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Safeguard your digital assets when trading with Enigma via access to a network of highly-secured custodians. Enigma protects client funds with multi-layer technology that leverages enterprise-grade MPC and multi-sig custody methods for peace of mind.

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Weekly Spotlight

UK regulation latest: phase-1 and stables

One of the most common misapprehensions we tend to see, with respects to the general regulatory approach towards crypto in Britain, is that Britain has tended to be a poor place to do crypto business over the last few years. Practically speaking, this is nonsense, and betrays something of a…
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Weekly Spotlight

Roundup, October 2023

An enormously and outsizedly positive month with BTC +29% (best since January 2023) and ETH up a more modest +9% (still the best since March). We did come into the month relatively bullish on BTC because of what we saw as a likely unwind of short pressure from September, but…
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Weekly Spotlight

BTC, ETFs, and the rally: 2020 redux?

As we write this, BTC is trading at its highest level in nearly 18 months. Tuesday's high print just above $35,000 and close at $34,000 both mark a return to a level not seen since the open at May 9th, 2022 - for those tracking timelines carefully, that was the…
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Weekly Spotlight

Bitcoin spot ETFs and fake news

A fond farewell to the 2023 bullmarket, 16th October 2023-2023, 14:30 to 14:45 UTC. Markets ripped upwards briefly at the aforementioned point a couple of days ago on a very simple headline: “BREAKING: SEC APPROVES ISHARES SPOT BITCOIN ETF”. In the wake of the news, BTC jumped into a double-digit…
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Weekly Spotlight

Headline updates: FTX and FCA

The FTX trial is now in full-swing in New York, with opening statements having taken place last Wednesday and with a litany of prosecution witnesses already having been presented to the court in its first week, including former FTX CTO Gary Wang (starting on Friday and continuing through yesterday) and…
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Weekly Spotlight

Roundup, September 2023

A modest positive print on the month for both BTC and ETH, especially BTC at +4%. This wasn't entirely unexpected, even in the context of our general and consistent bearish position on Q3 as a whole (which still ended -12% on BTC and -14% on ETH); as we noted in…
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Weekly Spotlight

Q3 market review and Q4 market outlook

At the time of writing, there remains a few days left on the board for Q3, but barring a development with very few analogues (ironically the 'Xi pump' in the last week of October in 2019 is probably one of them), the picture looks to be drawn for Q3 2023…
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Weekly Spotlight

Q3 market review and Q4 market outlook

At the time of writing, there remains a few days left on the board for Q3, but barring a development with very few analogues (ironically the 'Xi pump' in the last week of October in 2019 is probably one of them), the picture looks to be drawn for Q3 2023…
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Weekly Spotlight

BTC: September seasonality and the regulatory spectre

There tends to be something of a feeling of dread for crypto coming into late September every year for crypto markets for the very simple reason of said dread being empirically justified. Despite having returned tens of thousands of percent in gains since 2015, BTC has outright returned negatively on…
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Weekly Spotlight

Headline updates: FTX, ETF, BNB

The aftermath of FTX continues to play out as one would expect it to given that so many lawyers are involved - that is, slowly, and painfully. Further details came out on Monday (via a court filing) on the FTX 2.0 reboot plan, with the estate looking to any and…
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Weekly Spotlight

Roundup, August 2023

A weak month across the board, with both BTC and ETH returning negatively at -11%, and the month as a whole defined by just two days. The first was the 18th, which saw a plunge of -7% on both with lower wicks; this was confusing on the face of things…
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Weekly Spotlight

Grayscale verdict: what it means, and what’s next

After months of speculation and anticipation, we have finally seen some action. On Tuesday, the D.C. Circuit Court of Appeals ruled in favour of Grayscale in their case against the SEC, stating the point unequivocally: "The denial of Grayscale’s proposal was arbitrary and capricious because the Commission failed to explain…
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Weekly Spotlight

CRV, Aave, and collateralisation

Back in early August, as part of our monthly summary, we referenced Curve, Aave, and Michael Egorov as something to keep an eye on, and promised to revisit if necessary. While things quietened down in that first week of August on that front, they have become more alive again in…
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Weekly Spotlight

Market outlook latest: structural stagnancy

After a somewhat flaccid July, August has so far shaped up rather boringly for most crypto assets, as it tends to do. We revisit the outlook for BTC and broader crypto markets as we approach the halfway point of Q3.
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Weekly Spotlight

Roundup, July 2023

A weak month as expected. Both BTC and ETH reached less than 5% above their monthly opens ($30,500 and $1930 respectively) at their respective highs, and would both end the month at a few bps below -4%. As we said last month and in our Q3 outlook, we don't see…
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Weekly Spotlight

On Worldcoin and odd ducks

24th July saw the much-anticipated mainnet launch of Worldcoin - one of the stranger and more controversial projects in existence even by the standards of the crypto space. Despite its notoriety among crypto natives, its launch revealed a surprising lack of broader recognition, with mainstream media tripping over itself to…
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SEC-Ripple: the good, the bad, and the ugly

The most important takeaway from the summary judgement was the ruling that XRP sales on-exchange - or, to use the term heard around the world, 'programmatic sales' - do not represent the sale of an investment contract. This is crucial, because by now, the Ripple case isn't really about XRP…
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Weekly Spotlight

GHO, Aave, and the future of stablecoins

Today saw the confirmation of one of the more interesting developments of the year in DeFi innovation with the Aave DAO vote on the GHO stablecoin. Proposed back in June 2022, GHO isn't the most original concept in the world - an algorithmic stablecoin built on multi-collateral systems and mintable…
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Weekly Spotlight

Roundup, June 2023

The BlackRock filing saved what was otherwise looking like a weak month, after May provided the first red close technically in five; BTC ended +12% in the aggregate on the back of a +27% low-high move between 15th and 23rd June. ETH (which had closed positively in May) had an…
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Weekly Spotlight

Q3 market outlook: continuity in the doldrums?

Q2 has not exactly been lively for crypto. Our view coming into the quarter was that, in spite of the rally in mid-March, upside was likely to be capped and baseline directionality leaned negatively; markets were no longer in a state of panic, and had held up surprisingly well in…
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Weekly Spotlight

BlackRock, gold, and Grayscale: ETF latest

This week saw BlackRock filing for a spot Bitcoin ETF; we will not go through the whole story here, but in brief, the ETF would trade on major US markets, uses Coinbase as custodian without specifying purchase mechanisms in our reading, and the current deadline for a decision on the…
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Weekly Spotlight

UK regulatory latest: Sunak’s accelerator

We take a look at recent developments in the UK regulatory landscape in the light of a16z's decision to open a London office.
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Weekly Spotlight

Roundup, May 2023

Work on Ordinals as a protocol has continued to take place - most notably with BRC-721E, a process for (one-way) bridging ERC-721 NFTs on Ethereum over to Bitcoin - and the congestion on May 10th did so far represent the peak of congestion...
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Weekly Spotlight

Unlocks, FDV, and cliff-edges

Unlocks are in focus this week, with a significant portion of contributor and early investor tokens going out to OP investors, as well as the second in a number of community unlocks for SUI. We also outline a brief history of unlocks in crypto, and how in general they should…
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Weekly Spotlight

The case for FTX 2.0?

Social channels were set abuzz yesterday after – as often tends to be the case – a court filing. However, while most court filings are distinguished essentially by what they do (or don’t) destroy, this one was interesting for indications at what it might create.
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Weekly Spotlight

On Ethereum supply and correlation

Bitcoin-Ethereum correlation has recently dropped to some of its lowest marks in several years. While that drop has been overrepresented, it does bring up an important discussion about Ethereum in particular in the ‘ultrasound money’ era.
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Weekly Spotlight

Roundup, April 2023

ETH actually did see a short-term rally coming out of the upgrade, touching above $2100 for the first time since last August, but the rally was ultimately brief and ETHBTC is once again struggling to hold above 0.065.
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Weekly Spotlight

Inertia and Uncertainty

We find ourselves at something of an odd juncture in crypto markets right now wherein a lot seems to be crossing the headlines, and yet simultaneously, there often feels like little of real meaning to say. Everything is simultaneously in a moment of existential decision-making, and in total inertia and…
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Weekly Spotlight

Ethereum and the Shapella upgrade

We have to start here with something of an anti-climax: the Ethereum Shapella hard fork tonight is unlikely to either be a major short-term event or a significant medium-term catalyst for the asset in either direction.
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Weekly Spotlight

Roundup, March 2023

Focus has come off GBTC due to other events, and no further news has come through in the last month, but the discount has now sat at close to -36% for several weeks, and hence seems likely to narrow further coming into the next two quarters.
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Weekly Spotlight

Binance litigation: four (4) thoughts

The CFTC indictment against Binance charges the firm, CEO Changpeng Zhao, and ex-compliance head Samuel Lim with the following: illegal futures markets; illegal commodity options; failure to register as a FCM; failure to register as a DCM; failure to diligently supervise; failure to implement KYC/AML; and enabling KYC evasion.
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Weekly Spotlight

Arbitrum and airdrops

On February 22nd, while discussing Polygon (MATIC), we wrote: Layer-2 development has accelerated significantly as of late, with both optimistic and zero-knowledge rollups receiving a great degree of attention; both Optimism (optimistic) and Arbitrum (zero-knowledge) have been on upswings in almost all metrics…
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Weekly Spotlight

Special edition: Hypertetherisation

USDC and Circle USDC faced its biggest crisis since the asset’s inception in late 2018 when it got caught in the crossfire of the Silicon Valley Bank collapse. To explain it as simply as possible: USDC is fully-backed, with its reserves currently split roughly 75-25.
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Weekly Spotlight

Grayscale latest: “where’s the gap?”

