Disclaimers

ARP Digital conducts thorough due diligence on any Virtual Asset before offering services in relation to it. ARP Digital has established Virtual Asset Standards in line with VARA rules, and all assets must continuously meet these standards. In assessing whether a Virtual Asset meets these standards, ARP Digital considers a range of factors listed below:

• Market Metrics: Assessment of the Virtual Asset’s market capitalisation, fully diluted value, trading liquidity, trading volume distribution, and market depth. The Firm also considers the historical performance and stability of these metrics, including whether market capitalisation, liquidity, or trading activity have demonstrated sustained decline or volatility that may affect market integrity or client protection.
• Technology, Design and Use Case: Evaluation of the Virtual Asset’s design, technological architecture, core features, and intended or observed use cases, including the robustness and functionality of the underlying blockchain or distributed ledger protocol. The Firm considers both the originally intended use of the asset and any additional uses that may have emerged in practice.
• Compliance and Regulatory Considerations: Assessment of whether the Virtual Asset includes any features that may materially affect the Firm’s ability to comply with applicable laws, regulations, rules, or directives, including those relating to AML/CFT, sanctions compliance, securities regulations, intellectual property rights, or financial crime risks. The Firm also evaluates the regulatory treatment of the Virtual Asset by VARA and other relevant authorities, both within the UAE and internationally, including whether the asset has received regulatory approval or recognition in other jurisdictions.
• Prohibited or Restricted Assets: Confirmation that the Virtual Asset is not prohibited, restricted, or otherwise subject to regulatory enforcement actions by VARA or other competent authorities in jurisdictions where the Firm conducts or intends to conduct Virtual Asset activities.
• Security and Integrity of the Protocol: Evaluation of the security, resilience, and immutability of the underlying distributed ledger technology (DLT), including the robustness of the consensus mechanism, resistance to attacks or manipulation, history of security incidents, and the overall reliability of the protocol.
• Audit, Transparency, and Development Roadmap: Consideration of the transparency and governance of the Virtual Asset ecosystem, including whether smart contracts or protocols have undergone independent security audits and the outcomes of such audits. The Firm also reviews the development roadmap and future plans communicated by the issuer or relevant developers to assess the sustainability and ongoing development of the protocol.
• Market Integrity and Risk of Manipulation: Assessment of whether the Virtual Asset’s market may be susceptible to price manipulation, market abuse, fraud, or other forms of misconduct. Where relevant risks are identified, the Firm evaluates the mitigations available to detect, monitor, and prevent such activities.
• Conflicts of Interest: Identification and assessment of any potential or actual conflicts of interest that may arise where the Firm provides services in relation to the Virtual Asset, including situations involving issuers, affiliated entities, or market participants. Appropriate mitigation measures must be implemented where such conflicts are identified.
• Issuer Background and Governance: Where the Virtual Asset has an identifiable issuer or sponsoring entity, the Firm assesses the background, reputation, governance structure, and relevant experience of the issuer and its management. This includes consideration of any prior investigations, enforcement actions, or allegations related to fraud, misconduct, or regulatory breaches.
• Underlying Assets and Rights (where applicable): Where the Virtual Asset represents rights to underlying assets (such as asset-backed tokens or stablecoins), the Firm assesses the nature and quality of the underlying assets, the mechanisms supporting those assets, and the enforceability of the rights associated with the token.
• Asset Backing and Obligations: Where applicable, the Firm verifies whether sufficient assets or reserves are available to satisfy obligations associated with the Virtual Asset, including redemption rights or other contractual claims.
• Alignment with Underlying Physical Markets (where applicable): Where a Virtual Asset is linked to, references, or derives value from an underlying physical market, the Firm assesses whether the asset’s structure, terms, and conditions appropriately reflect the operation of that underlying market and whether the design could adversely impact the functioning or integrity of that market.
• Ongoing Monitoring and Periodic Review: The Firm periodically reviews the characteristics, performance, and market behaviour of supported Virtual Assets to ensure continued alignment with regulatory expectations, market standards, and any relevant underlying physical markets where applicable may delist assets that no longer meet the criteria.

It demonstrates ARP Digital’s commitment to only support high-quality and compliant virtual assets.

