Summary of the Exchange of Crypto-Assets Policy

Last updated: 31. August 2025

Purpose

This policy establishes the procedures and governance mechanisms under which Floin conducts the exchange of crypto-assets for funds and other crypto-assets, in compliance with MiCAR Article 77 and Delegated Regulation (EU) 2025/305 Article 14.

1. System Architecture and Execution Method

Floin operates an internal exchange engine connected to external oracles and liquidity providers. The engine executes trades automatically based on client instructions, using smart routing to determine optimal execution channels. Failover mechanisms and latency thresholds are in place. Trade execution is time-stamped and stored in a write-once audit ledger.

Floin continuously monitors its exchange systems to ensure reliability.

2. Price Determination and Reference Sources

Floin determines exchange prices using real-time market data from Kraken, our primary trading partner. This ensures that the prices you see on our platform are aligned with live market conditions and based on a trusted source.

  • Quotes include all costs: Each price shown to you includes a markup, a service fee, and the estimated blockchain network fee. This way, you always see the full cost of your transaction upfront. For a complete breakdown of our fees and markups, please see our Fee Schedule.

  • Consistent for all clients: Prices are applied uniformly and do not change depending on client type or transaction size. Every customer has access to the same transparent pricing structure.

  • Reliable and traceable: All prices and transactions are logged and stored in our systems, ensuring reliability and enabling full auditability in line with regulatory standards.

Manual price overrides are not permitted unless triggered by a governance flag and require dual approval.

3. Client Instruction Handling

Orders can be placed through our app or web platform. The system validates:

  • Token availability and eligibility

  • Client’s KYC status and wallet whitelisting

  • Trading limits and balance sufficiency

Orders that breach thresholds are automatically rejected or sent to manual review queue.

All instructions and rejections are logged with timestamps and reviewer IDs.

4. Publication and Transparency

Executed prices and rolling volume statistics are published on Floin’s website via a public dashboard, as required under Article 77 of MiCAR. The pricing methodology and latest reference source list are included in the Pricing FAQ.

6. Record Retention

All records are retained for at least 5 years in tamper-evident storage in line with MiCAR Art. 68 and Delegated Regulation Art. 4.