STIX OTC FZE (“STIX”, “we”, “us” or the “Company”) is licensed and regulated by the Dubai Virtual Assets Regulatory Authority (“VARA”) to engage in the regulated activities of providing ‘Broker Dealer’ and ‘Advisory’ services for a period of [To Be Inserted]. These public disclosures (“Public Disclosures”) are reviewed annually unless there is a change in applicable laws due to which the Company may be required to implement an earlier update.
STIX endeavours to ensure that its public disclosure practices are in compliance with the regulatory framework of the Virtual Assets Regulatory Authority (“VARA”), including, inter alia, the Virtual Assets and Related Activities Regulations 2023_ (the “VARA Regulations”), and the accompanying rulebooks (“Rulebooks”) issued by VARA. All capitalised terms, if not defined in this document, have the same meaning ascribed to them in the VARA Regulations or the accompanying Rulebooks.
1.1. STIX is committed to conducting its business according to the principle that it must manage conflicts of interest appropriately. At present, STIX identifies potential conflicts of interest arising out of the Company’s ‘Broker Dealer’ and ‘Advisory’ services and has put in place internal mechanisms and guardrails to ensure that no conflicts arise and mechanisms for managing conflicts of interest should a conflict arise.
1.2. The below table comprehensively captures the nature of the conflict of interest arising out of the Company’s activities and the implemented management and remedial measures.
| Nature of Potential Conflict of Interest | Date of Declaration | Management Measure |
|---|---|---|
| Biased Recommendations: Advisors might recommend Virtual Assets that are traded through the brokerage division to increase commission revenue from transactions. | Not arisen | STIX will: transparently disclose to Clients the dual role of the Company in both advisory and brokerage services. clearly explain the potential conflicts of interest and how they are managed - i.e., through separation of functions and independent oversight by the Chief Risk and Compliance Officer. |
| Fee Structure Conflicts: The advisory division may prefer recommending frequent transactions to generate more brokerage commissions. | Not arisen | STIX will: implement transparent and standardized fee structures for both advisory and brokerage services; and ensure that advisory fees are not directly linked to brokerage commissions to avoid incentivizing biased recommendations. |
| Information Asymmetry: Advisors might have access to confidential information from the brokerage division that could unfairly influence their advice. | Not arisen | STIX will: implement a strict separation between the advisory and brokerage divisions, including separate management, teams, and information systems. Ensure that advisors and brokers do not share sensitive information that could influence their respective activities. |
1.3. STIX has and will continue to identify potential conflicts of interest arising out of its outsourcing arrangements with group entities. For more details, you can access our Conflict of Interest Policy by writing to us at legal@stix.co.
2.1. STIX appreciates you trusting us with your personal data. We are committed to protecting your privacy. For more details, you can access our Privacy Policy, the Client Agreement and the Terms of Use.
3.1. STIX is committed to promptly, fairly, consistently, and efficiently resolving all complaints received by Clients and/or other stakeholders. STIX views complaints from its Clients and stakeholders as an opportunity to complete the loop, and continually improve the quality of its services. To that end, STIX has formulated and implemented comprehensive complaints handling procedures. If you seek to make any complaints, you can write to us at legal@stix.co.
3.2. STIX is committed to the highest standards of integrity, accountability, and transparency. STIX seeks to be responsive to all employees and stakeholders, be seen as a trusted organisation that treats its employees with respect, demonstrate commitment to its own policies, applicable laws and regulations, and strengthen the “speak up” culture. An important aspect of this is a mechanism to enable the voicing of concerns in a responsible and effective manner. If you are an employee of STIX or a stakeholder and seek to raise any concerns, you can write to us at legal@stix.co anonymously. You can also write to legal@stix.co for a copy of our whistleblower policy.
4.1. Virtual Assets and Product 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 for more information in this respect.
5.1. STIX provides (a) Broker-Dealer Services; and (b) Advisory Services, in and from the Emirate of Dubai to Qualified and Institutional Investors (“Clients”). STIX operates a digital platform (https://app.stix.co) (“Platform”) which will facilitate transactions between buyers and sellers of (a) specified crypto tokens; or (b) contractual instruments that give the holders entitlement to tokens (such as Simple Agreement for Future Tokens (“SAFTs”) or Token Purchase Agreements (“TPAs”) (“Associated Contractual Rights”) (collectively the “Products”). In particular, STIX operates an arranging platform to ‘facilitate’ or ‘bring about’ transactions between buyers and sellers who hold large stakes in specified tokens or who hold Associated Contractual Rights. Specifically, STIX wishes to engage in the following regulated activities within the definition of the term ‘Broker-Dealer Services’ under the Regulations: “Arrange orders for the purchase and sale of tokens (or Associated Contractual Rights) between two entities”.