On 8th February, we wrote that “resolution on the Grayscale trust situation has been slower than expected or desired over the last few months, and action since the start of 2023 has emphasised those issues.” The tale of the tape has been false dawns followed by long nights wrought over…
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Weekly Spotlight

Roundup, February 2023

GBTC discount fell to lows of 47% on February 13th, not coincidentally at the same time as Bitcoin itself hit monthly lows just under $22,000
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Weekly Spotlight

Polygon, layoffs, and layer 2s

Polygon announced layoffs of around 100 staff on Tuesday out of a total headcount of 500.The Polygon chain (Matic) has always been particularly reliant on centrally-originated business development and partnerships for growth compared to certain compatriots; the layoffs likely point towards an attempted shift towards a more technically-oriented framework.
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Weekly Spotlight

Are stablecoins securities?

Are stablecoins securities? On the face of it, the question seems absurd; no major stablecoin is yield-generating on an asset level, and nobody buys stablecoins with an expectation of profit from that act alone. It is absurd that we have to even consider the question.
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Weekly Spotlight

Grayscale GBTC and ETHE outlook

Resolution on the Grayscale trust situation has been slower than expected or desired over the last few months, and action since the start of 2023 has emphasised those issues.
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Weekly Spotlight

UK cryptoasset regulation

The British Treasury today published a number of proposals as part of a consultation that “sets out proposals for the UK’s financial services regime for cryptoassets, and marks the next stage of the UK’s phased approach”.
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Special Reports

Illiquidity & Opportunity Pt 2

The FTX bank run and collapse created illiquid conditions that unevenly impacted digital asset returns. However, the crisis did not change fundamental value drivers for some digital protocols.
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Special Reports

Illiquidity & Opportunity Pt 1

Though FTX was not the largest exchange by volume, its collapse evaporated market liquidity and the full effects are yet to be determined. Exchange data shows the FTX collapse drove the volume impact on returns.
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Special Reports

Where are We?

Though BTC prices support last week’s view that digital asset markets remain in a downward trending regime, macro and fundamentals suggest changes are in the wind. Sunday marked the lowest close in two years at $16.3k BTC. Though it ended the free-fall, last week continued a negative trend for BTC…
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Special Reports

Post-FTX Bankruptcy Market Update

The international crypto exchange shocked the industry when it announced top competitor, Binance, would acquire FTX to rescue it from insolvency. Now, with Binance out of the deal, and FTX Group filing Chapter 11 proceedings in the US, we will discuss our immediate expectations for digital assets markets.
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Special Reports

Polygon Continues to Develop NFT Partnership to Grow Mainstream Blockchain Adoption

Polygon’s MATIC token reaped the fruits of Polygon Labs’ business development labors this year after Meta announced it’s full suite of NFT integrations with Polygon yesterday. Since the update, MATIC rose 8% – over 6% better than ETH and BTC. Right now, no other network is doing more for mainstream…
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Special Reports

A View of Bitcoin & the Fed Funds Rate in 2022

Everyone knows not to trade FOMC meetings. The last meeting in September saw $37M in BTC liquidations – $28M of which were shorts. While BTC price held up the last time Chair Powell announced a rate increase, correlation to equity markets has spelled disaster for BTC price during the previous…
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Special Reports

Vellir Policy Monitor

October’s Vellir Policy Monitor covers the most important policy and regulatory changes impacting on crypto markets: The EU’s final MiCA text with last minute changes to stablecoins and NFTs, expected in 2024; US Financial Stability Oversight Council requested Congress clarify security v. commodity classification and stablecoin legislation; The Financial Stability…
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Special Reports

Vellir Policy Monitor | Oct 2022, Published by Project Vellir

Vellir Policy Monitor | Oct 2022, Published by Project Vellir. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Special Reports

HANetf Digital Assets & Crypto Review | H1 2022, Published by HANetf

HANetf Digital Assets & Crypto Review | H1 2022, Published by HANetf. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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General

Update: MakerDAO to Launch $100M DAI Vault Backed by Real World Loans

Last week, MakerDAO decided to launch a DAI vault backed by loans originated by Huntingdon Valley Bank to create DeFi’s largest stablecoin pool backed by real world assets.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Special Reports

Staked ETH Vigilantes

Staked ETH (stETH) from Lido Finance is a derivative digital asset that represents ETH staked in the Ethereum Beacon Chain. All stETH token balances grow to accrue ETH staking rewards and the underlying ETH.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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General

Stable Is as Stable Does

Stable Is as Stable Does. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Special Reports

UST Crash & Proposal to Fork Terra, Reset LUNA Supply

The dust is far from settled after UST crashed this week and took Terra down with it. Though UST was not backed by any assets, the crash destroyed at least $72B of value from UST and LUNA market capitalization alone.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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Weekly Spotlight

Weekly Highlights

Weekly Highlights. Download the PDF here for access to the report.
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General

Bridges, You Are the Weakest Link

Bridges, You Are the Weakest Link. Download the PDF here for access to the report.
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General

Research Note: Layer 1 Competition

Research Note: Layer 1 Competition. Download the PDF here for access to the report.
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General

CRV Wars: Over before it Started

CRV Wars: Over before it Started. Download the PDF here for access to the report.
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General

Perpetual Protocol

Perpetual Protocol is a decentralized derivatives exchange that operates perpetual futures markets across Ethereum Layer 1 and xDai Layer 2 networks…
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General

dYdX

dYdX. Download the PDF here for access to the report.
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General

Aave

The Aave protocol is a set of smart contracts that operate open-source money markets. The protocol started on Ethereum and has launched parallel protocols on numerous Layer 2 and other Layer 1 networks…
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General

Alchemix

Alchemix. Download the PDF here for access to the report.
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General

Yearn

Yearn. Download the PDF here for access to the report.
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General

Curve

Curve provides an automated and decentralized digital asset exchange where users can earn revenue for providing liquidity to traders.
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General

Balancer

Balancer. Download the PDF here for access to the report.
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General

Synthetix

Synthetix. Download the PDF here for access to the report.
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General

MakerDAO

MakerDAO. Download the PDF here for access to the report.
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General

Bancor

Bancor. Download the PDF here for access to the report.
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General

SushiSwap

SushiSwap. Download the PDF here for access to the report.
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General

Components of a collapse: DeFi and Iron Finance

Components of a collapse: DeFi and Iron Finance. Download the PDF here for access to the report.
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General

Compound

Compound. Download the PDF here for access to the report.
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General

May 19th, 2021: a primer

May 19th, 2021: a primer. Download the PDF here for access to the report.
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General

Alts latest: ETH, mid-caps, and what’s next

Alts latest: ETH, mid-caps, and what’s next. Download the PDF here for access to the report.
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General

CME BTC and ETH latest: on dry powder

CME BTC and ETH latest: on dry powder. Download the PDF here for access to the report.
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General

Retail sentiment and the BTC/ETH divergence

Retail sentiment and the BTC/ETH divergence. Download the PDF here for access to the report.
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General

A brief history of DOGE

A brief history of DOGE. Download the PDF here for access to the report.
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General

The Bitcoin contango and CME futures: a discussion of discussions

The Bitcoin contango and CME futures: a discussion of discussions. Download the PDF here for access to the report.
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General

‘Crypto weekends’ in 2021

‘Crypto weekends’ in 2021. Download the PDF here for access to the report.
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General

Q2 in review: Ethereum’s doldrums

Q2 in review: Ethereum’s doldrums. Download the PDF here for access to the report.
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General

The death of the Grayscale trade: a primer

The death of the Grayscale trade: a primer. Download the PDF here for access to the report.
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General

Reassessing the ‘Coinbase effect’

Reassessing the ‘Coinbase effect’. Download the PDF here for access to the report.
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General

Regional markets and the Asian session

Regional markets and the Asian session. Download the PDF here for access to the report.
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General

Institutional latest: CME and spot

Institutional latest: CME and spot. Download the PDF here for access to the report.
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General

Tether latest: the NYAG case

Tether latest: the NYAG case. Download the PDF here for access to the report.
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General

Tackling Tether FUD

Tackling Tether FUD. Download the PDF here for access to the report.
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General

Debunking the BTC ‘short squeeze’

Debunking the BTC ‘short squeeze’. Download the PDF here for access to the report.
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General

Latest trends: retail spot, institutional

Latest trends: retail spot, institutional. Download the PDF here for access to the report.
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General

BTC and ETH: gauging current sentiment

BTC and ETH: gauging current sentiment. Download the PDF here for access to the report.
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General

BTC and ETH: gauging current sentiment

BTC and ETH: gauging current sentiment. Download the PDF here for access to the report.
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General

BTC, momentum, and drawdown risk

BTC, momentum, and drawdown risk. Download the PDF here for access to the report.
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General

The three big questions for BTC in 2021

The three big questions for BTC in 2021. Download the PDF here for access to the report.
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General

Explaining the 2020 ETF boom

Explaining the 2020 ETF boom. Download the PDF here for access to the report.
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General

Institutional latest: GBTC, CME, CFTC

Institutional latest: GBTC, CME, CFTC. Download the PDF here for access to the report.
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General

BTC at $13,500: why and where?

BTC at $13,500: why and where?. Download the PDF here for access to the report.
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General

BTC at $12,500: why and where?

BTC at $12,500: why and where?. Download the PDF here for access to the report.
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General

CME and Bakkt latest: is interest waning?

CME and Bakkt latest: is interest waning?. Download the PDF here for access to the report.
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General

Retail trends: spot, derivatives, DeFi

Retail trends: spot, derivatives, DeFi. Download the PDF here for access to the report.
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General

BTC: seasonality and Q4 outlook

BTC: seasonality and Q4 outlook. Download the PDF here for access to the report.
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General

SPX correlation latest: risk outlook for Q4

SPX correlation latest: risk outlook for Q4. Download the PDF here for access to the report.
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General

Alts in review: ETH and traditional large-caps

Alts in review: ETH and traditional large-caps. Download the PDF here for access to the report.
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General

Price action and regional markets: is the momentum there yet?

