Legal & Compliance

Regulatory
Framework

Bequant operates through two regulated entities. Each entity maintains its own legal and compliance documentation, with shared policies applicable across the group.

Bequant Pro Limited
Company No. C 88065 · Malta
MFSA Authorised · VFA – MiCA conversion
Est. 2018
Bequant Prime Limited
Company No. 218593 · Seychelles
FSA VASP Licence Application
Pending approval
Entity 01

Bequant Pro Limited
MFSA Authorised · Company No. C 88065 · Malta

Bequant Pro Limited (“Bequant Pro” or “BEQUANT PRO”) is a private limited company incorporated in Malta (Company No. C 88065) with its registered and principal place of business at The Core, Valley Road, Msida, MSD 9021, Malta.

BEQUANT PRO currently holds a Class 3 Virtual Financial Assets (VFA) Licence (No. VFA/06), issued by the Malta Financial Services Authority on 28 April 2021, authorising: custodian or nominee services; reception and transmission of orders; execution of orders; dealing on own account; and placing of virtual financial assets.

As at the date of these disclosures, BEQUANT PRO conducts over-the-counter (OTC) services only, as permitted under the Licence and as specified in the Terms of Business. Bequant applied for MiCA authorisation on 29 July 2025 and continues to operate under the applicable transitional (grandfathering) regime until 30 June 2026. Upon granting of MiCA authorisation, the VFA Licence shall be terminated.

Legal enquiries: compliance@bequant.io · legal@bequant.io

Document 1 of 5

Terms of Business

Terms of Business – Bequant Pro
BQ Pro · ToB · Effective 08 April 2026
View document →
These Terms of Business govern the provision of OTC crypto-asset services by Bequant Pro Limited to institutional counterparties. By accessing Bequant's services, clients agree to be bound by these Terms in their entirety.
Entity
Bequant Pro Limited · C 88065 · Malta
Registered Office
The Core, Valley Road, Msida, MSD 9021, Malta
Services Scope
Over-the-counter (OTC) crypto-asset trading
Current Licence
VFA Licence No. VFA/06 · MiCA authorisation pending
Governing Law
Laws of Malta; MiCA transitional regime
Dispute Resolution
LCIA arbitration · Seat of arbitration: London · English law

The Terms of Business set out Bequant Pro's regulatory status, the scope and conditions of services provided, client obligations, risk acknowledgements, fee structures, and procedures for termination and dispute resolution. All clients are required to complete institutional KYC/AML onboarding prior to the commencement of any services.

Document 2 of 5

Conflicts of Interest Disclosure

Conflicts of Interest Disclosure – Bequant Pro
MiCA Article 72(2) · CDR (EU) 2025/1142 · 08 April 2026
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Published pursuant to Article 72(2) of Regulation (EU) 2023/1114 (MiCA) and Commission Delegated Regulation (EU) 2025/1142. This disclosure is reviewed and updated at least annually by the Compliance Officer and approved by the board.

Identified Conflict

The Ultimate Beneficial Owner (UBO) of Bequant Pro Limited is also the Chief Executive Officer (CEO) of the company. This dual role creates a potential conflict between the personal financial interests of the UBO/CEO and the obligation to act in the best interests of clients at all times.

Mitigation Measures

  1. Written Conflicts of Interest Policy, reviewed and approved by the board at least annually.
  2. Conflicts Register maintained and updated upon identification of any new or changed conflict.
  3. Information barriers (Chinese walls) between proprietary trading activities and client-facing operations to prevent the flow of confidential information.
  4. Mandatory pre-service disclosure to all clients of identified material conflicts prior to service commencement.
  5. Independent compliance function with direct reporting line to the board, operating separately from commercial activities.
  6. Prohibition on personal account dealing in instruments or positions that could disadvantage client interests.
  7. Defined escalation procedure for conflicts that cannot be adequately managed by existing controls, requiring board-level resolution.
  8. Mandatory annual training for all staff on conflicts of interest recognition, management, and escalation obligations.
  9. Remuneration structures reviewed annually to ensure no incentive arrangements create misaligned interests with client obligations.
  10. Annual board review and formal sign-off on the updated Conflicts Register, with a summary included in the annual compliance report.
Document 3 of 5

Sustainability Disclosures

Sustainability Disclosures – Bequant Pro
MiCA Article 66(5) · CDR (EU) 2025/422 · 08 April 2026
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Published pursuant to Article 66(5) of Regulation (EU) 2023/1114 (MiCA) and Commission Delegated Regulation (EU) 2025/422.
Reference period: 1 January 2025 – 31 December 2025.

