Zap (Strike) Europe Limited

(Version 1 | 1 June 2026)

1. Introduction

Zap (Strike) Europe Limited (registration number C114533), doing business as “Strike”, registered at 171 Old Bakery Street, Valletta, Malta (VLT 1455) (the “Firm” or “Zap”), is incorporated in Malta and licensed and regulated by the Malta Financial Services Authority (MFSA) as a Crypto-Asset Service Provider under Regulation (EU) 2023/1114 on Markets in Crypto-Assets (“MiCA”), and the Markets in Crypto-Assets Act (Ch.647) of Malta, including to provide.

  • exchange of crypto-assets for funds
  • exchange of crypto-assets for other crypto-assets

(together, “Conversion Services”), alongside its other MiCA crypto-asset services.

2. Scope

The purpose of this Policy is to set out and specify:

  • the non-discriminatory commercial policy of the Firm relating to the types of clients that the Firm agrees to transact with and the conditions to be met by those clients;
  • the crypto-asset prices provided by the Firm; and
  • other provisions relating to executions by the Firm.

3. Eligible Clients

3.1 Types

The Firm will serve natural persons in their own capacity (“Individuals”) and other eligible legal entities (“Entities” aka ‘businesses’). Individuals and Entities are expected to be retail investors, but may also include professional investors and eligible counterparty entities.

“Entities” includes limited liability entities (such as limited liability corporations, however described in different jurisdictions), limited partnerships, partnerships, trusts, and other entity types having separate legal personality that are not Individuals. The Firm may limit the types of Entities that are acceptable to it, including eligibility and non-eligibility criteria such as business activities, beneficial owners, or risk appetite.

3.2 Location

The Firm will permit applications by persons that are located in an Eligible Jurisdiction.

With respect to Individuals their location will be determined by residence. For instance a person resident in Malta will be deemed to be located in Malta regardless of their nationality.

With respect to Entities, their location will be determined by the jurisdiction of their incorporation or establishment. For instance a Malta incorporated limited company will be deemed to be located in Malta.

3.3 Eligible Jurisdictions

The Firm will maintain a list of its “Eligible Jurisdictions”. The Risk Committee is required to approve any addition of any new country or jurisdiction as an Eligible Jurisdiction.

The Firm’s core target market is the EU/EEA accessed via MiCA passporting rights.

3.4 Client Acceptance Policy

The Firm has established clear eligibility criteria for accepting new clients, ensuring compliance with Applicable Law, and the Firm’s risk management framework. The Client Acceptance Policy of the Firm is the main framework establishing the criteria and procedures for onboarding new clients.

The Firm has an efficient and streamlined client acceptance processes, which implement applicable regulatory requirements with due consideration being given to the business profile of the prospective client.

3.5 Onboarding; CDD

All clients of the Firm must meet the eligibility criteria established by the Firm, be duly onboarded and approved by the Firm in accordance with its Financial Crime Policy and related procedures, including passing applicable customer acceptance and due diligence (CDD) procedures including sanctions screening and verification, and being within the Firm’s risk appetite.

3.6 Exclusions

The Firm retains absolute discretion on the customers that it provides services to and will only provide crypto-asset services to clients that it is permitted to provide services to under applicable law, and that are within its risk appetite.

The Firm will not serve any person that has not been approved in accordance with the Firm’s customer due diligence (CDD) and other diligence or review procedures set out in the Firm’s Financial Crime Policy. The Firm may decline to serve, suspend services to, or cease serving (including terminating accounts) any Individual or Entity that is outside the Firm’s risk appetite, or which is no longer eligible for any reason as determined by the Firm.

4. Crypto-asset prices

4.1 Conversion Price

Where a client requests an exchange of crypto-assets for funds, or an exchange of crypto-assets for other crypto-assets (a “Conversion”) they will be shown a firm price (the “Firm Price”) for the relevant transaction in the App. The Firm Price will be determined by the Firm, as further described in paragraph 4.2 below.