Price action and regional markets: is the momentum there yet?. Download the PDF here for access to the report.
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General

Institutional latest: CME and Bakkt

Institutional latest: CME and Bakkt. Download the PDF here for access to the report.
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General

Retail spot and derivatives latest: ‘higher than Dec 2017’?

Retail spot and derivatives latest: ‘higher than Dec 2017’?. Download the PDF here for access to the report.
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General

BTC and the bull trend: driver or passenger?

BTC and the bull trend: driver or passenger?. Download the PDF here for access to the report.
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General

The August 2nd flash crash

The August 2nd flash crash. Download the PDF here for access to the report.
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General

Quarterly premiums: watching for euphoria

Quarterly premiums: watching for euphoria. Download the PDF here for access to the report.
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General

The return of SPX-BTC correlation: cause for concern?

The return of SPX-BTC correlation: cause for concern?. Download the PDF here for access to the report.
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General

CME latest trends: OI, trader count, options

CME latest trends: OI, trader count, options. Download the PDF here for access to the report.
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General

Retail venues latest: a picture of stagnancy?

Retail venues latest: a picture of stagnancy?. Download the PDF here for access to the report.
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General

Alts, latest trends: ETH, ADA, LINK, ZEC

Alts, latest trends: ETH, ADA, LINK, ZEC. Download the PDF here for access to the report.
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General

BTC: Q2 in review

BTC: Q2 in review. Download the PDF here for access to the report.
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General

Difficulty and network processing power: recent trends

Difficulty and network processing power: recent trends. Download the PDF here for access to the report.
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General

Volatility compression: a gathering storm?

Volatility compression: a gathering storm?. Download the PDF here for access to the report.
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General

Doing the Bartman: June 2nd in perspective

Doing the Bartman: June 2nd in perspective. Download the PDF here for access to the report.
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General

Interest re-opened: trends in CME and retail

Interest re-opened: trends in CME and retail. Download the PDF here for access to the report.
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General

Alts in review: the outlook for Q3

Alts in review: the outlook for Q3. Download the PDF here for access to the report.
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General

After the halving: obsolence and ‘miner capitulation’

After the halving: obsolence and ‘miner capitulation’. Download the PDF here for access to the report.
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General

Halving and retail demand: a late bubble?

Halving and retail demand: a late bubble?. Download the PDF here for access to the report.
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General

CFTC latest: is institutional money returning?

CFTC latest: is institutional money returning?. Download the PDF here for access to the report.
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General

The halving: a brief examination

The halving: a brief examination. Download the PDF here for access to the report.
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General

BTC seasonality and the Q2 outlook

BTC seasonality and the Q2 outlook. Download the PDF here for access to the report.
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General

Past the abyss? This implications of $7000 (again)

Past the abyss? This implications of $7000 (again). Download the PDF here for access to the report.
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General

Examining the SPX-BTC truism

Examining the SPX-BTC truism. Download the PDF here for access to the report.
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General

Three thoughts on alts in Q2

Three thoughts on alts in Q2. Download the PDF here for access to the report.
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General

‘All correlations go to 1’

‘All correlations go to 1’. Download the PDF here for access to the report.
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General

At the abyss: the potential implications of $7000

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With a Far-Reaching Network and a Seasoned Team, Enigma is a Trusted Global Partner

Created in 2017 as a subsidiary of the Makor Group, a leading cross-asset brokerage group, Enigma is among the world’s first institutional-grade providers of digital-assets liquidity, bridging the gap between traditional finance and blockchain.

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Press releases

Enigma Securities Receives FINRA Approval for Corporate Equity Securities Broker Services

NEW YORK, June 28, 2022 /PRNewswire/ -- Enigma Securities ("Enigma"), a Broker-Dealer providing liquidity and advisory services, today announced it has received Financial Industry Regulatory Authority (FINRA) approval to operate as a broker-dealer for corporate equity securities.
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Enigma Securities Advances Digital Asset FinTech with Release of ‘Front-to-Back Crypto Hub’ for Institutions

NEW YORK, June 22, 2022 /PRNewswire/ -- Enigma Securities ("Enigma"), a comprehensive financial services firm for digital assets liquidity and advisory, today announced the release of Enigma X, its front-to-back crypto hub for institutions. Enigma X enables crypto services, including currency spot trading, borrowing and lending, news and market research tracking and derivatives monitoring and clearing.
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ETC Group expands Institutional-Grade Liquidity Pool with Appointment of Enigma Securities as new Authorised Participant (AP)

June 9th, 2022. London/Frankfurt: ETC Group ( www.etc-group.com ), Europe's leading specialist provider of institutional-grade, digital asset-backed securities, announces that Enigma Securities, a full-service international financial services firm for digital assets liquidity and advisory, has been appointed as Authorised Participant.
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Enigma Securities Appoints Barry Finkelstein as Global Head of Investment Banking

NEW YORK, May 17, 2022 /PRNewswire/ -- Enigma Securities ("Enigma"), a full-service financial services firm for digital assets liquidity and advisory, today announced the appointment of Barry Finkelstein as its Global Head of Investment Banking. Finkelstein brings more than 30 years of experience in trading, structuring and distribution at leading Wall Street firms. Most recently, he led business development at Layer-1 blockchain technology company, Algorand Inc.
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Welcome to Enigma

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1. Acceptance of the Terms

1.1. These terms of use (the “Terms”) set out the terms and conditions under which you (“You” or “Your” as appropriate) can purchase Bitcoin (“Crypto” or “Cryptocurrency”) from Enigma Markets Inc. (the “Service”). Enigma Markets Inc. (“Us”, “We” or “Enigma” as appropriate) is a Delaware corporation Enigma is currently registered as a Money Services Business (“MSB”) with the Financial Crimes Enforcement Network (“FinCEN”).

1.2. You acknowledge and agree that by engaging with Enigma to execute transactions or generally using the Service in any way, You will be deemed to have accepted these Terms. You understand that each order submitted to Enigma may result in Your entry into one or more binding transactions (a “Transaction”). You assume full financial and performance responsibility for all such Transactions created as a result of the process set out in these Terms.

2. Amendment to the Terms

Unless We consider any amendment to be a material change to the Terms (in which case we will provide You with not less than 7 (seven) days’ prior notice (a “Notice”)), We reserve the right to amend the Terms at any time without prior notice to You. All changes shall take effect immediately and an updated version of the Terms shall be published on Our website. If You do not agree to any amendment, you should stop using the Service immediately.

3. Risks

3.1. The risk of loss in trading or holding Cryptocurrency can be high. The price of a given Cryptocurrency can vary greatly in a very short span of time. Many Cryptocurrencies are not backed by any asset, commodity or central bank. You should ensure that You fully understand these risks and You may therefore wish to take legal or financial advice before using the Service or placing any order.

3.2. The regulatory regime governing blockchain technologies, cryptocurrencies, and tokens is uncertain, and new regulations or policies may materially adversely affect the development of our Services and the value of your cryptocurrencies.

3.3. You accept the inherent security risks of providing information and dealing online over the Internet and agree that We have no liability or responsibility for any breach of security unless it is due to our gross negligence.

4. Users

4.1. You must set up and maintain an account to use the Service and submit orders (an “Account”). Your eligibility to use the Service will be assessed on a case-by-case basis and may depend on the country where You reside. Enigma reserves the right to refuse to allow You to establish an account or use the Service for any reason at its absolute discretion.

4.2. You represent and warrant that Your use of the Service, and Your entry into each Transaction to which You become a party complies with applicable law and regulation in Your jurisdiction, including but not limited to: (i) legal capacity and any other applicable legal requirements in Your jurisdiction for trading Cryptocurrency and using the Service, (ii) any foreign exchange or regulatory restrictions applicable to Your use of the Service, and (iii) the receipt of any governmental or other consents (or exemptions) that You may need to be obtain prior to Your use of the Service.

4.3. Nothing in these Terms shall be deemed, nor shall cause, You and Enigma to be treated as partners or joint ventures.

5. The Service

5.1. We will process Your orders in relation to Crypto at our absolute discretion. In order to provide the Service, Enigma may rely on data and prices of third-party exchanges. You acknowledge and understand that Enigma has no responsibility or liability for the provision of the Related Services, which, whether provided by an affiliate or otherwise, are outside the scope of the Terms. Any authority granted by You to Enigma shall extend to the providers of the Related Services, where applicable.

5.2. The Service includes Crypto exchange services (namely the buying and selling of Crypto). Enigma shall not, nor is it under any obligation to, provide You with any advice in relation to the merits or suitability of any Transaction and You are required to rely on Your own judgement before submitting any order to Us.

6. Orders

6.1. You must submit all orders in accordance with these Terms and/or the Enigma Website if applicable. You acknowledge that We reserve the right to decline any order for any reason (including Your breach of the Terms, inadequate funds in Your Account, or market conditions).

6.2. If, following acceptance but before execution of Your order, an event takes place which, in Our reasonable opinion, means it is no longer reasonable to execute such order (for example regulatory action, change in law or following the request of an applicable third-party exchange), You acknowledge that We may cancel Your order without any liability to You (and update Your account balance accordingly).

6.3. Irrespective of the time at which (or medium by which) You place an order, You agree to pay or receive the price at the time the associated Transaction is executed. You acknowledge and understand that the nature of the Crypto market means that the price at which Your Transaction is executed may vary significantly from the price quoted at the time of Your order. Enigma is not liable for any such price fluctuations. The Service is independent of any exchanges, and We are under no obligation to quote or refer to a particular price or index.

6.4. We will use our reasonable endeavours to act upon any request to cancel or amend an order before it is confirmed. You acknowledge and agree that if We are unable to cancel or amend an order before it is confirmed, You will be bound by the resultant Transaction. You agree to accept the price in which Transactions are executed as final and binding.