Covered Crypto-Assets (15 Networks)

Sustainability disclosures are published for the following 15 crypto-asset networks traded or custodied by Bequant Pro during the reference period:

BTC
ETH
LTC
BCH
DOGE
ETC
SOL
BNB
ADA
TRX
AVAX
DOT
TON
ATOM
NEAR

The full disclosures include principal adverse impact indicators covering energy consumption (kWh), greenhouse gas emissions (tCO₂eq), renewable energy share (%), and waste electrical equipment metrics for each network, prepared using the MiCA Delegated Regulation templates.

Bequant Pro does not itself operate mining, staking, or validator infrastructure. Network data is sourced from publicly available disclosures and is reviewed at least annually. Contact: compliance@bequant.pro

Documents 4 & 5 of 5

Complaints Handling

Complaints Handling Procedure – Bequant Pro
MiCA Article 71 · CDR (EU) 2025/294 · 08 April 2026
View document →
Complaints Form – English and Maltese Languages
CDR (EU) 2025/294 · Annex Template · 08 April 2026
View document →
Acknowledgement
3 days
Written acknowledgement within 3 working days of receipt
Full Response
15 days
Full investigation and substantive response within 15 working days
Submit by Email
compliance@bequant.pro
Submit by Post
FAO: Head of Compliance
Bequant Pro Limited
The Core, Valley Road, Msida, MSD 9021, Malta

Complaints may be submitted in English or Maltese using the Complaints Form above. Bequant Pro will acknowledge all complaints in writing within 3 working days and provide a full substantive response within 15 working days. In complex cases, the client will be notified of any extended timeline.

If dissatisfied with Bequant Pro's response, clients may escalate to the Office of the Arbiter for Financial Services, Valletta, Malta.

Entity 02

Bequant Prime Limited
FSA Seychelles · Company No. 218593 · VASP Licence Application Pending

Bequant Prime Limited (“BEQUANT PRIME”) is incorporated in the Republic of Seychelles (Company No. 218593) with its registered address at Suite 3, Global Village, Jivan's Complex, Mont Fleuri, Mahé, Republic of Seychelles. The company operates bequant.pro and bequant.io under the registered trademark “Bequant”.

Trading, custody, prime brokerage and lending services related to digital assets are regulated in Seychelles as of 2024 under the Virtual Asset Service Providers Act (VASP Act). BEQUANT PRIME has submitted its VASP licence application to the Financial Services Authority (FSA). As per Section 42 of the VASP Act 2024, entities that submitted a completed application during the transitional period may continue operations until the FSA communicates its decision. The FSA has confirmed BEQUANT PRIME's application has progressed to the assessment stage.

Legal enquiries: compliance@bequant.io · legal@bequant.io

Document

Terms of Business

Terms of Business – Bequant Prime
BQ Prime · ToB · Effective 09 April 2026
View document →
The Terms of Business govern the provision of digital asset services by Bequant Prime Limited to institutional counterparties under the VASP Act 2024 (Seychelles).
Entity
Bequant Prime Limited · Company No. 218593
Registered Office
Suite 3, Global Village, Jivan's Complex, Mont Fleuri, Mahé, Seychelles
Regulation
VASP Act 2024 (Seychelles) · FSA · Application pending
Governing Law
Laws of the Republic of Seychelles

Service Schedules

The Terms of Business comprise four service schedules, each governing a distinct service line:

Schedule ACustody Services
Safekeeping and administration of digital assets on behalf of institutional clients, including sub-custody and segregated account arrangements.
Schedule BOTC Trading
Over-the-counter block trade execution across 200+ digital asset pairs with fiat settlement in EUR, USD, GBP and AED.
Schedule CPrime Brokerage
Integrated prime infrastructure: margin lending, cross-venue collateral management, FIX API connectivity and risk monitoring.
Schedule DClearLoop Settlement
Off-exchange settlement via ClearLoop — trade on-exchange while assets remain in regulated off-exchange custody.
Regulatory

Regulatory Information

Entity
Bequant Prime Limited · Company No. 218593 · Seychelles
Regulator
Financial Services Authority · Bois De Rose Avenue, Victoria, Mahé
Licence Status
VASP application submitted · Progressed to assessment stage · Pending approval
Framework
Virtual Asset Service Providers Act 2024 (Seychelles) · Section 42 Transitional Provisions
AML & KYC

AML & KYC Policy

Seychelles AML requirements under the Anti-Money Laundering Act 2020 and VASP regulations apply to Bequant Prime Limited. Pending formal licence, equivalent CDD/EDD procedures aligned to FATF Recommendations are applied across all client relationships.

