Zap (Strike) Europe Limited

Last updated 1 June 2026

About this disclosure

Zap (Strike) Europe Limited, a Malta company with registered number C114533 and LEI 984500457TAB0A3BZ224, doing business as “Strike” ("Strike", "we", "us") is authorised as a crypto-asset service provider (CASP) by the Malta Financial Services Authority (MFSA) for the purposes of Regulation (EU) 2023/1114 (“MiCA”)

This document is intended for European (EEA/UK) customers of Strike, and sets out how Strike identifies, prevents, manages, and discloses conflicts of interest in connection with the crypto-asset services it provides.

It is published pursuant to Article 72(2) of MiCA and relevant regulatory technical standards including Commission Delegated Regulation (EU) 2025/1142.

What is a conflict of interest?

A conflict of interest arises when the personal, financial, or other interests of Strike, its employees, or its associated persons may interfere with Strike's ability to act impartially and in the best interests of its clients.

For these purposes, a conflict of interest exists where Strike or a connected person is in any of the following situations:

  • it is likely to make a financial gain, avoid a financial loss, or receive another benefit, at the expense of a client;
  • it has an interest in the outcome of a service provided to the client which is distinct from the client's own interest;
  • it has a financial interest or other incentive to favour one client over another;
  • it receives an inducement from a person other than the client in connection with a service provided to that client; or
  • it carries out the same business as the client.

Conflicts of interest can take place (without limitation):

  • between customers and Strike;
  • between shareholders, managing directors and Strike
  • between Strike and its employees
  • between customers and other companies of the Strike group;
  • between customers themselves

How we manage conflicts of interest

Strike has adopted a Conflict of Interest Policy, which sets out how we identify, prevent, manage, and where necessary disclose conflicts of interest. The policy is reviewed at least annually and updated as required.

Our management framework includes the following measures:

  • A Conflicts of Interest Register, which is an internal register which documents all identified actual and potential conflicts of interest, Strike's assessment of each, and the measures taken to prevent, manage, or disclose them.
  • An Order Execution Policy, which governs how client transactions are executed and sets out Strike's best execution obligations and order routing methodology.
  • Remuneration arrangements designed not to create conflicts of interest: Strike does not link staff remuneration to customer transaction volumes or revenues.
  • A Personal Account Dealing Policy, for the connected persons of Strike.
  • Outside Business Activity (OBA) disclosure, prior approval, and monitoring requirements applicable to all management body members and employees.
  • Information barriers and need-to-know principles where needed to prevent inappropriate information flows.
  • Governance requirements, including the obligation on management body members to disclose and abstain from voting on matters where they have a conflict of interest.
  • Independent compliance oversight.

In some cases, a conflicts of interest may be unavoidable. In this case, Strike will inform the customers regarding the conflict of interest and disclose it accordingly. Disclosure of a conflict of interest to a client is not a substitute for prevention or management. This document is that disclosure.

Disclosed conflicts of interest

The following conflicts of interest have been identified by Strike. Where a conflict cannot be fully prevented, Strike manages it through the measures described and, where required, discloses it to clients.

Fee based service
Strike charges fees to clients in connection with its crypto-asset services. Any fee charged to a client represents a cost to that client and revenue to Strike. This is an inherent feature of any commercial service. Fees are disclosed to clients in the product interface and in the Terms of Service prior to any transaction. Clients are not required to transact.

Transaction model
Strike executes client transactions as principal and executes matching principal transactions with market makers and liquidity providers (a matched principal model). In this capacity, Strike acts as the counterparty to client transactions and determines the price and execution venue for the matched trade. Strike is subject to best execution obligations, and Strike has implemented an Order Execution Policy which includes an order routing engine designed to achieve best execution for clients and sets objective routing criteria. Strike does not exercise discretion over client prioritisation.

Regulatory data collection and disclosure
As a regulated crypto-asset service provider authorised by the Malta Financial Services Authority (MFSA), Strike is required by EU and national law (including MiCA, the Transfer of Funds Regulation, and applicable laws in Malta) to collect, retain, and in certain circumstances disclose to regulators, tax authorities, and other competent authorities information relating to its clients and their transactions. This is a legal requirement of Strike, but is not in the interest of clients therefore representing a potential conflict. Strike's obligations in this regard are a requirement of law. They are disclosed and acknowledged by customers in the Terms of Service. Strike discloses this potential conflict.

Group structure and intra-group activities
Strike is part of a corporate group, and certain of its staff hold roles at, or have responsibilities for, other group entities. Interrelationships within a group can in principle give rise to decisions that favour group interests over client interests. Similarly Strike relies on its parent group for enterprise technology and infrastructure services. A conflict could arise if group interests influenced service quality, prioritisation, or decision-making to the detriment of Strike or its clients. Strike manages these conflicts by using robust governance arrangements within its entities. All intra-group services (technology, infrastructure, customer support) are governed by a formal Intercompany Services Agreement with defined service levels, performance standards, audit rights, and exit provisions. Strike's Board retains full independence and oversight.

Outside business activities
Members of Strike's management body and employees may hold external roles or interests (outside business activities, or OBAs) separate from their roles at Strike. If these exist, these may in principle create conflicts between an individual's external interests and their duties to Strike and its clients. OBAs are subject to mandatory disclosure, prior Board approval, and ongoing monitoring under the Conflict of Interest Policy. Certain OBAs are prohibited without explicit written approval, including roles at competing crypto-asset service providers.

Personal account dealing
Staff and management body members may hold or transact in crypto-assets, including bitcoin, in a personal capacity. As required by MiCA, Strike has implemented a Personal Account Dealing Policy.

Remuneration
Variable remuneration linked to transaction volumes or revenues could in principle create an incentive for staff to act in ways inconsistent with fair client treatment. Strike does not link staff remuneration to customer transaction volumes or revenues. Strike's remuneration arrangements are designed not to create or incentivise conflicts of interest.

Order execution and liquidity allocation
In periods of constrained liquidity or market volatility, executing a transaction for one client could in principle affect execution quality for a subsequent client where liquidity is limited. This risk is mitigated through automated execution arrangements, multiple liquidity providers with deep liquidity, objective and pre-determined routing criteria, and the absence of discretionary client prioritisation.