Conflicts of Interest & Regulatory Disclosures

Regulatory Statement: In accordance with Article 72 of the Markets in Crypto-Assets Regulation (EU) 2023/1114 (“MiCAR”), BCB PAY EU (the “Company”) is required to maintain and operate effective organizational and administrative arrangements to identify, prevent, manage, and disclose conflicts of interest. This page provides a transparent overview of potential conflicts inherent to our operations as a licensed Crypto-Asset Service Provider (CASP) and the measures we enforce to protect our clients.

 

  1. Core principles of our framework

We design our services to ensure that the interests of our clients are always prioritized over the interests of the Company, its shareholders, management, or employees. Where a conflict cannot be completely prevented, it is rigorously managed and transparently disclosed below.

[ Identify ] ──> [ Prevent / Segregate ] ──> [ Mitigate & Monitor ] ──> [ Disclose ]

  1. Potential conflict of interest situations

Conflicts of interest can take place:

  • between customers and the Company;
  • between shareholders, members of the management and the Company;
  • between the Company and its employees;
  • between customers and other companies of BCB Group;
  • between customers themselves.

In individual cases, conflicts of interest may be unavoidable. In this case, the Company will inform the customers regarding the conflict of interest and disclose it accordingly. It is then up to the customers to decide whether they wish to conclude the transaction despite the conflict.

  1. Measures Taken to Prevent and Mitigate Conflicts 

The Company employs strict organizational and technical safeguards to ensure that client interests are always prioritized:

  • Robust Governance & Oversight: Every business unit operates under an explicit, independent reporting structure leading directly to the Senior Leadership Team and Executive Committee, eliminating unmonitored operational dependencies.
  • Information Barriers (“Chinese Walls”): We enforce strict “need to know” protocols and structural information barriers to control the flow of confidential data and prevent unauthorized information sharing.
  • Annual Disclosures & Training: All staff members undergo regular, mandatory training on conflict identification and are required to make comprehensive personal interest declarations annually.
  • Independent Compliance Monitoring: Our local Compliance Department independently evaluates and maintains the company’s central Conflicts of Interest Register, implementing one-off or permanent mitigation measures as required.