BEST EXECUTION & EXCHANGE TRADING POLICY
1. INTRODUCTION
1.1 ABOUT OFZA
1.1.1 OFZA Fintech Virtual Asset Exchange Services LLC (the “Firm”, “the Company”, “OFZA”) is licensed and regulated by the Dubai Virtual Assets Regulatory Authority (VARA) as a Virtual Asset Service Provider (VASP Reference: VL/24/12/002) for the following Virtual Asset Activities:
a) Exchange Services,
b) Broker-Dealer Services,
c) VA Management and Investment Services.
1.1.2 OFZA has its registered office 21C13, i-Rise Tower, Al Thanyah First, Al Barsha Heights, Dubai, United Arab Emirates
1.2 PURPOSE
1.2.1 The purpose of this policy is to define the standards, systems, and procedures through which OFZA achieves the best execution for its clients. It aims to establish transparent rules governing order handling, trade execution, system controls, and client communications ensuring that all trading activity complies with VARA regulatory requirements and reflects the best market practices.
1.2.2 OFZA will ensure that, the most updated version of best execution policy will be published on the website that will comply the best execution obligation and take all sufficient steps to obtain the best possible result when executing orders or transmitting orders for execution on behalf of clients, taking into account execution factors, which include but not limited to price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order. The Policy will be reviewed at least annually and whenever a material change occurs that may affect OFZA’s ability to consistently achieve the best possible results for its clients
1.3 OBJECTIVES
1.3.1 This Order Execution and Trading Policy outline the framework adopted by OFZA to ensure that all client orders for virtual assets are executed in a manner that consistently delivers the best possible results. The policy is applicable to all trading activities conducted through OFZA’s broker-dealer platform, including centralized exchanges, OTC desks, and liquidity provider. It serves as a foundational reference for all internal and external stakeholders involved in the trading and execution process.
1.3.2 Where OFZA executes an Order on your behalf or receives and transmits an Order for execution, it will take all sufficient steps to provide you with the best possible result in accordance with its Best Execution Policy.
1.3.3 The objectives of this policy are to:
a) Ensure consistent and fair execution of client orders in alignment with VARA regulatory expectations and internal standards.
b) Protect clients from adverse execution outcomes by implementing robust pre- and post-trade controls.
c) Enhance transparency in pricing, execution quality, and associated trading costs.
d) Define clear procedures, system controls for order validation, rejection, modification, and cancellation.
e) Prevent and detect abusive, manipulative, or otherwise unfair trading practices including but not limited to insider trading, market abuse practices such wash trading, pump and dump etc.
f) Maintain comprehensive records and enable continuous monitoring and assessment of execution quality.
g) Automated and manual trade-surveillance tools will be used under the oversight of the Market Surveillance Manager and Compliance Officer to ensure continuous monitoring of trading activity.
h) Communicating material changes to clients in a timely and clear manner.
1.3.4 It must be noted that OFZA will ensure that it takes all reasonable steps to act honestly, fairly, and professionally in accordance with the best interests of its clients at all times. Even in circumstances where best execution requirements do not apply, OFZA will ensure that Clients are treated fairly, that any conflicts of interest are properly identified, managed, and disclosed, and that all business is conducted with integrity.
1.3.5 OFZA maintains clear internal standards and procedures designed to achieve fair, transparent, and consistent outcomes for all Clients.
1.4 POLICY REVIEW AND MAINTENANCE
1.4.1 The Trading team led by Head of Trading will ensure that Policies, procedures, systems and controls are assessed annually for effectiveness.
1.4.2 Continuous improvements are made to execution infrastructure, surveillance systems, and risk controls.
1.4.3 All system changes are logged, auditable, and implemented without disrupting client operations.
2. BEST EXECUTION FRAMEWORK
2.1 BEST EXECUTION ASSURANCE
2.1.1 OFZA is committed to delivering the best possible outcomes for client orders, considering execution price, transaction costs, execution speed, and likelihood of execution and settlement.