All clients undergo comprehensive due diligence including: verification of legal entity identity and corporate structure; identification of Ultimate Beneficial Owners (UBOs ≥25%); verification of directors and authorised signatories; assessment of source of funds and wealth; and ongoing transaction monitoring and screening against UN, EU, OFAC and relevant national sanctions lists.

Complaints

Complaints Handling

Submit by Email
compliance@bequant.io

Formal complaints procedures for Bequant Prime will be published in full upon VASP licence approval by the FSA Seychelles. In the interim, all enquiries and complaints should be directed to the compliance email above. All complaints are acknowledged within 3 working days and investigated without undue delay.

Bequant Pro & Bequant Prime

Website Risk Disclosure

Website Risk Disclosure Statement
Bequant Pro & Bequant Prime · 08 April 2026
View document →
This Website Risk Disclosure applies to both Bequant Pro Limited (Malta) and Bequant Prime Limited (Seychelles) and all services operated under the Bequant brand. Digital asset trading and related services involve significant risks. The full disclosure identifies 29 distinct risk categories. Services are provided to institutional and professional counterparties only.

Principal Risk Categories

Market & Price Risks
  • Price Volatility
  • Liquidity Risk
  • Market Manipulation
  • Leverage & Margin Risk
  • Exchange Rate Risk
Regulatory & Legal Risks
  • Regulatory Change Risk
  • Jurisdictional Risk
  • Tax Treatment Risk
  • AML / Sanctions Risk
  • Insolvency Risk
Technology Risks
  • Cybersecurity Risk
  • Technology & System Failure
  • Smart Contract / Protocol Risk
  • Fork & Network Upgrade Risk
  • Wallet & Private Key Risk
Counterparty & Operational
  • Counterparty Risk
  • Custody Risk
  • Settlement Risk
  • Operational Risk
  • Key Person Risk
Macro & Environmental Risks
  • Energy & Environmental Risk
  • Political & Geopolitical Risk
  • Force Majeure
  • Concentration Risk
  • Information Asymmetry
Investor Protection Notices
  • No Regulatory Compensation Scheme
  • No Guarantee of Returns
  • Past Performance Not Indicative
  • Suitability: Institutional Clients Only

The full Website Risk Disclosure Statement should be read in its entirety before engaging with any Bequant service. This summary does not constitute the full disclosure. Digital asset prices can be highly volatile and you may lose all capital invested.

Bequant Pro & Bequant Prime

Privacy Policy

Privacy Policy
Bequant Pro & Bequant Prime · GDPR (EU) 2016/679 · 08 April 2026
View document →
This Privacy Policy applies to both Bequant Pro Limited (Malta — data controller under GDPR Regulation (EU) 2016/679) and Bequant Prime Limited (Seychelles). Privacy enquiries: compliance@bequant.io

Data We Collect

Identity Data
Name, date of birth, nationality, passport or government-issued ID
Contact Data
Email address, telephone number, postal address
Financial Data
Bank account details, transaction history, source of funds and wealth
KYC / AML Data
Verification documents, UBO declarations, sanctions and PEP screening results
Technical Data
IP address, device identifiers, browser type and version, login timestamps
Usage Data
Website browsing behaviour, service usage patterns, session and interaction data

Legal Bases for Processing

  • Contract performance — processing necessary to deliver services under the Terms of Business.
  • Legal obligation — AML/KYC obligations under PMLA (Malta), VFAA, MiCA, and VASP Act (Seychelles).
  • Legitimate interests — fraud prevention, system and network security, and service improvement.
  • Consent — marketing communications where applicable and separately obtained.

Data Retention

KYC / AML Records
5 years
Minimum from end of client relationship (regulatory requirement)
Transaction Records
5 years
MiCA Article 83 / AML Directive requirement
Complaints Records
5 years
MiCA CDR (EU) 2025/294 requirement

Your Rights (GDPR)

Where GDPR applies, data subjects have the right to: access their personal data; rectification of inaccurate data; erasure (“right to be forgotten”) where applicable; restriction of processing; data portability; object to processing; and lodge a complaint with the Information and Data Protection Commissioner (IDPC) in Malta or the relevant supervisory authority in your jurisdiction.

To exercise any right, contact: compliance@bequant.io