Provide a comprehensive Risk Disclosure Statement to educate users on the risks of virtual asset trading and investment. This should be a standalone page and must include all material risks VARA expects to be disclosed (per Market Conduct Rulebook Part V.B).

Important Notice

Virtual Assets are highly speculative and involve a high degree of risk. The value of Virtual Assets can fluctuate significantly and may decline rapidly. You should not buy, sell, or hold Virtual Assets unless you fully understand the risks involved and are prepared to lose the entire value of your investment. You should only use funds that you can afford to lose without affecting your financial situation.

By accessing or using the services provided by ARP Digital FZCO (“ARP Digital”, “the Firm”), you acknowledge that you understand and accept the risks associated with Virtual Asset transactions.

1. Risk of Loss and Price Volatility

Virtual Assets may lose their value in part or in full and are subject to extreme volatility at times. Prices may fluctuate rapidly over short periods due to market conditions, speculation, regulatory developments, technological changes, or other factors.

The value of a Virtual Asset can increase or decrease significantly within minutes or hours, and there is a real possibility that the value of a Virtual Asset may decline to zero. Past performance of any Virtual Asset does not guarantee future results.

2. Transfer and Irreversibility Risks

Transactions involving Virtual Assets may not always be transferable and some transfers may be irreversible.

Once a Virtual Asset transaction is recorded on a blockchain or distributed ledger, it is generally permanent and cannot be reversed. If you send Virtual Assets to an incorrect wallet address or to an unsupported network, it may not be possible to recover those assets.

In addition, certain platforms, protocols, or network conditions may impose restrictions, delays, or limitations on transfers.

3. Liquidity Risk

Virtual Assets may not be liquid. In certain market conditions, there may be limited or no buyers available for a particular Virtual Asset.

This means that you may not be able to sell your Virtual Assets when you wish, or you may only be able to sell them at a significantly reduced price. Liquidity conditions can change quickly, especially during periods of market stress or heightened volatility.

4. Transparency and Privacy Risks

Some Virtual Asset transactions are not private and may be recorded on public distributed ledger technologies (DLTs), such as blockchain networks.

While your personal identity may not be directly visible on the blockchain, transaction details such as wallet addresses, timestamps, and transfer amounts are typically publicly accessible and may be traceable. As a result, transactions may be analysed and linked to individuals through blockchain analysis tools or other investigative methods.

You should not assume that Virtual Asset transactions are fully anonymous or private.

5. Fraud, Manipulation, and Cybersecurity Risks

Virtual Assets may be subject to fraud, manipulation, theft, including through hacks and other targeted schemes, and may not benefit from legal protections.

The Virtual Asset ecosystem may be exposed to scams, market manipulation, phishing attacks, cyber-attacks, and other fraudulent schemes. Exchanges, wallet providers, and blockchain protocols may be targeted by hackers or malicious actors seeking to gain unauthorized access to digital assets.

If such an event occurs, it may be difficult or impossible to recover stolen assets. In many cases, there may be limited legal recourse available to affected users.

6. No Government Guarantees or Legal Tender Status

Virtual Assets are typically not backed by any government or central authority and are generally not considered legal tender.

Unlike traditional bank deposits, Virtual Assets are generally not protected by deposit insurance schemes or government guarantees. This means that losses resulting from market movements, service provider failures, or cyber incidents may not be recoverable.

7. Regulatory and Legal Risks

The regulatory environment for Virtual Assets is still developing and may change rapidly.

Changes in laws, regulations, or government policies in the UAE or other jurisdictions may impact the availability, legality, or value of certain Virtual Assets or related services. New regulations or restrictions could limit your ability to buy, sell, transfer, or hold Virtual Assets.

8. Technology and Network Risks

Virtual Assets rely on distributed ledger technologies and blockchain networks, which may be subject to technical failures, software bugs, protocol vulnerabilities, or network disruptions.

Blockchain networks may experience congestion, delays, forks, or other operational issues that could affect transaction processing times, network functionality, or asset value.

9. Market and Operational Risks

The Virtual Asset market is relatively new and evolving. Market infrastructure, liquidity providers, and trading venues may be less established than traditional financial markets.

Operational failures, outages, or disruptions affecting exchanges, blockchain networks, or third-party service providers may delay or prevent transactions.