2.1.2 This policy applies to all clients and all types of virtual asset transactions facilitated through the broker-dealer platform. The execution framework is designed to be dynamic and continuously evaluated to reflect market structure changes and technological advancements
2.1.3 Pre- and Post-Trade Disclosures
OFZA shall disclose to each client, both prior to execution and in the post-trade confirmation,
a) The portion of any amount payable by the client that is retained by OFZA as fees or commissions; and
b) Whether twenty percent (20%) or more of client orders are routed to any single liquidity source. If such concentration exists, OFZA shall identify the relevant liquidity source(s).
2.2 BEST EXECUTION FACTORS
2.2.1 Market Conditions
a) Market conditions include factors such as price, spreads, volatility, market sentiment, relative liquidity and pressure of communications, all of which play a critical role in determining the best execution. These factors can significantly impact the quality of execution.
2.2.2 Transaction Size
a) The size of transactions significantly influences execution quality. Large market orders may cause adverse price movements due to their impact on the liquidity of the crypto asset. To mitigate this risk and ensure orderly execution, OFZA has implemented predefined minimum and maximum quantity limits per order. Any order that exceeds or falls short of these thresholds will be automatically rejected by the system, and the client will receive a corresponding notification message explaining the reason.
2.2.3 Sources Of Liquidity
a) Orders may be routed through centralised exchanges, OTC desks, and liquidity providers. The platform utilises a structured liquidity hierarchy to determine the optimal execution venue for client orders. This hierarchy prioritises liquidity sources based on key factors such as best available price, depth of liquidity, and execution latency.
2.2.4 accessibility of quotes to trade in the Virtual Asset(s) in question under the market conditions prevailing at the relevant time, noting that, even in the event that certain sources of liquidity are not available, OFZA are not relieved from taking reasonable steps and employing their market expertise in seeking to achieve the best Execution of client orders; and the terms and conditions of the order which result in the transaction, as communicated to OFZA.
2.2.6 To support this process, the system continuously stores and analyses real-time pricing data from multiple liquidity sources. Based on these data points, client orders are dynamically routed to the most favourable external liquidity provider to ensure best execution.
2.2.7 All orders are executed externally at the liquidity provider’s side; no internal execution takes place. Additionally, the platform maintains the capability to track and report the percentage distribution of total order flow routed to each liquidity source. This ensures ongoing monitoring, transparency, and evaluation of execution performance across all connected venues.
2.2.8 The relative importance of the execution factors—price, costs, speed, likelihood of execution and settlement, size, nature, or any other relevant consideration—is dynamic and depends on several variables such as market conditions, order type, and liquidity availability.
2.2.9 Subject to any specific Client instructions, OFZA generally considers price as the most significant execution factor in achieving the best possible result for its Clients. Other factors are assessed and applied with equal weighting unless, in OFZA’s reasonable judgment and considering prevailing market conditions, another factor becomes more critical to achieve an overall better result for the Client.
2.2.10 OFZA will not compare the results achieved for Clients under this Policy with results that may be achieved by another VASP or firm, as each operates under distinct execution arrangements and fee structures.
2.2.11 OFZA maintains a transparent and consistent fee structure, ensuring that all applicable fees, commissions, and implicit costs are fully disclosed to Clients. OFZA does not apply discriminatory pricing or vary fees depending on the execution venue used.
2.2.12 OFZA onboards Liquidity Providers only after conducting a comprehensive due-diligence and suitability assessment, evaluating:
a) Legal presence, regulatory standing, and reputation
b) Compliance screening, sanctions, and adverse-media checks.
c) Competitive and transparent pricing and market depth
d) Financial soundness and operational resilience
e) Technology infrastructure and connectivity
f) Risk management, trade surveillance, and market-abuse prevention measures
2.3 DOCUMENTATION AND RECORD KEEPING
2.3.1 OFZA shall maintain comprehensive, auditable records evidencing how each client order met the best execution criteria (price, cost, speed, likelihood of execution/settlement, and size). All supporting documentation, including liquidity-source selection data, order timestamps, and trade confirmations, shall be retained for a minimum of eight (8) years