Under REGULATION (EU) 2023/1114 ("MiCAR") Article 77(1), Crypto-asset service providers exchanging crypto-assets for funds or other crypto-assets shall establish a non-discriminatory commercial policy that indicates, in particular, the type of clients they agree to transact with and the conditions that shall be met by such clients. This policy is designed to satisfy that requirement. It applies to the trading of certain crypto assets OTC by DRW Europe BV (“DRW Europe”) with counterparties while providing the service of exchanging of crypto-assets for funds and other crypto-assets (“the in-scope services”).

DRW Europe will only provide in-scope services to institutional clients. DRW Europe will not onboard or offer liquidity directly to retail clients. DRW Europe shall allow access to its quotes for clients who satisfy the following criteria:

DRW Europe may decide to refuse to enter into or discontinue business relationships with clients on the basis of commercial considerations, including but not limited to the client’s credit status, the counterparty risk and the final settlement of the transaction, security or technology implications or any legal / regulatory restrictions.

Non-Discriminatory Commercial Policy

#### **Purpose and scope **

Under REGULATION (EU) 2023/1114 ("MiCAR") Article 77(1), Crypto-asset service providers exchanging crypto-assets for funds or other crypto-assets shall establish a non-discriminatory commercial policy that indicates, in particular, the type of clients they agree to transact with and the conditions that shall be met by such clients. This policy is designed to satisfy that requirement. It applies to the trading of certain crypto assets OTC by DRW Europe BV (“DRW Europe”) with counterparties while providing the service of exchanging of crypto-assets for funds and other crypto-assets (“the in-scope services”).  

#### **Clients **

DRW Europe will only provide in-scope services to institutional clients. DRW Europe will not onboard or offer liquidity directly to retail clients. DRW Europe shall allow access to its quotes for clients who satisfy the following criteria:  

1. have completed the on-boarding process and been approved as a counterparty in line with DRW Europe’s Client KYC Process, including meeting DRW Europe’s AML/CTF requirements; and 
2. have agreed terms with DRW Europe in respect of the client agreements that govern the relationship between the parties.

DRW Europe may decide to refuse to enter into or discontinue business relationships with clients on the basis of commercial considerations, including but not limited to the client’s credit status, the counterparty risk and the final settlement of the transaction, security or technology implications or any legal / regulatory restrictions.