10. No Investment Advice

ARP Digital does not provide investment, financial, legal, or tax advice.

Any information provided by ARP Digital is for informational purposes only and should not be considered investment advice or a recommendation to buy, sell, or hold any Virtual Asset. You are responsible for conducting your own research and, where appropriate, seeking independent professional advice before making any financial decision.

11. Acceptance of Risk

By accessing or using ARP Digital’s services, you acknowledge that:

• You understand the risks associated with Virtual Assets;
• You have carefully considered whether trading or holding Virtual Assets is appropriate for you; and
• You accept full responsibility for any losses that may arise from your participation in Virtual Asset transactions.

You further confirm that you understand that Virtual Assets are high-risk financial products and that you may lose the entire value of your investment.

Support & Complaints

Our Commitment to You

ARP Digital FZCO (“ARP Digital”) is committed to providing high-quality service and treating all clients fairly. We strive to ensure that our products and services meet the highest standards of professionalism and transparency.

If at any time you are dissatisfied with our services or believe that something has gone wrong, we encourage you to tell us. We take all complaints seriously and are committed to reviewing and resolving them promptly, fairly, and in accordance with the requirements of the Virtual Assets Regulatory Authority (VARA).

How to Submit a Complaint

You may submit a complaint to ARP Digital through any of the following channels:

Email

You can send your complaint to our dedicated complaints email address: Complaints@arpdigital.io. Please include your name, contact information, and a clear description of the issue.

Online Form

You may submit your complaint through our online support or complaint form available on this website.

Phone

You may contact our support team by phone to raise a complaint: +971 52 708 1422. Our team will assist in recording your complaint and guiding you through the process.

Mail

You may also submit complaints by post to: ARP Digital FZCO, 34th Floor, HDS Tower, M Cluster, Jumeirah Lake Towers, Dubai, United Arab Emirates.

Information to Include in Your Complaint

To help us investigate your complaint efficiently, please provide the following information where possible:

• Your full name and contact details
• Your registered account email address
• Transaction reference number (if applicable)
• Date of the issue or transaction
• A clear description of the problem or concern
• Any supporting documents or screenshots

Providing complete information helps us review and resolve your complaint more quickly.

What Happens After You Submit a Complaint

Acknowledgement of Your Complaint

We will acknowledge receipt of your complaint within 7 calendar days of receiving it. This acknowledgement may include a reference number and confirmation that your complaint is under review.

Investigation and Resolution

ARP Digital aims to investigate and resolve complaints within 4 weeks (28 days) of receiving them.

Each complaint is reviewed by our Compliance team or designated Complaint Handling personnel, who will conduct an impartial investigation of the matter.

Where an error or issue is identified, ARP Digital will take appropriate corrective action.

If More Time Is Needed

In some cases, complaints may require additional investigation.

If we cannot resolve your complaint within 4 weeks, we will:

• Inform you of the reason for the delay
• Provide an update on the progress of the investigation
• Provide a revised timeframe for resolution

In exceptional circumstances, the maximum timeframe for providing a final response is 8 weeks (56 days) from the date your complaint was received.

No Fees for Complaints

Submitting a complaint to ARP Digital is completely free of charge.

Clients will not be charged any fees for filing or handling complaints.

Communication of the Outcome

Once the investigation has been completed, we will provide you with a final written response explaining:

• The outcome of our investigation
• Any actions taken by ARP Digital
• Any remedy or resolution offered, if applicable

We aim to ensure that our responses are clear, transparent, and fair.

If You Are Not Satisfied With the Outcome

If you are not satisfied with our response, you may request that the complaint be reviewed internally by senior management.

To request an escalation, please contact us through the same channels listed above and reference your complaint number.

Escalating Your Complaint to VARA

ARP Digital FZCO is regulated by the Virtual Assets Regulatory Authority (VARA).

If you are not satisfied with our final response, or if 8 weeks have passed without a resolution, you may escalate your complaint to VARA.

You may contact VARA through their official channels:

Virtual Assets Regulatory Authority (VARA). Website: https://vara.ae. Email: varaconnect@vara.ae.

Further guidance on submitting complaints to VARA may be found on their website.

