Conflict of Interest Public Policy

The company has assessed and mapped out potential conflict of interest situations arising in its operations. The company has followed the principle of proportionality in its assessment. It has also taken into account the scope, nature, and range of crypto-asset services it provides, in accordance with Article 72(1) of Regulation (EU) 2023/1114.

The assessment has considered that the company no longer engages in ordinary business operations but is winding down its activities. Therefore, the company no longer has a typical competitive position with other companies, and related conflicts of interest are not relevant for the company. The company also does not offer any trading, execute orders on behalf of clients, provide investment advice, or issue new cryptocurrencies, which significantly reduces the potential for conflicts of interest between the company's employees and its customers. The company only offers asset custody services and the possibility for customers to withdraw their assets from the service.

On the other hand, the company has recognized that the client's interests must be protected, and client relationship management, customer service, or the equal treatment of clients must not suffer due to conflict of interest situations. Furthermore, no conflict of interest may adversely affect the protection of client assets, the company's continuity, or the sufficiency of financial resources.

The company has identified the following conflict of interest as the most relevant for its customers:

The company does not allow customers to withdraw their assets, which results in the collection of more administration fees. This also involves the customer's right to withdraw assets and, on the other hand, the company's obligation to identify and know its customers, and the conflict arising from this. This conflict of interest is managed by the company by not collecting administration fees from the customer if the customer is actively trying to withdraw funds from the service. This removes the company's financial interest in preventing the customer from withdrawing their assets. In addition, the company's goal is to wind down operations and get customers to withdraw their assets.

If a conflict of interest situation is identified, it should be reported to compliance@localbitcoins.com.