The Firm Price for a transaction will be held for a stated duration, after which it will no longer be valid and may not be executed and must be refreshed. The duration for which the Firm Price is valid may be amended from time to time, and may be different for different types of Conversion.

A clients’ request for a Conversion will - if submitted by a client and accepted by the Firm - be executed at the Firm Price, or in respect of a recurring transaction, at the relevant Conversion price determined by the Firm at each recurring transaction time. If the Firm Price has expired at the time the client requests to execute the transaction, the client may need to request a new Firm Price or refresh their transaction.

4.2 Determining the Price

The Firm Price and the price of any Conversion of crypto-assets will be determined by the Firm. The Firm has a variety of inputs and pricing sources it may use to determine price quoted in respect of a transaction, including current market rates, and quotes provided by its liquidity providers (that the Firm may use to hedge its transactions with clients). The Firm will also take into account in its pricing the duration for which it holds the Firm Price for a Customer and the market volatility at the time of the relevant Firm Price, as well as the requested size of the transaction.

4.3 Fees

Conversions (when executed) are subject to fees, which are clearly disclosed to the relevant client both in the App, and on the Firm’s website. All prices shown by the Firm will include market spreads and margin, and the existence of market spreads and margin is disclosed to clients in the Firm’s Terms of Service.

All fees and charges of the Firm shall be transparent, reasonable, and applied consistently across all types of Clients. Any variations shall be based solely on objective factors such as account type, specific service agreements, volume tiering, and other acceptable matters determined by the Firm from time to time and shall be implemented on a non-discriminatory basis.

The Firm may run certain promotions or referral bonus programs. These rules will be non discriminatory, transparently communicated to customers, and applied using objective criteria among the Firm’s eligible customer base for that promotion or bonus program.

The Firm may adjust these fees, and its fee structure for instance the relevant tiers and fee-tiering, from time to time (clients will be shown the updated fees in the App and on the website).

4.4 Additional Transaction types

Target Buy/Sell

Target Buy/Sell are a type of transaction where the client requests a Conversion but only at a specified price (a “Target Price”). This may be to purchase a crypto-asset if the price falls to a certain level (a “Target Buy”) or to sell a crypto asset if its price rises to a certain level (“Target Sell”). Where a client submits a Target Buy/Sell request that is accepted by the Firm, the Firm provides the firm price of the relevant crypto-asset at the time the order is submitted. Provided that the order has not been cancelled, if the Conversion price of the relevant crypto-asset is at or exceeds the Target Price at any time, the relevant Conversion will be made at the Target Price based on the instruction of the client.

Recurring orders

Clients are able to submit ‘recurring instructions’ to the Firm (aka DCA or ‘recurring transactions’) to buy (or sell) a designated amount of a crypto-asset on a frequency that they determine from an available list provided by the Firm (for instance daily, weekly). If a Conversion is a recurring transaction, this will be considered a standing instruction (and request) from the Client to enter into a Conversion in the amount and at the time(s) they specify when establishing their recurring transaction. The relevant Conversion will be carried out by the Firm based on the Firm’s price for the relevant Conversion at the time.

5. Service Provision

​​The Firm shall provide Conversion Services to all eligible Clients under objective terms, conditions and criteria.

The Conversion Services are regularly updated to meet evolving market conditions, technological advancements, and regulatory changes. The Clients will be notified of any significant changes that may affect the Conversion Services.

All transactions will be undertaken on a “pre-funded” basis which means that the Client will be able to buy or sell a crypto assets only to the extent that his account has the necessary funding/ holding. This will avoid the risk of settlement failures.

5. Client reporting

5.1 Regular Reporting

The Firm provides Clients with regular reports detailing the status of their crypto-asset investments. These reports (referred to as account statements) are available in-App in a durable medium (PDF or CSV), and include summary of the Client’s account balance, asset holdings, and recent transactions in that report period. These are issued monthly, and annually.