Complaint Form

For convenience, you may also complete our Complaint Form, available on this page. This form helps ensure that all necessary information is included to allow us to investigate your complaint effectively.

Anti-Bribery and Corruption Commitment

Our Commitment to Ethical Conduct

ARP Digital FZCO (“ARP Digital”) is committed to conducting all business activities with the highest standards of integrity, honesty, and transparency. As a regulated entity authorised by the Virtual Assets Regulatory Authority (VARA), we strictly comply with all applicable UAE laws, VARA regulations, and international anti-bribery and corruption standards.

ARP Digital enforces a strict Anti-Bribery and Corruption (ABC) policy and adopts a zero-tolerance approach to any form of bribery, corruption, fraud, or unethical conduct.

Bribery in any form — whether offering, promising, giving, requesting, or accepting any improper advantage, payment, gift, or benefit to influence a business decision — is strictly prohibited at ARP Digital.

Anti-Bribery and Corruption Policy

ARP Digital maintains a comprehensive Anti-Bribery and Corruption Policy, which applies to all directors, employees, contractors, and representatives of the Firm.

This policy establishes strict rules designed to prevent bribery and corruption and includes, among other things:

• Prohibition of offering, giving, or accepting bribes or improper payments
• Restrictions on gifts, hospitality, and other benefits that could improperly influence business decisions
• Requirements to conduct business only with reputable counterparties and partners
• Mandatory reporting of any suspected misconduct or unethical behaviour
• Monitoring and internal controls designed to detect and prevent corruption risks

All employees and representatives of ARP Digital are required to comply with this policy and to act in accordance with the Firm’s ethical standards.

Reporting Concerns or Misconduct

ARP Digital encourages employees, clients, partners, and members of the public to report any concerns relating to bribery, corruption, fraud, or other unethical conduct.

If you suspect that an ARP Digital employee, contractor, or representative may be involved in bribery or corrupt practices, or if you have been approached in a manner that raises concern, please report the matter immediately.

Reports may be submitted confidentially through the following contact: Email: compliance@arpdigital.ae.

Reports may be made anonymously if desired. ARP Digital treats all reports seriously and ensures that concerns raised in good faith are handled confidentially and without retaliation.

All reported concerns are reviewed and investigated in accordance with the Firm’s internal policies and regulatory obligations.

Our Public Commitment

ARP Digital publicly affirms its zero-tolerance stance toward bribery and corruption.

We communicate this commitment to all employees, partners, clients, and service providers at the start of our business relationships and expect all parties working with us to adhere to the same high standards of integrity.

Through these measures, ARP Digital seeks to maintain the trust of our clients, partners, regulators, and the broader financial community.

As ARP Digital FZCO will engage in Broker-Dealer Services, VARA’s Broker-Dealer Services Rulebook (Part I.B) mandates additional website disclosures related to these activities.

Conflicts of Interest

ARP Digital FZCO (“ARP Digital”) seeks to identify, manage, and mitigate any actual or potential conflicts of interest that may arise in the course of providing services to clients. A conflict of interest may arise where the interests of ARP Digital, its employees, or its affiliates could differ from the interests of a client. ARP Digital has implemented policies and controls designed to ensure that clients are treated fairly and that potential conflicts are appropriately managed and disclosed.

Examples of potential conflicts include:

• Principal Trading: ARP Digital may act as principal in certain transactions, meaning the Firm may take the opposite side of a client’s trade. This could create a potential conflict because the Firm may benefit from spreads or price movements. To manage this risk, prices are derived from prevailing market rates across multiple liquidity sources, pricing is monitored to ensure fair and competitive quotes, and internal controls are implemented to ensure that client interests are treated fairly and consistently.
• Relationships with Affiliates or Partners: ARP Digital may maintain relationships with affiliated entities or service providers that support operational, technological, or infrastructure services. Where such relationships exist, ARP Digital ensures that decisions are made in the best interests of clients and that appropriate governance controls and information barriers are implemented to manage potential conflicts.
• Personal Trading by Employees: Employees of ARP Digital may be permitted to trade virtual assets personally, subject to strict internal policies. These policies are designed to prevent the misuse of confidential information and include monitoring of employee trading activity and restrictions intended to ensure that employee trading does not disadvantage clients.