5.2. As part of its Advisory Services, STIX provides analytics and proprietary insights and research to its Clients. STIX shares the pros and cons of Products listed on the Platform and makes recommendations to its Clients to ensure a comprehensive suite of services. The Products may be Virtual Assets which have not been issued at the time of their listing on the Platform. However, the Company will ensure that such Virtual Assets also meet the Company’s virtual asset listing standards. The Company’s Virtual Assets Listing Standards are available at
5.3. STIX, as part of its Broker Dealer and Advisory services, will refer and/or introduce Clients to each other as well as other entities, including but not limited to other virtual asset service providers, for monetary benefit. Any monetary benefit and/or fees STIX receives are clearly set out in STIX’s Client agreement which all Clients must enter into as part of their on-boarding process. Should STIX update its fees, it will provide adequate notice of such change, in accordance with the Client agreement.
5.4. To ensure independence and mitigate any potential conflict of interests, the teams headed by the Head of Advisory and the Head of Institutional Sales will not be permitted to share confidential information relating to Clients between themselves. The Company will institute Role Based Access Control (RBAC) Mechanisms to ensure that files pertaining the Clients onboarded for Advisory Services are not accessible to STIX team members who provide services to Broker-Dealer Clients and vice versa. This will include segregated drives and folders for data storage by the respective teams, which are not accessible to each other.
5.5. The list of Virtual Assets and Products available on the Platform is constantly evolving and our website will be updated as required:
| Name of the Product |
|---|
| Eigenlayer |
| Celestia |
| Manta Network |
| Fuel Network |
| Etherfi |
| Ethena |
| Scroll |
| zkSync |
| LayerZero |
| RISC Zero |
| Altlayer |
| Berachain |
| Anoma |
| Aleo |
| Ceramic |
| Space and Time |
| Starkware |
| Kakarot |
| Sui |
| GenSyn |
| Ondo Finance |
| DELV |
| Sei Network |
| Flashbots |
| Wormhole |
5.6. STIX will provide in a prominent manner on its Platform, available information pertaining to Virtual Assets and Products available on the Platform. This includes, but is not limited to:
(a). Name and symbol;
(b). date of issuance;
(c). market capitalization and fully diluted value;
(d). circulating supply including as a percentage of the maximum total supply (if applicable);
(e). largest reduction in price from high to low stated as both an absolute amount and a percentage change, including when it occurred; and
(f). information that can be found via publicly available data sources such as CoinMarketCap.
6.1. STIX does not quote prices of the Products available on the Platform. Sellers who list their Products on the Platform determine the price. The seller sets a reserve price which is the lowest price at which a seller is willing to sell the Product. The Platform contains a bidding mechanism that enables potential buyers to place bids (indicating their interest) to purchase a Product and the seller can choose which bid they wish to accept (irrespective of price).
7.1. STIX’s services are limited to arranging transactions between the buyers and sellers and related advisory services for the Products. STIX does NOT: (i) operate as a crypto exchange; (ii) facilitate automatic matching of transactions; (iii) enter into transactions as a dealer for its own account; or (iv) make a market in tokens using Client Assets.
8.1. In the process of providing its services, STIX does NOT handle, hold, control or manage Client Assets or Client Money, whether in fiat form or otherwise. STIX does NOT maintain or provide clearing services for other VASPs. Client Money and Client Assets are directly transferred between the buyer and the seller. The buyer only notifies STIX about the receipt of the product from the seller and simultaneously the seller receives the relevant funds (i.e., the consideration for the sale) from the buyer.
9.1. STIX and any member(s) of its Senior Management or Board have not faced any past convictions or prosecutions, whether before the courts of the UAE or the courts of another jurisdiction.
10.1. STIX has appointed the following persons as Responsible Individuals:
(a). Taranveer Sabharwal (Chief Executive Officer); and
(b). Vivek Prasad (Chief Risk and Compliance Officer).
11.1. STIX does not have any accounts, funds or virtual assets maintained by a third party, apart from those as maybe required to provides its Services.