6.5. You acknowledge and understand that all Transactions are entered into on a matched principal basis and Enigma owes You no fiduciary duty in the course of providing the Service. For the avoidance of doubt, nothing in these Terms shall preclude Enigma (or any other party approved by Enigma at Our absolute discretion) from acting as a market maker (“Market Making Activity”). Any terms, conditions, agreements or rules in relation to Market Making Activity shall be provided separately.

7. Funds

7.1. Enigma’s fund settlement process operates on either a same day (T+0) or delayed settlement basis. All purchase orders to buy Crypto must be paid for with an amount of fiat currency equal to the relevant purchase price plus any associated fees transmitted to and received by our relevant account(s). For all sell orders to dispose of Crypto: (i) the associated number of Crypto; and (ii) an amount of fiat currency equal to the associated fee, must be transmitted to and received by our relevant accounts. Failure to conclude that will result in the rejection of future orders. A list of fiat currencies We accept is available on Our website (“Accepted Currency”) or will be communicated to You in due course. If You attempt to make a payment in any currency other than an Accepted Currency, then such payment may be rejected.

7.2. It is Your responsibility to ensure that You hold sufficient cleared funds and Crypto (when applicable) in your bank account and Crypto wallet to satisfy the settlement of any Transaction. The Service does not include the provision of margin.

7.3. Non-custodial disclaimer.

8. Price

8.1. You acknowledge and understand that when You enter into a Transaction via the Service, the fee for the Transaction will be a fee determined by Us, taking into account market conditions. Such price may include a spread (the “Spread”) as against the price at which we purchased the Crypto. You acknowledge and understand that the size of the Spread can vary dependent on market conditions.

8.2. You also acknowledge that any third-party fees, such as conversion charges and/or card processing fees, will be passed on to You (“Third Party Fees” and together with the Spread, the “Fees”).

9. Cash/Crypto Transmission

9.1. We will establish and maintain one or more bank accounts or digital wallets for accepted fiat currency or Crypto to be transmitted to us by You prior to an Order being executed. You acknowledge and accept that once transmitted, the funds or Crypto will be held in Our account in Our name, or in that of a third-party firm, which may be an affiliate of ours (including, without limitation, Makor Securities London Limited) (a “Third Party Account Provider”). You acknowledge and understand that: (i) the funds or Crypto transmitted to such accounts or digital wallets are Enigma’s own funds or Crypto; and (ii) the transfer of funds or Crypto from You to Us is solely referable to Your purchase of Crypto and is not a deposit.

9.2. In the event of our insolvency, in respect of fiat currency, You will rank as an unsecured creditor of ours for return of such funds if such entitlement arises under the relevant insolvency laws of Delaware; and (vi) in the event of insolvency in relation to the Third Party Account Provider, Enigma may only have an unsecured debt claim against the Third Party Account Provider on Your behalf if such entitlement arises under the relevant insolvency laws of England. Enigma does not accept any liability for losses resulting from its insolvency or the insolvency of a Third-Party Account Provider. Your claim in respect of Crypto if such a claim arises following the insolvency of the Enigma Wallet holder may be limited to an unsecured debt claim, and the Crypto or cash sum You receive in respect of Your Crypto may be insufficient to satisfy Your Account balance.

9.3. In respect of the transfer of the funds, we will aim to [credit Your Account with the corresponding amount of Crypto (provided the terms of your Order have been accepted by Us) within 1 business day of receipt of the relevant Order. In respect of withdrawals, we will debit Your Account, when agreed upon delay, with the corresponding amount of fiat currency following Your authorisation.] The corresponding funds will then settle to Your bank account within 3 business days. We are not responsible for any delay in the settlement of a Transaction resulting from circumstances beyond our control, including any third-party systems failure.

9.4. You acknowledge and understand that the Crypto Which Enigma supports may change from time to time.

9.5. You will not be entitled to interest in respect of any funds or Crypto held by Us, a Third-Party Account Provider or an Enigma Wallet holder.

9.6. As described above, Your money and Cryptocurrency will not be segregated. Consequently, If We or a Third- Party Account Provider become insolvent, there may be delays in identifying individual assets, increasing the risk of loss.

10. Tax

It is Your sole responsibility to determine whether and to what extent any taxes apply to the Transactions and, if applicable to report and remit the correct payment to the appropriate tax authorities. Enigma does not and will not provide any advice with respect to the tax implications of Your entry into Transactions.

11. Delivery

Following the execution of a Transaction, delivery will occur on Enigma’s records and Your Account balance will be updated accordingly.

12. Security

12.1. You shall be solely responsible for controlling and monitoring the use of the password to Your Account, and shall not permit any person to provide Your password, to any third party. You acknowledge and agree that You shall be bound by any actions taken through the use of Your Account including all orders and the resulting Transactions or other arrangements, as applicable, whether or not such actions were authorised by You. We accept no liability for any loss that You may sustain due to compromise of Your password and/or Account that did not arise directly as a result of Our loss or negligence. If You believe Your Account has been compromised, You should contact us immediately at info@enigma-securities.io.

12.2. By registering an Account, You agree to be bound by and to indemnify and hold Enigma harmless for any and all actions taken by, or omissions of, individuals using an instruction to transfer Crypto to a digital wallet (a “Wallet”).

13. Information Provided

13.1. Any information provided to You via Our website or otherwise does not amount to investment advice. You may use this information for the purposes of the Service only, and shall not disseminate or reproduce the information in any way. Any price quoted or referenced on the website if applicable may be different from the execution price of the Transaction. Enigma does not recommend that any cryptocurrency should be bought, sold, acquired or held by You and will not be held responsible for any decision you make in this regard based on the information provided by Enigma

13.2. Enigma does not provide investment, tax, or legal advice, and you are solely responsible for assessing whether any transaction you enter into via Our Service is appropriate for you based on your objectives, financial circumstances and risk tolerance.

13.3. We provide the Service on an “as-is” basis to facilitate the submission of orders and execution of Transactions and any reasonably related activity (the “Permitted Purpose”).

14. Your Warranties

14.1. You hereby represent and warrant that:

14.1.1. You have the right, power, and ability to enter into and perform under the Terms;

14.1.2. You have, and comply with, all necessary rights, consents, licenses, and approvals for the operation of your business and to allow you to access and use Our Service in compliance with the Terms and applicable laws, rules, and regulations;

14.1.3. You are authorized to initiate transactions from Your bank account and digital wallet;

14.1.4. In the event that You authorize Enigma to transfer Crypto to a Wallet, whether hosted by You or a third party, such Wallet is beneficially owned by You.

14.2. In connection with the foregoing representations and warranties, You further agree as follows:

14.2.1. You shall indemnify, defend and hold Enigma harmless for any and all claims, losses or damages arising from or related to any breach of the foregoing representations and warranties; and

14.2.2. Enigma may terminate Your Account immediately upon written notice in the event that it concludes, in its reasonable opinion, that You have materially breached any representation or warranty under this Agreement (following applicable notice, grace and cure periods).

15. No Warranty

15.1. The Service is provided “as is” and “as available” without warranties of any kind, whether express or implied. To the fullest extent permissible pursuant to applicable law, we, our subsidiaries, affiliates, and licensors make no express warranties and hereby disclaim all implied warranties regarding the Service and any part of it (including, without limitation, the site, any smart contract, or any external websites), including the implied warranties of merchantability, fitness for a particular purpose, non-infringement, correctness, accuracy, or reliability. We do not make any representations or warranties that access to any part of the Services will be uninterrupted or error-free.

15.2. Neither Enigma nor its affiliates gives any express or implied warranties or representations (including warranties of satisfactory quality and fitness) relating to: (i) any third party systems or protocols used to support the Service; (ii) the long-term value of any Crypto; (iii) the liquidity of any Crypto market or exchange; (iv) the accuracy or timeliness of historical Crypto price data made available to You by one of Our brokers; (v) the amount of time needed to execute a Transaction following an order (which is dependent on factors outside of Our control); (vi) the immutability or security of blockchain or underlying software underpinning any Crypto or any digital wallet (including the Enigma Wallet) associated with the Service (together, the “Technology”); or (vii) the freedom of the Technology from any errors, viruses or disruption.

16. Limitation of Liability

TO THE FULLEST EXTENT PROVIDED BY LAW, IN NO EVENT WILL ENIGMA, ITS AFFILIATES, OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS, OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE SERVICE OR ANY WEBSITES LINKED TO IT, INCLUDING ANY INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF OPPORTUNITY, LOSS OF REPUTATION, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT, OR OTHERWISE, EVEN IF FORESEEABLE.

WITHOUT LIMITATION TO THE ABOVE, IN NO EVENT SHALL ENIGMA BE LIABLE FOR ANY AMOUNT GREATER THAN THE VALUE OF THE CRYPTO AND FIAT CURRENCY THAT IS CREDITED TO, (OR WHERE APPLICABLE, OUGHT TO HAVE BEEN CREDITED TO, YOUR ACCOUNT) AT THE TIME OF ANY ALLEGED LOSS OR CLAIM.

YOU ACKNOWLEDGE AND AGREE THAT WE HAVE MADE THE SERVICE AVAILABLE TO YOU AND ENTERED INTO THESE TERMS IN RELIANCE UPON THE WARRANTY DISCLAIMERS AND LIMITATIONS OF LIABILITY SET FORTH HEREIN, WHICH REFLECT A REASONABLE AND FAIR ALLOCATION OF RISK BETWEEN THE PARTIES AND FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN US. WE WOULD NOT BE ABLE TO PROVIDE THE SERVICE TO YOU WITHOUT THESE LIMITATIONS.