Disclosure of Leadership Family Relationships

ARP Digital FZCO wishes to inform its clients that certain members of our senior management are immediate family members. In particular, our Chief Executive Officer and Non-executive Board Member are brothers from the Kanoo family, in addition, they also have close familial ties with the Chairman of the Board. We acknowledge that this family relationship could potentially pose a conflict of interest in the management of the Company. ARP Digital FZCO has implemented robust corporate governance controls to ensure that this relationship does not adversely affect our clients. These measures include independent oversight by our Independent Non-Executive Board Member and established Board Committees, strict conflict-of-interest policies requiring disclosure and recusal in decision-making, and committee structures designed to prevent any undue influence. We are committed to operating with transparency and integrity, and we affirm that all clients will be treated fairly and impartially, with the above governance safeguards in place. If you have any questions about this disclosure or our conflict management practices, please contact our compliance department for more information.

ARP Digital continuously monitors its business activities for potential conflicts of interest and implements appropriate controls to ensure fair treatment of all clients.

Client Agreement

View Client Agreement

Data Privacy

Privacy Policy shared separately.

Whistleblowing

Refer to the anti-corruption/whistleblowing contact in the ABC section, indicating that ARP has a policy for staff and stakeholders to report misconduct safely.

Complaints Handling

Refer to the complaints handling procedure in the section above.

Pricing Policy

ARP Digital provides over-the-counter (OTC) trading services for virtual assets. Prices offered to clients are based on prevailing market conditions and available liquidity across multiple global trading venues and liquidity providers. Pricing may be determined using a combination of market data obtained from reputable exchanges, liquidity provider quotes, and internal pricing models that aggregate available market information.

When executing a transaction, ARP Digital provides clients with a quoted price reflecting current market conditions. The quoted price may include a spread or commission, which is incorporated into the trade price and disclosed to the client at the time of execution. Where ARP Digital acts as principal, the quoted price reflects the price at which ARP Digital is willing to buy or sell the relevant virtual asset based on prevailing market conditions. ARP Digital aims to provide competitive and transparent pricing at all times.

Order Routing Practices

ARP Digital primarily executes client trades as principal to ensure immediate and efficient settlement. However, to maintain deep liquidity and secure the best available pricing for our clients, we may route a portion of our order flow to external liquidity providers. In these instances, our primary venues for sourcing liquidity are Circle and Tether.

Custody for Other VASPs

ARP Digital UAE does not provide custody or clearing services for any other VASP.

Client Asset Protection

ARP Digital takes the protection of client assets seriously and implements safeguards designed to ensure that client ownership is protected at all times. Client funds and virtual assets are held separately from ARP Digital’s own assets in order to maintain clear segregation and prevent commingling. Virtual assets are stored using secure wallet infrastructure and industry-standard security measures, while strict access controls are applied to systems responsible for handling client assets. Operational monitoring procedures are also in place to track transactions and balances and to ensure the accuracy and security of client holdings. These measures are designed to ensure that clients retain ownership of their assets and that those assets remain protected.

Referral Arrangements

ARP Digital UAE has no referral or introduction agreements with third parties at this time.

Use of Third-Party Accounts or Custodians

ARP Digital does not hold client money or virtual assets with third-party custodians. Client funds and virtual assets are managed through the Company’s designated wallet and custody infrastructure, implemented to support secure storage and transaction execution in line with the Company’s operational and risk management framework.

Additional Disclosures

ARP Digital FZCO and its management have not been subject to any criminal convictions or regulatory sanctions. We will disclose any such information as required by VARA.

All these activity-specific points ensure ARP Digital’s website meets the Broker-Dealer Services Rulebook disclosure obligations.

As per the requirements outlined in Rule V.A.3 of the Market Conduct Rulebook and Rule I.B.1 of the Broker-Dealer Rulebook of Dubai’s Virtual Assets Regulatory Authority, ARP DIGITAL FZCO is required to make certain disclosures regarding the leadership of the Company.

The responsible individuals of ARP DIGITAL FZCO are as follows:

• Abdulaziz Saud Kanoo, Co-founder and CEO
• Bader Ghulam Al Balooshi, CO/MLRO/ Interim CRO