This Execution Policy outlines the principles and procedures followed by Norwegian Block Exchange AS ("NBX") when executing orders on behalf of clients in connection with OTC crypto-asset transactions, to ensure compliance with Article 15 of the Regulatory Technical Standards (RTS) under Article 62(5) of Regulation (EU) 2023/1114 (MiCA).
This policy applies to all OTC trades executed by NBX on behalf of its clients, where NBX acts to source liquidity from external venues or counterparties in order to fulfil client requests.
Settlement of fiat legs is limited to the client’s own verified bank account. Settlement of crypto-assets, including EMTs, is restricted to Travel Rule compliant wallets or to/from other Travel Rule compliant service providers.
NBX obtains express client consent to the execution policy before any OTC trade is executed. Consent is documented during the onboarding process.
NBX may execute orders on the following trading venues or through liquidity providers:
NBX selects execution venues based on the following criteria:
NBX does not receive any remuneration, discount, or non-monetary benefit in exchange for routing orders to a particular trading platform or counterparty. Venue selection is strictly based on best execution factors.
NBX takes all sufficient steps to achieve the best possible result for the client, considering the following factors:
Relative importance of these factors may vary depending on the client’s specific instructions or the characteristics of the trade.
Where NBX intends to execute orders outside a trading platform (e.g. via bilateral OTC counterparty), NBX will inform the client and obtain prior express consent for each such transaction.
Clients may provide specific instructions regarding execution (e.g. preferred venue or target price). NBX will follow such instructions to the extent possible but will notify the client that doing so may limit NBX's ability to achieve best execution.
NBX performs due diligence and ongoing quality assessment of all execution venues, including:
NBX has implemented controls to prevent misuse of sensitive client order information. Access to OTC order details is limited to authorized personnel, and internal handling follows strict segregation protocols.
Operational reversals, adjustments and error corrections related to settlements and transfers are governed by NBX’s Terms of Service §3.6 (Reversals and Error Corrections) and §21 (Transfer Services Terms). For OTC-related activity, Execution Policy - OTC governs execution, while Transfer Services Terms govern transfers/settlement.
This Execution Policy is available to clients upon request and is published through secure client channels. Clients are notified of any material changes in advance. The latest version is always available at www.nbx.com.
NBX maintains records of all OTC trades, including evidence of client consent, venue selection rationale, and execution quality assessments. NBX will demonstrate compliance with Article 78 of MiCA upon request by Finanstilsynet.