THE FOREGOING DOES NOT AFFECT ANY LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

17. Termination

We may, at Our sole discretion: (i) close Your Account for any reason by giving seven (7) days’ notice or (ii) with or without prior notice suspend or terminate the Service (or any part of the Service) without liability to You. If Your Account is in credit on the date of termination (howsoever occurring), We will aim to transfer the funds and/or Crypto to Your bank account or Crypto wallet (as applicable) within 3 working days minus any Fees or payments that are due to Us.

18. Supplemental Terms

If You have agreed to use Connectivity or a Trading Platform (both as defined in Appendix 1), the terms of Appendix 1 will also apply.

19. Governing Law

These Terms are governed by and construed in accordance with the laws of the state of Delaware, without giving effect to any choice or conflict of law provisions.

20. DISPUTE RESOLUTION; ARBITRATION

PLEASE READ THIS SECTION CAREFULLY. IT MAY SIGNIFICANTLY AFFECT YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT. ALL DISPUTES ARISING OUT OF OR RELATED TO THESE TERMS OF USE OR ANY ASPECT OF THE RELATIONSHIP BETWEEN YOU AND US, WHETHER BASED IN CONTRACT, TORT, STATUTE, FRAUD, MISREPRESENTATION, OR ANY OTHER LEGAL THEORY, WILL BE RESOLVED THROUGH FINAL AND BINDING ARBITRATION BEFORE A NEUTRAL ARBITRATOR INSTEAD OF IN A COURT BY A JUDGE OR JURY, AND YOU AGREE THAT THE COMPANY AND YOU ARE EACH WAIVING THE RIGHT TO SUE IN COURT AND TO HAVE A TRIAL BY A JURY. YOU AGREE THAT ANY ARBITRATION WILL TAKE PLACE ON AN INDIVIDUAL BASIS; CLASS ARBITRATIONS AND CLASS ACTIONS ARE NOT PERMITTED AND YOU ARE AGREEING TO GIVE UP THE ABILITY TO PARTICIPATE IN A CLASS ACTION.

Any disputes arising from this Agreement shall be decided by binding arbitration which shall be conducted, at the request of any party, in Philadelphia, Pennsylvania, before one arbitrator designated by the American Arbitration Association (the “AAA“), in accordance with the Commercial Arbitration Rules of the AAA, and to the maximum extent applicable, the United States Arbitration Act (Title 9 of the United States Code). Notwithstanding anything in this Agreement to the contrary, any party may proceed to a court of competent jurisdiction to obtain equitable relief at any time. An arbitrator shall have no authority to award punitive damages or other damages not measured by the prevailing party’s actual damages. To the maximum extent practicable, an arbitration proceeding under this Agreement shall be concluded within 180 days of the filing of the dispute with the AAA. This arbitration clause shall survive any termination, amendment, or expiration of the Agreement and if any provision of this arbitration clause is found to be unenforceable, the remaining parts of the arbitration clause shall not be affected and shall remain fully enforceable.

21. NO CLASS ACTION

YOU AND THE COMPANY AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

22. CONTACT US

All feedback, comments and questions on the Terms should be sent to info@enigma-securities.io.

Appendix 1

Electronic Connectivity and Trading Platform Facilities

A1 Access and use: We may permit You to place transaction orders in cryptocurrencies with us by direct electronic communication to us through an electronic system (“Connectivity”). We may also provide You with electronic access to a platform to enable You to execute transactions electronically (the “Trading Platform”) which includes all related software and accompanying documentation. Your right to use Connectivity or the Trading Platform and any financial data, market and business information provided on or through Connectivity at the Trading Platform (“Information”) is limited to use for the purpose of receiving and viewing Information for the transmission and execution of transaction orders. We may amend the terms of this Appendix 1 with respect to the addition of a financial instrument or an execution issue to our Connectivity or Trading Platform services.

A.3 Licences: Connectivity and the Trading Platform are owned by us (and/or an affiliated entity) or third parties that license their use to us (and/or an affiliated entity) (the “Licensors”). You acknowledge and agree that Connectivity and the Trading Platform are the exclusive property of the Company and/or the Licensors, and that the Information is the exclusive property of ours and/or the Licensors or such licensor’s third party vendors or their suppliers, and we the Licensor and such third party vendors and their suppliers retain all proprietary right, title, and interest, including, without limitation, copyright, in the Information. We grant You a personal, limited, revocable, non-exclusive, non-transferable license to access and use Connectivity and the Trading Platform under the terms of this Appendix 1. You shall not copy, license, sell, transfer, make available Connectivity or the Trading Platform or information to any other person. You shall not remove or alter any copyright notice or other proprietary or restrictive notice contained in Connectivity, the Trading Platform or Information.

A.4 Access responsibility: You are responsible for obtaining and maintaining, at Your cost, the necessary computer equipment and internet access required to enable You to access and use the Connectivity, the Trading Platform and Information. You are responsible for any equipment, software or internet access provided by a third party which You require to access and use Connectivity and the Trading Platform. You acknowledge and agree that we (and affiliated entities) are not responsible for any Connectivity or Trading Platform interface applications with third parties such as execution venues, information vendors and other investment firms such as derivative exchange execution and clearing brokers.

A.5 Information changes: Certain Information may be provided by third parties. If any of the Information ceases to be furnished by any third party vendors in a manner which is compatible with Connectivity or the Trading Platform, we may remove as much Information as is affected, without advance notice, without incurring any liability to You, and without any change to any of Your payment or other obligations. Further, we may modify, amend, alter, update, supplement or replace Connectivity or the Trading Platform software (which, among other things, determines the functionality and appearance of some or all of the Connectivity or Trading Platform features) from time to time, in whole or in part, without any notice (except for material changes to functionality as reasonably practical), without incurring any liability to You, and without any change to any of Your payment or other obligations. You acknowledge and agree that Your use of Connectivity or the Trading Platform after any modification, amendment, alteration, update, supplement or replacement shall constitute Your acceptance of such modification, amendment, alteration, update, supplement or replacement.

A.6 Security: You shall keep any user name, password or access code (referred to in this Appendix 1 as “User Codes“) provided to You for Connectivity or access to the Trading Platform confidential and secure. You shall be responsible for the safeguarding and security of Your User Codes. You shall be solely responsible for all orders and transactions arising from any person’s Connectivity use or access to the Trading Platform using Your User Codes notwithstanding any lack of our access controls or the failure of any access controls we may have implemented. You shall notify us immediately and in writing in the event of (i) any loss or theft of part or all of the User Codes; or (ii) any actual or suspected unauthorised use of the User Codes; or (iii) any actual or suspected breach of security or confidentiality of the User Codes. You shall maintain with respect to Connectivity and the Trading Platform adequate systems and controls to ensure that (i) use is only by authorized personnel; (ii) order accuracy, order size, compliance with credit and order limits is checked and validated; and (iii) order direction, order duplication and order retransmission errors do not occur. You will ensure that no computer viruses, worms or similar items are introduced through Connectivity to our computer systems and networks or to the Trading Platform. You will be responsible for the installation and proper use of any virus detection software which we may require.

A.7 System risk: Connectivity the Trading Platform and Information is provided “as is”. The entire risk as to the quality and performance of Connectivity or the Trading Platform or Information and any third party related goods and services is with You. We (or affiliated entities) make no warranties (express or implied), representations, or guarantees as to merchantability, fitness for any particular purpose, performance, service continuity, absence of interruptions or errors or otherwise with respect to Connectivity or the Trading Platform or Information. Neither we nor our affiliated entities nor licensors, third party vendors or suppliers of Connectivity, the Trading Platform or Information, shall have any obligation or liability to maintain Connectivity, the Trading Platform or Information or to supply any corrections, updates or releases. We reserve the right, in our absolute discretion, and without prior notice, to reject cancel or refuse to display or seek execution of any order for any reason. We may at any time and in our absolute discretion impose and vary limits and conditions upon the placement of orders using Connectivity or the Trading Platform including limits on size, order types and execution venues and conditions concerning collateral requirements.

A.8 No execution guarantee: You acknowledge and agree that Connectivity or Trading Platform order entry does not guarantee order execution. We will not be responsible for any execution of orders that are not received by reason of Connectivity or Trading Platform malfunction or otherwise. When You use Connectivity or the Trading Platform, unless You have received an electronic order acknowledgement, Your order will be deemed not to have been received. In the event You dispute or deny knowledge of any order which has been electronically acknowledged we will in either case be entitled immediately to liquidate or otherwise offset the position in the relevant investment or financial instrument without prejudice to such other rights we may have under this Appendix 1. Execution venues may reject or cancel Your transaction orders for which we accept no responsibility. You acknowledge that: (1) orders may be delayed for many reasons and the price of a security at the time of order entry may not be the same as the price of such security at the time such order is executed; and (2) cancellation of orders may not be possible prior to execution, even if the cancellation order is received prior to the time at which the order was to be executed.

A.9 System compliance training: You shall provide Your employees that use the Connectivity or Trading Platform with adequate information and training upon (i) the terms of this Appendix 1; and (ii) execution venue rules which we or our affiliated entities are subject and which You must also comply to ensure there is no breach of such rules by us or an affiliated entity. With respect to Connectivity or Trading Platform use for transactions on regulated markets, multilateral trading facilities or exchanges You shall neither engage in, nor facilitate, nor fail to take reasonable steps to prevent:

  • any action or any course of conduct that has the effect, or may be expected to have the effect, of artificially and/or abnormally moving the price or value of any cryptocurrency, or securities admitted to the regulated market or exchange, or any instrument underlying such cryptocurrency or securities or the level of any index of which such cryptocurrency or securities are a component;
  • entering artificial orders or otherwise entering into or causing any artificial transaction;
  • reporting a fictitious transaction or any other false data to the regulated market, exchange or other competent authority or causing such data to be input into any of their systems;
  • any action or any course of conduct that creates or may reasonably be expected to create any false or misleading impression as to the market in, or price or value of, any cryptocurrency, securities or related financial instruments;
  • any other action or any other course of conduct that may damage the integrity and the transparency of the regulated market or exchange; or
  • agreeing or acting in concert with, or providing any assistance to, any person with a view to or in connection with any action or course of conduct referred to in paragraphs (a) to (f) inclusive.

