and recommendations related to conflicts of interest between the Group Entities;

   ·    Taking the client’s prior permission for an activity or matter that could give rise to a conflict of interest where the conflict of interest cannot be prevented or managed effectively using other means.

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PRIVACY

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Lunarark appreciates you trusting us with your personal data. We are committed to protecting your privacy. For more details on how we collect and process your personal data, you can access our Privacy Policy at https://www.lunarark.ae

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COMPLAINTS AND WHISTLEBLOWING

Complaints: Lunarark is committed to promoting fair treatment of customers through consistent, structured, and effective internal measures. These measures ensure that customers and potential customers have appropriate access to recourse within the Company and with regulatory authorities. Acting with honesty, justice, and equity, the Company always prioritises the best interests of its customers while maintaining market integrity. To that end, Lunarark has formulated and implemented a comprehensive complaints handling procedure. 

Complainants can make a complaint in writing by letter to: One JLT, Jumeirah Lake Towers, Dubai, PO BOX 451805, via email at Clientservices@Lunarark.ae or via the clients preferred method of communication channel i.e. Telegram. Contact details are also provided on the Company’s website at https://www.lunarark.ae.  

Whistleblowing: Lunarark is committed to the highest standards of integrity, accountability, and transparency. An important aspect of this commitment is establishing a mechanism to enable every person serving or connected to the Company to voice concerns in a responsible and effective manner. If you seek to raise any concerns, you can write to us at Compliance@lunarark.ae anonymously. You can also write to Compliance@lunarark.ae for a copy of our whistleblowing policy. 

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RISK 

Virtual assets and their transactions are subject to several risks, including but not limited to market risks, credit risks, liquidity risks, and technology risks. Please read our detailed Risk Disclosure Statement at https://www.lunarark.ae for more information on the risks associated with virtual asset. 

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SERVICES 

Lunarark provides Broker Dealer Services in relation to the virtual assets specified in the below table (collectively referred to as “Virtual Assets”). 

Lunarark does so by arranging orders for the purchase and sale of Virtual Assets between two entities or persons; soliciting or accepting orders for Virtual Assets by accepting fiat currency or other Virtual Assets for such orders; and entering into virtual asset transactions as a dealer on behalf of an entity for its own account (collectively the “Services”).  

The list of Virtual Assets and Services offered by Lunarark is constantly evolving and if we add, modify, amend or otherwise change a Service, or amend the list of supported Virtual Assets, in whole or in part, we will update the website accordingly. Lunarark will update its website on an ongoing basis with current details of the Virtual Assets it trades in including details of the name of the token, abbreviation, issuance date, market capitalization, circulating supply, date of last independent smart contract and largest price reduction.  

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Virtual Assets Offered

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RESPONSIBLE INDIVIDUALS

In accordance with applicable laws and regulations, Lunarark has appointed the following two (2) individuals who are senior officials at Lunarark as responsible parties to ensure Lunarark’s compliance with all legal and regulatory obligations:

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PRICING

The prices of the virtual assets quotes to our clients are determined by Lunarark, considering the following:  

1.     External price sources from liquidity providers; 

2.     The current risk position of Lunarark; and 

3.     Per-client configurations, determined by Lunarark or, in some cases, at the request of the client. 

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EXECUTION & ROUTING 

Client orders will always be executed by Lunarark one xecution venues which Lunarark chooses. Lunarark may act as an agent or as a principal to fulfill its client orders. The decision to act either as an agent or a principal is determined by a multitude of factors, which are listed in our internal policies. Lunarark will notify its clients with whom it has an ongoing business relationship of any material changes to its order execution policy or arrangements.  

A description of Lunarark’s order execution and routing practices may be sought by clients by writing to Compliance@lunarark.ae.         

In the event Lunarark routes twenty percent (20%) or more of its orders to any single liquidity provider, the identity of such sources will be updated below:

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Lunarark does not introduce or refer its clients to any other entities including other virtual asset service providers.

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Lunarark does not introduce or refer its clients to any other entities including other virtual asset service providers.

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HOLDING AND CONTROLLING CLIENT MONEY 

Lunarark does not offer custody services in relation to virtual assets for its clients. However, in the process of providing its services, Lunarark may hold or control Client Money (as defined in the VARACompliance and Risk Management Rulebook). This Client Money will be held in dedicated Client Accounts (as defined in the VARA Compliance and RiskManagement Rulebook) in accordance with applicable laws and regulation. ClientMoney held with designated licensed financial institutions licensed in the UAE, that are well versed with handling of Client Money.

Lunarark shall ensure that Client Money is always identifiable and secure. Lunarark shall ensure compliance with all applicable law and regulations in handling and controlling Client Money including formulating and implementing the necessary policies, systems and controls, appropriate to the nature and scale of Lunarark’s operations. Lunarark’s own operational funds accounts will not be commingled with the Client Money. 

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HOLDING AND CONTROLLING CLIENT ASSETS

Lunarark does not offer custody of Client VAs (as defined in the VARA Compliance and Risk Management Rulebook). Fireblocks LLC custodiesClient VAs in line with its own regulatory approvals. Lunarark only takes custody of Client VAs in the course of providing its Broker Dealer Services. 

Among the key arrangements envisaged to this end, Lunarark selects custodians only after having performed due diligence on such service providers. This entails an analysis on the regulatory status, internal approvals processes, and risk management practices. Lunarark intends to appoint only entities ensuring asset segregation or equivalent safeguards for longterm custody purposes. Lunarark will conduct such due diligence on its service providers on a regular basis, to ensure the regulatory status of the service provider.  

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STATEMENTS BY LUNARARK

Lunarark does not hold or maintain funds or Virtual Assets or provide clearing services for other VASPs.