The Clients’ holdings with the Firm are available through the App.

5.2 Ad-Hoc Reporting

Clients can request and obtain any past monthly reports (account statements) at any time from within the App. In exceptional circumstances, Clients may request statements by contacting the Firm’s customer support function, but this may be subject to reasonable ID verification to ensure customer privacy on the basis that account statements contain personal data including financial data, which the Firm does not routinely provide by email for security and privacy reasons.

7. Client communication

7.1 Clear and timely communication

The Firm shall provide clear, accurate, and timely communication to all Clients including:

Service Information: Clients will be provided access to all necessary information before entering into any agreement, including details about the Conversion Services, associated fees, and potential risks. This is provided and available in the Firm’s Terms of Service, and on the Firm’s website, available free of charge.

Ongoing Updates: The Firm will keep Clients informed about any changes to the Conversion Services, market conditions, or regulatory requirements that may affect them. This is expected to be by email to their account email address, or via in-App notifications, website posts, or a combination thereof.

Accessible Communication Channels: Multiple digital communication channels will be available to Clients, including email, and in-App chat, ensuring accessibility and responsiveness. The Firm does not currently offer phone support.

7.2 Risk disclosures

The Firm will provide Clients with detailed information about the risks associated with crypto-assets and the Conversion Services. This is provided and available in the Firm’s Terms of Service, available on the Firm’s website, available free of charge.

7.3 Customer support

The Firm offers market standard customer support to all Clients, including:

Customer support function: A dedicated customer support function will be available to assist Clients with any queries or issues related to the Conversion Services. This is accessible in-App, or via email. This will include any technical support necessary for the Firm’s services, including service access.

Educational Resources: The Clients will have access to educational materials and resources to enhance their understanding of crypto-assets and the related Conversion Services. This is provided at a group level at https://strike.me/en/learn/ and accessible to all persons free of charge on the web.

Complaints Management: The Clients have the right to submit complaints regarding any aspect of the Conversion Services provided by the Firm as set out below.

8. Complaints management

The Firm maintains a complaints policy/ procedures (the “Complaints Policy”) with effective and transparent procedures for the prompt, fair and consistent handling of complaints. Clients can file complaints free of charge with the Firm regarding any aspect of the Conversion Services. A complaint can be submitted through multiple channels, including email.

The Firm shall investigate all complaints in a timely and fair manner, and communicate the outcome of such investigations to Clients within a reasonable period. The Firm shall keep a record of all accepted complaints received from Clients and any measures taken in response thereto.

A summary of the Complaints Policy is available on the Firm’s website.

9. Obligations & Responsibilities of Clients

The principal obligations of Clients in relation to the Conversion Services are the following:

  • Accurate Information: The Clients must provide accurate and up-to-date information during the onboarding process and throughout the relationship. This includes promptly notifying the Firm of any changes to their personal or financial circumstances.

  • Compliance with Regulations: The Clients must comply with Applicable Law, including that related to AML-CFT. The Clients are responsible for ensuring that the source of their funds is legitimate and that they do not engage in any illicit activities.

  • Understanding Risks: The Clients are expected to fully understand the risks associated with investing in crypto-assets. The Firm provides educational resources and risk disclosures, but the Clients must take responsibility for their activities and decisions.

  • Use of Services: The Clients must use the Firm’s services in a lawful and ethical manner, adhering to the terms and conditions outlined in the service agreement. Any misuse of services may result in the termination of the client relationship.

10. Governance and Oversight

The Board is ultimately responsible for the performance of the Firm’s obligations with respect to Conversion Services and this Policy.

The Board has delegated responsibility to [the Risk Committee] to oversee the Firm’s compliance with this Policy and applicable law relating to Conversion Services.

The Firm is aware of its obligation to manage conflicts of interest, for instance under Article 72 MiCA. The Firm maintains a Conflict of Interest Policy for these purposes.

11. Updates and Review

This Policy will be reviewed at least annually.