A.10 System misuse: You shall not use the Connectivity or Trading Platform for orders or transactions for or in connection with any activity which may constitute a fraudulent or illegal purpose or market abuse or otherwise use the Connectivity or Trading Platform in contravention of any applicable law and regulatory provisions. For the purposed of this Appendix 1 “market abuse” means behaviour in relation to investments which involves insider dealing, market manipulation or market distortion in breach of applicable laws or regulatory provisions. You undertake to familiarise Yourself and comply with any applicable law and regulatory provisions concerning the short sale of securities if You seek to execute a short sale transaction and You will ensure that Your use of the Connectivity or the Trading Platform will not result in a breach by us (or any affiliated entity) of any applicable law and regulatory provisions concerning the short sale of securities or any terms of this Appendix 1 concerning short sale orders or transactions.

A.11 Order entry error: If an order entry is made using the Connectivity or Trading Platform by mistake or does not reflect the intended transaction (an “erroneous order”) then You shall be responsible for amending or canceling such orders as necessary and for closing any resultant positions subject to our rights in this Appendix 1.

A.12 Pre–execution controls: We reserve the right to limit Your use of Connectivity and the Trading Platform and apply pre-execution trading controls as may be appropriate to preserve compliance with applicable law or this Appendix 1 or any other trading limits or redirection which may be notified to You. With respect to the use of Connectivity or the Trading Platform, we shall have the right to reject or cancel orders or enter off-setting orders or restrict Your ability to enter further orders in the event You act in breach of the terms concerning Connectivity or the Trading Platform in this Appendix 1. Connectivity or the Trading Platform, Your access thereto and any information, service feature or function provided by means of Connectivity or the Trading Platform may be changed, limited, suspended, discontinued or terminated by us at any time without notice or liability.

A.13 Disclaimer: Neither ourselves nor any affiliated entity (nor any director, officer or employee thereof) shall have any liability to You or any third party for any losses (including loss of profits), expenses, costs, claims, damages (including punitive, special or exemplary damages) or for any account of profits or other restitution of any kind whatsoever arising from or incidental to the provision of access to or use of Connectivity or the Trading Platform or Information (including any failure to provide access to Connectivity or the Trading Platform or any operational failure of Connectivity or the Trading Platform or the introduction of any viruses, worms or similar items into Your computer systems and networks through Connectivity or the Trading Platform or any software we provide).

A.14 Indemnity: You shall indemnify and hold us and any affiliated entity harmless (and our respective employees, officers, directors and agents) from and against any and all claims, demands, legal actions or proceedings and all liabilities, damages, losses, expenses and costs (including legal and accounting fees and expenses) (collectively “Losses“) arising out of or incidental to Your use of, or access to, Connectivity or the Trading Platform or any associated third party services or equipment provided under the terms of this Appendix 1 except to the extent that any such Losses, as finally determined by a Court of competent jurisdiction, were caused solely and directly by dishonest or wilful misconduct of us or any affiliated entity.

A.15 Third–party software: To the extent that You are using Connectivity or the Trading Platform in conjunction with a third-party software (including, but not limited to, an algorithm), we expressly disclaim liability for any Losses arising from such third-party software. This disclaimer is without prejudice to any other provision of the Terms or Appendix 1.

1. Acceptance of the Terms

1.1. These terms of use (the “Terms”) set out the terms and conditions under which you (“You” or “Your” as appropriate) can trade cryptocurrencies, for example Bitcoin or Ethereum (“Crypto” or “Cryptocurrency”) using Enigma Securities Limited (the “Service”). Enigma Securities Ltd (“Us”, “We” or “Enigma” as appropriate) is a company registered in England and Wales with company number 11114339 and registered office 6th Floor, 30 Panton Street, London SW1Y 4AJ, UK. Enigma is registered with the Financial Conduct Authority (the “FCA”) for certain cryptoasset activity (with reference number 930442) and is an Appointed Representative of Makor Securities London Ltd which is authorised and regulated (with reference number 625054) by the FCA.

1.2 .  You acknowledge and agree that by engaging with Enigma to execute transactions or generally using the Service in any way, You will be deemed to have accepted these Terms. You understand that each order submitted to Enigma (whether by voice broking, email or via any other electronic interface that We may provide and/or accept) may result in Your entry into one or more binding transactions (a “Transaction”). You assume full financial and performance responsibility for all such Transactions created as a result of the process set out in these Terms.

2. Amendment to the Terms

Unless We consider any amendment to be a material change to the Terms (in which case we will provide You with not less than 7 (seven) days’ prior notice (a “Notice”)), We reserve the right to amend the Terms at any time without prior notice to You. All changes shall take effect immediately and an updated version of the Terms shall be published on Our website. If You do not agree to any amendment then You should stop using the Service immediately.

3. Risks

3.1. Cryptocurrencies such as Bitcoin and Ethereum are not currently classified as a type of regulated financial instrument under the current UK or European regulatory frameworks (including MiFID II). This means that the Service and Related Services are not governed by the same rules and regulations that apply to similar services relating to other products, for example, derivatives. You will not therefore benefit from the statutory client money protections available to clients receiving regulated investment services, including access to the Financial Services Compensation Scheme and the Financial Ombudsman for dispute resolution. The FCA client money regime, as set out in the FCA’s Client Asset Sourcebook, will also not apply to our provision of the Services to You.

3.2. The risk of loss in trading or holding Cryptocurrency can be high. The price of a given Cryptocurrency can vary greatly in a very short space of time. Many Cryptocurrencies are not backed by any asset, commodity or central bank. You should ensure that You fully understand these risks and You may therefore wish to take legal or financial advice before using the Service or placing any order.

4. Users

4.1. You must set up and maintain an account to use the Service and submit orders (an “Account”). Your eligibility to use the Service will be assessed on a case-by-case basis and may depend on the country where You reside. Enigma reserves the right to refuse to allow You to establish an account or use the Service for any reason at its absolute discretion.

4.2. You represent and warrant that Your use of the Service, and Your entry into each Transaction to which You become a party complies with applicable law and regulation in Your jurisdiction, including but not limited to: (i) legal capacity and any other applicable legal requirements in Your jurisdiction for trading Cryptocurrency and using the Service, (ii) any foreign exchange or regulatory restrictions applicable to Your use of the Service, and (iii) the receipt of any governmental or other consents (or exemptions) that You may need to be obtain prior to Your use of the Service.

4.3. Nothing in these Terms shall be deemed, nor shall cause, You and Enigma to be treated as partners or joint ventures.

5. The Service

5.1. We will process Your orders in relation to Crypto at our absolute discretion. In order to provide the Service, Enigma may rely on data and prices of third party exchanges and/or arrange for orders to be executed with or through an unaffiliated third party (the “Related Services”). You acknowledge and understand that Enigma has no responsibility or liability for the provision of the Related Services, which, whether provided by an affiliate or otherwise, are outside the scope of the Terms. Any authority granted by You to Enigma shall extend to the providers of the Related Services, where applicable.

5.2. The Service includes Crypto exchange services (namely the buying and selling of Crypto). Enigma shall not, nor is it under any obligation to, provide You with any advice in relation to the merits or suitability of any Transaction and You are required to rely on Your own judgement before submitting any order to Us.

6. Orders

6.1. You must submit all orders in accordance with these Terms and/or the Enigma Website if applicable. You acknowledge that We reserve the right to decline any order for any reason (including Your breach of the Terms, inadequate funds in Your Account, or market conditions).

6.2. If, following acceptance but before execution of Your order, an event takes place which, in Our reasonable opinion, means it is no longer reasonable to execute such order (for example regulatory action, change in law or following the request of an applicable third-party exchange), You acknowledge that We may cancel Your order without any liability to You (and update Your account balance accordingly).

6.3. Irrespective of the time at which (or medium by which) You place an order, You agree to pay or receive the price at the time the associated Transaction is executed. You acknowledge and understand that the nature of the Crypto market means that the price at which Your Transaction is executed may vary significantly from the price indicated at the time of Your order. Enigma is not liable for any such price fluctuations. The Service is independent of any exchanges, and We are under no obligation to quote or refer to a particular price or index.

6.4. We will use our reasonable endeavours to act upon any request to cancel or amend an order. You acknowledge and agree that if We are unable to cancel or amend an order, You will be bound by the resultant Transaction. You agree to accept the price in which Transactions are executed as final and binding.

6.5. You acknowledge and understand that all Transactions are entered into on a matched principal basis and Enigma owes You no fiduciary duty in the course of providing the Service. For the avoidance of doubt, nothing in these Terms shall preclude Enigma (or any other party approved by Enigma at Our absolute discretion) from acting as a market maker (“Market Making Activity”). Any terms, conditions, agreements or rules in relation to Market Making Activity shall be provided separately.

7. Funds

7.1. Enigma’s fund settlement process operates on either a same day (T+0) or delayed settlement basis. All purchase orders to buy Crypto must be paid for with an amount of fiat currency equal to the relevant purchase price plus any associated fees transmitted to and received by our relevant account(s). For all sell orders to dispose of Crypto: (i) the associated number of Crypto; and (ii) an amount of fiat currency equal to the associated fee, must be transmitted to and received by our relevant accounts. Failure to conclude that will result in the rejection of future orders. A list of fiat currencies We accept is available on Our website (“Accepted Currency”) or will be communicated to You in due course. If You attempt to make a payment in any currency other than an Accepted Currency, then such payment may be rejected.

