Legal and Regulatory Disclosures

Entity Information

BitGo MENA FZE is a Free Zone Establishment with registered office at Unit 108, Level 1, The Offices 4 – One Central, Dubai World Trade Centre. Registration Number: L-3375, Free Zone Entity (FZE), providing Broker-Dealer Services, regulated by VARA under license number VL/25/09/001. Responsible individuals: Benjamin Choy, Karam Albsharat.

Disclosures/Disclaimers for UAE Customers

1. Virtual assets are not legal tender, are not backed by the government, and accounts and value balances are not subject to any investor protections

2. Legislative/regulatory changes may adversely affect virtual asset use, transfer, exchange, and value

3. Virtual asset transactions may be irreversible; losses from fraud/accidents may not be recoverable

4. Transactions deemed made when recorded on public ledger, not necessarily when initiated

5. Value derived from continued market participation; potential for permanent total loss

6. Virtual assets may have limited transferability or movement restrictions

7. Limited or no liquidity, difficult to exchange/dispose

8. Non-private transactions permanently recorded on distributed ledger technology

9. No assurance of continued acceptance as payment

10. Volatility and unpredictability of the price of virtual asset relative to fiat asset may result in significant loss over a short period of time

11. Increased fraud, manipulation, theft, cyber attack risk without legal protections

12. Technological difficulties may prevent asset access/use

13. Bond/trust accounts may be insufficient to cover customer losses

14. E-trading platform details: clients trade directly from custody accounts via Request for Quote widget. Market/limit orders executed through matching engine routing to liquidity providers. Revenue through transaction fees. Additional fees for fiat deposits/withdrawals possible.

15. Order routing to BitGo affiliates (BitGo Prime LLC, BitGo Hong Kong Ltd) based on best available price/liquidity. No established practices for routing 20%+ to single provider. Disclosure required if concentration exceeds threshold.

16. Clearing/settlement by BitGo Custody MENA FZE, not BitGo MENA FZE

17. BitGo MENA FZE does not hold client assets; BitGo Custody MENA FZE does

18. Trading clients must open Custodial Account with BitGo Custody MENA FZE

19. BitGo MENA FZE operates on riskless principal basis; holds no virtual assets

20. Multiple due diligence levels and reference checks on employees

21. BitGo MENA FZE provides services exclusively to Qualified Investors and Institutional Clients

22. Proprietary assets held with third parties; virtual assets held by BitGo Custody MENA FZE; funds held by Zand Bank P.J.S.C.

Virtual Asset Standards per Rule VIII.A.1 of VARA Market Conduct Rulebook

Evaluation Factors

• Market metrics: Market capitalization, fully diluted value, liquidity; downward trending assessment

• Design system: Design, features, intended/unintended use cases review

• Legal compliance and prohibitions: Features affecting regulatory compliance; AML/CFT, sanctions, securities, intellectual property review; VARA/other authority regulatory treatment; prohibition assessment across jurisdictions

• Security: Underlying Digital Ledger Technology protocol security/immutability

• Future Development: Issuer/developer roadmap considerations

• Risk of market manipulation: Susceptibility assessment and BitGo mitigations

• Conflicts of interest: Potential/actual conflict assessment and mitigations

• Issuer background: Issuer background investigation; sector experience; fraud/deceit investigation history

• Asset rights and availability: Rights representation consideration; enforceability assessment; asset sufficiency evaluation

• Market correlation: Virtual asset terms reflecting existing physical market operation; adverse impact avoidance

• Periodic review: Terms/conditions reviewed for physical market correlation; standards/practices conformance

Contact: support@bitgo.com