7.2. It is Your responsibility to ensure that You hold sufficient cleared funds and Crypto (when applicable) to satisfy the settlement of any Transaction. The Service does not include the provision of margin.

8. Price

8.1. You acknowledge and understand that when You enter into a Transaction via the Service, the fee for the Transaction will be a fee determined by Us, taking into account market conditions. Such price may include a spread (the “Spread”) as against the price available to Us to fill Your order. You acknowledge and understand that the size of the Spread can vary dependent on market conditions.

8.2. You also acknowledge that any third-party fees, such as conversion charges and/or card processing fees, will be passed on to You (“Third Party Fees” and together with the Spread, the “Fees”).

9. Cash/Crypto Transmission

9.1. We will establish and maintain one or more bank accounts or digital wallets for accepted fiat currency or Crypto to be transmitted to us by You prior to an Order being executed. You acknowledge and accept that once transmitted, the funds or Crypto will be held in Our account in our Our name, or in that of a third-party firm, which may be an affiliate of ours (including, without limitation, Makor Securities London Limited) (a “Third Party Account Provider”). You acknowledge and understand that: (i) Your funds or Crypto will therefore be held in the same bank account or digital wallet as Enigma’s own funds or Crypto; (ii) the rules and regulations of the FCA’s Client Asset Sourcebook do not apply to You and/or Your use of the Service and Related Services and therefore You may not benefit from the FCA client money regime for the protection of Your funds or Crypto post transmission to Our account; (iii) the transfer of funds or Crypto from You to Us is solely referable to Your purchase of Crypto or Our purchase of Your Crypto and is not therefore a deposit as defined under the FCA rules.

9.2. In the event of our insolvency, in respect of fiat currency, You will rank as an unsecured creditor of ours for return of such funds if such entitlement arises under the relevant insolvency laws of England; and (vi) in the event of insolvency in relation to the Third Party Account Provider, Enigma may only have an unsecured debt claim against the Third Party Account Provider on Your behalf if such entitlement arises under the relevant insolvency laws of England. Enigma does not accept any liability for losses resulting from its insolvency or the insolvency of a Third-Party Account Provider. Your claim in respect of Crypto if such a claim arises following the insolvency of the Enigma Wallet holder may be limited to an unsecured debt claim, and the Crypto or cash sum You receive in respect of Your Crypto may be insufficient to satisfy Your Account balance.

9.3. In respect of the transfer of the funds, we will aim to credit Your Account with the corresponding amount of Crypto (provided the terms of your Order have been accepted by Us) within 1 business day of receipt of the relevant Order. In respect of withdrawals, we will debit Your Account, when agreed upon delay, with the corresponding amount of fiat currency following Your authorisation. The corresponding funds will then settle to Your bank account within 3 business days. We are not responsible for any delay in the settlement of a Transaction resulting from circumstances beyond our control, including any third-party systems failure.

9.4. You acknowledge and understand that the Crypto Which Enigma supports may change from time to time.

9.5. You will not be entitled to interest in respect of any funds or Crypto held by Us, a Third-Party Account Provider or an Enigma Wallet holder.

9.6. As described above, Your money and Cryptocurrency will not be segregated. Consequently, If We or a Third- Party Account Provider become insolvent, there may be delays in identifying individual assets, increasing the risk of loss.

10. Tax

It is Your sole responsibility to determine whether and to what extent any taxes apply to the Transactions and, if applicable to report and remit the correct payment to the appropriate tax authorities. Enigma does not and will not provide any advice with respect to the tax implications of Your entry into Transactions.

11. Delivery

Following the execution of a Transaction, delivery will occur on Enigma’s records and Your Account balance will be updated accordingly.

12. Security

12.1. You shall be solely responsible for controlling and monitoring the use of the password to Your Account, and shall not permit any person to provide Your password, to any third party. You acknowledge and agree that You shall be bound by any actions taken through the use of Your Account including all orders and the resulting Transactions or other arrangements, as applicable, whether or not such actions were authorised by You. We accept no liability for any loss that You may sustain due to compromise of Your password and/or Account that did not arise directly as a result of Our loss or negligence. If You believe Your Account has been compromised, You should contact us immediately at info@enigma-securities.io.

12.2. By registering an Account, You agree to be bound by and to indemnify and hold Enigma harmless for any and all actions taken by, or omissions of, individuals using an instruction to transfer Crypto to a digital wallet (a “Wallet”).

13. Information Provided

13.1. Any information provided to You via Our website or otherwise does not amount to investment advice. You may use this information for the purposes of the Service only, and shall not disseminate or reproduce the information in any way. Any price quoted or referenced on the website if applicable may be different from the execution price of the Transaction.

13.2. We provide the Service on an “as-is” basis to facilitate the submission of orders and execution of Transactions and any reasonably related activity (the “Permitted Purpose”).

14. Your Warranties

14.1. You hereby represent and warrant that:

14.1.1. You are and have been in compliance with the laws of the United Kingdom and any other jurisdiction that may have an interest in any transaction under this agreement including any anti-money laundering laws or any anti bribery and corruption laws of any other countries or jurisdictions that are applicable to such transactions and will remain in compliance with all such laws for as long as You are party to the Terms;

14.1.2. You have not taken and will not take any actions in furtherance of an offer, payment, promise to pay or authorisation of the payment or giving of, or a request or acceptance of, money, Crypto or anything else of value, to or by any other person (whether or not a government official) while knowing that all or any portion of the money or value offered, given or promised to such other person is for the purpose of securing the improper performance of that person’s function or the misuse of that person’s position; and

14.1.3. In the event that You authorise Enigma to transfer Crypto to a Wallet, whether hosted by You or a third party, such Wallet is beneficially owned by You.

14.2. In connection with the foregoing representations and warranties, You further agree as follows:

14.2.1. You shall indemnify, defend and hold Enigma harmless for any and all claims, losses or damages arising from or related to any breach of the foregoing representations and warranties; and

14.2.2. Enigma may terminate Your Account immediately upon written notice in the event that it concludes, in its reasonable opinion, that You have materially breached any representation or warranty under this Agreement (following applicable notice, grace and cure periods).

15. No Warranty

15.1. The Services are provided on an “as is” and “as available” basis. To the maximum extent permitted by applicable law, we specifically disclaim any implied warranties of title, merchantability, fitness for a particular purpose and/or non-infringement. We do not make any representations or warranties that access to any part of the Services will be uninterrupted or error-free.

15.2. Neither Enigma nor its affiliates gives any express or implied warranties or representations (including warranties of satisfactory quality and fitness) relating to: (i) any third party systems or protocols used to support the Service; (ii) the long-term value of any Crypto; (iii) the liquidity of any Crypto market or exchange; (iv) the accuracy or timeliness of historical Crypto price data made available to You by one of Our brokers; (v) the amount of time needed to execute a Transaction following an order (which is dependent on factors outside of Our control); (vi) the immutability or security of blockchain or underlying software underpinning any Crypto or any digital wallet (including the Enigma Wallet) associated with the Service (together, the “Technology”); or (vii) the freedom of the Technology from any errors, viruses or disruption.

16. Limitation of Liability

Enigma shall not be liable to You or any person for any losses, liabilities, damages, claims, costs or expenses arising from: (i) the performance of any Related Services; (ii) any delay in the execution of a Transaction; or (iii) the occurrence of any event describe in Clause 17, above (except where such an event was caused by Our negligence, fraud or wilful default). Without limitation to the above, in no event shall Enigma be liable for any amount greater than the value of the Crypto and fiat currency that is credited to, (or where applicable, ought to have been credited to, Your Account) at the time of any alleged loss or claim.

17. Termination

We may, at Our sole discretion: (i) close Your Account for any reason by giving seven (7) days’ notice or (ii) with or without prior notice suspend or terminate the Service (or any part of the Service) without liability to You. If Your Account is in credit on the date of termination (howsoever occurring), We will aim to transfer the funds and/or Crypto to Your bank account or Crypto wallet (as applicable) within 3 working days minus any Fees or payments that are due to Us.

18. Supplemental Terms

If You have agreed to use Connectivity or a Trading Platform (both as defined in Appendix 1), the terms of Appendix 1 will also apply.

19. Governing Law

These Terms are governed by and construed in accordance with the law of England and Wales. The courts of England and Wales will have exclusive jurisdiction to adjudicate any dispute arising under or in connection with these Terms.

Appendix 1

Electronic Connectivity and Trading Platform Facilities

A1 Access and use: We may permit You to place transaction orders in cryptocurrencies and derivatives thereof (including foreign exchange) with us by direct electronic communication to us through an electronic system (“Connectivity”). We may also provide You with electronic access to a facility to enable You to execute transactions electronically through us on execution venues that we (or an affiliated entity) are a member or participant and which we may notify to You (the “Trading Platform”) which includes all related software and accompanying documentation. Your right to use Connectivity or the Trading Platform and any financial data, market and business information provided on or through Connectivity at the Trading Platform (“Information”) is limited to use for the purpose of receiving and viewing Information for the transmission and execution of transaction orders. We may amend the terms of this Appendix 1 with respect to the addition of a financial instrument or an execution issue to our Connectivity or Trading Platform services.

A.2 Central counterparty, clearing agent or prime broker: The terms of this paragraph A.2. apply to cryptocurrency derivatives. We may provide Connectivity to the Trading Platform for the execution of transactions on an exchange, multilateral trading facility or other regulated market or trading platform (where the transaction is cleared through a central counterparty) for execution of transactions. We may make Your access to and use of Connectivity to the Trading Platform for execution of such transactions conditional upon Your execution of a give-up agreement on terms approved by us with (i) a clearing member and/or an execution broker member of the relevant exchange, multilateral trading facility or regulated market; or (ii) or a prime broker participant or central-counterparty for the relevant multilateral trading facility, regulated market or trading platform. We may pay a portion of the fees or charges we receive from You for our services to a central counterparty or operator of an exchange, multilateral trading facility, other regulated market or trading platform.

A.3 Licence: Connectivity and the Trading Platform are owned by us (and/or an affiliated entity) or third parties that licence their use to us (and/or an affiliated entity). You acknowledge and agree that Connectivity and the Trading Platform are the exclusive property of ours and/or the Licensors, and that the Information is the exclusive property of ours and/or the Licensors or such licensor’s third party vendors or their suppliers, and we the Licensor and such third party vendors and their suppliers retain all proprietary right, title, and interest, including, without limitation, copyright, in the Information. We grant You a personal, limited, revocable, non-exclusive, non-transferable licence to access and use Connectivity and the Trading Platform under the terms of this Appendix 1. You shall not copy, license, sell, transfer, make available Connectivity or the Trading Platform or information to any other person. You shall not remove or alter any copyright notice or other proprietary or restrictive notice contained in Connectivity, the Trading Platform or Information.

A.4 Access responsibility: You are responsible for obtaining and maintaining, at Your cost, the necessary computer equipment and internet access required to enable You to access and use the Connectivity, the Trading Platform and Information. You are responsible for any equipment, software or internet access provided by a third party which You require to access and use Connectivity and the Trading Platform. You acknowledge and agree that we (and affiliated entities) are not responsible for any Connectivity or Trading Platform interface applications with third parties such as execution venues, information vendors and other investment firms such as derivative exchange execution and clearing brokers.

A.5 Information changes: Certain Information may be provided by third parties. If any of the Information ceases to be furnished by any third party vendors in a manner which is compatible with Connectivity or the Trading Platform, we may remove as much Information as is affected, without advance notice, without incurring any liability to You, and without any change to any of Your payment or other obligations. Further, we may modify, amend, alter, update, supplement or replace Connectivity or the Trading Platform software (which, among other things, determines the functionality and appearance of some or all of the Connectivity or Trading Platform features) from time to time, in whole or in part, without any notice (except for material changes to functionality as reasonably practical), without incurring any liability to You, and without any change to any of Your payment or other obligations. You acknowledge and agree that Your use of Connectivity or the Trading Platform after any modification, amendment, alteration, update, supplement or replacement shall constitute Your acceptance of such modification, amendment, alteration, update, supplement or replacement.

A.6 Security: You shall keep any user name, password or access code (referred to in this Appendix 1 as “User Codes“) provided to You for Connectivity or access to the Trading Platform confidential and secure. You shall be responsible for the safeguarding and security of Your User Codes. You shall be solely responsible for all orders and transactions arising from any person’s Connectivity use or access to the Trading Platform using Your User Codes notwithstanding any lack of our access controls or the failure of any access controls we may have implemented. You shall notify us immediately and in writing in the event of (i) any loss or theft of part or all of the User Codes; or (ii) any actual or suspected unauthorised use of the User Codes; or (iii) any actual or suspected breach of security or confidentiality of the User Codes. You shall maintain with respect to Connectivity and the Trading Platform adequate systems and controls to ensure that (i) use is only by authorised personnel; (ii) order accuracy, order size, compliance with credit and order limits is checked and validated; and (iii) order direction, order duplication and order retransmission errors do not occur. You will ensure that no computer viruses, worms or similar items are introduced through Connectivity to our computer systems and networks or to the Trading Platform. You will be responsible for the installation and proper use of any virus detection software which we may require.

A.7 System risk: Connectivity the Trading Platform and Information is provided “as is”. The entire risk as to the quality and performance of Connectivity or the Trading Platform or Information and any third party related goods and services is with You. We (or affiliated entities) make no warranties (express or implied), representations, or guarantees as to merchantability, fitness for any particular purpose, performance, service continuity, absence of interruptions or errors or otherwise with respect to Connectivity or the Trading Platform or Information. Neither we nor our affiliated entities nor licensors, third party vendors or suppliers of Connectivity, the Trading Platform or Information, shall have any obligation or liability to maintain Connectivity, the Trading Platform or Information or to supply any corrections, updates or releases. We reserve the right, in our absolute discretion, and without prior notice, to reject cancel or refuse to display or seek execution of any order for any reason. We may at any time and in our absolute discretion impose and vary limits and conditions upon the placement of orders using Connectivity or the Trading Platform including limits on size, order types and execution venues and conditions concerning collateral requirements.

A.8 No execution guarantee: You acknowledge and agree that Connectivity or Trading Platform order entry does not guarantee order execution. We will not be responsible for any execution of orders that are not received by reason of Connectivity or Trading Platform malfunction or otherwise. When You use Connectivity or the Trading Platform, unless You have received an electronic order acknowledgement, Your order will be deemed not to have been received. In the event You dispute or deny knowledge of any order which has been electronically acknowledged we will in either case be entitled immediately to liquidate or otherwise offset the position in the relevant investment or financial instrument without prejudice to such other rights we may have under this Appendix 1. Execution venues may reject or cancel Your transaction orders for which we accept no responsibility. You acknowledge that: (1) orders may be delayed for many reasons and the price of a security at the time of order entry may not be the same as the price of such security at the time such order is executed; and (2) cancellation of orders may not be possible prior to execution, even if the cancellation order is received prior to the time at which the order was to be executed.

A.9 System compliance training: You shall provide Your employees that use the Connectivity or Trading Platform with adequate information and training upon (i) the terms of this Appendix 1; and (ii) execution venue rules which we or our affiliated entities are subject and which You must also comply to ensure there is no breach of such rules by us or an affiliated entity. With respect to Connectivity or Trading Platform use for transactions on regulated markets, multilateral trading facilities or exchanges You shall neither engage in, nor facilitate, nor fail to take reasonable steps to prevent:

    • any action or any course of conduct that has the effect, or may be expected to have the effect, of artificially and/or abnormally moving the price or value of any cryptocurrency, or securities admitted to the regulated market or exchange, or any instrument underlying such cryptocurrency or securities or the level of any index of which such cryptocurrency or securities are a component;

    • entering artificial orders or otherwise entering into or causing any artificial transaction;

    • reporting a fictitious transaction or any other false data to the regulated market, exchange or other competent authority or causing such data to be input into any of their systems;

    • any action or any course of conduct that creates or may reasonably be expected to create any false or misleading impression as to the market in, or price or value of, any cryptocurrency, securities or related financial instruments;

    • any other action or any other course of conduct that may damage the integrity and the transparency of the regulated market or exchange; or

    • agreeing or acting in concert with, or providing any assistance to, any person with a view to or in connection with any action or course of conduct referred to in paragraphs (a) to (f) inclusive.

A.10 System misuse: You shall not use the Connectivity or Trading Platform for orders or transactions for or in connection with any activity which may constitute a fraudulent or illegal purpose or market abuse or otherwise use the Connectivity or Trading Platform in contravention of any applicable law and regulatory provisions. For the purposed of this Appendix 1 “market abuse” means behaviour in relation to investments which involves insider dealing, market manipulation or market distortion in breach of applicable laws or regulatory provisions. You undertake to familiarise Yourself and comply with any applicable law and regulatory provisions concerning the short sale of securities if You seek to execute a short sale transaction and You will ensure that Your use of the Connectivity or the Trading Platform will not result in a breach by us (or any affiliated entity) of any applicable law and regulatory provisions concerning the short sale of securities or any terms of this Appendix 1 concerning short sale orders or transactions.

A.11 Order entry error: If an order entry is made using the Connectivity or Trading Platform by mistake or does not reflect the intended transaction (an “erroneous order”) then You shall be responsible for amending or cancelling such orders as necessary and for closing any resultant positions subject to our rights in this Appendix 1.

A.12 Pre-execution controls: We reserve the right to limit Your use of Connectivity and the Trading Platform and apply pre-execution trading controls as may be appropriate to preserve compliance with Applicable Regulations or this Appendix 1 or any other trading limits or redirection which may be notified to You. With respect to use of Connectivity or the Trading Platform we shall have the right to reject or cancel orders or enter off-setting orders or restrict Your ability to enter further orders in the event You act in breach of the terms concerning Connectivity or the Trading Platform in this Appendix 1. Connectivity or the Trading Platform, Your access thereto and any information, service feature or function provided by means of Connectivity or the Trading Platform may be changed, limited, suspended, discontinued or terminated by us at any time without notice or liability.

A.13 Disclaimer: Neither ourselves nor any affiliated entity (nor any director, officer or employee thereof) shall have any liability to You or any third party for any losses (including loss of profits), expenses, costs, claims, damages (including punitive, special or exemplary damages) or for any account of profits or other restitutionary relief of any kind whatsoever arising from or incidental to the provision of access to or use of Connectivity or the Trading Platform or Information (including any failure to provide access to Connectivity or the Trading Platform or any operational failure of Connectivity or the Trading Platform or the introduction of any viruses, worms or similar items into Your computer systems and networks through Connectivity or the Trading Platform or any software we provide).

A.14 Indemnity: You shall indemnify and hold us and any affiliated entity harmless (and our respective employees, officers, directors and agents) from and against any and all claims, demands, legal actions or proceedings and all liabilities, damages, losses, expenses and costs (including legal and accounting fees and expenses) (collectively “Losses“) arising out of or incidental to Your use of, or access to, Connectivity or the Trading Platform or any associated third party services or equipment provided under the terms of this Appendix 1 except to the extent that any such Losses, as finally determined by a Court of competent jurisdiction, were caused solely and directly by dishonest or wilful misconduct of us or any affiliated entity.

A.15 Third party software: To the extent that You are using Connectivity or the Trading Platform in conjunction with a third party software (including, but not limited to, an algorithm), we expressly disclaim liability for any Losses arising from such third party software. This disclaimer is without prejudice to any other provision of the Terms or Appendix 1.