Zap (Strike) Europe Limited

(Version 1 | 1 June 2026)

1. Introduction

Zap (Strike) Europe Limited d/b/a “Strike” (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 the cryptoasset service of execution of orders for crypto-assets on behalf of clients (“Order Execution Services”).

The Firm provides the services of exchange of crypto-assets for funds (together, “Conversion Services”), governed by its Conversion Services Policy. When providing Conversion Services it faces customers as principal, but obtains pricing from a variety of execution venues and executes back-to-back transactions with those execution venues, to ensure it is not exposed to market risk (on a matched principal basis). The Firm therefore considers this principal trading activity to be Order Execution Services as well as Conversion Services, and has implemented this Policy.

Article 78 of MiCA sets out requirements in relation to the execution of orders for crypto assets on behalf of clients. This includes that crypto asset service providers shall take all necessary steps to obtain the best possible result for clients when executing orders, taking into account price, costs, speed, likelihood of execution and settlement, size, nature, conditions of custody of the crypto assets or any other consideration relevant to the execution of the order.

The Firm is committed to executing client orders in line with these principles. To do so it has established effective arrangements including an assessment of execution venues and ongoing monitoring.

This Policy also serves to provide for the prompt, fair and expeditious execution of client orders and prevent the misuse by the Firm’s employees (or any group staff) of any information relating to client orders.

2. Scope

This Policy applies to all exchanges of crypto-assets for funds that are executed with a customer of the Firm where an offsetting transaction is executed with an execution venue so that the firm is carrying out back-to-back matched principal trading.

3. Order execution factors

When executing orders for crypto assets on behalf of clients the Firm will take all necessary steps to obtain the best possible result for clients taking into account factors of:

  • price,

  • costs,

  • speed,

  • likelihood of execution,

  • likelihood of settlement,

  • size,

  • nature,

  • any other consideration relevant to the execution of the order.

The only exception to this is where the client provides specific instructions for the execution of the order, or particular parts of the order (see Order Types). This includes but is not limited to specific instructions relating to price limits, timing and method of execution.

This policy provides for the prompt, fair and expeditious execution of client orders.

4. Order types, and order execution flow

4.1 Back-to-back transactions

The Firm operates on a back-to-back transaction trading basis. This means it executes customer orders as principal (which it considers to be exchange of crypto-assets for funds or other crypto-assets), but enters into an equal and offsetting transaction in the same amount simultaneously to ensure that the Firm is not exposed to market risk in the relevant crypto-asset(s) associated with that client order.

4.2 Standard buy or sell orders

The Firm executes customer conversions at a price based on the customer’s specific instructions. The customer will specify the amount of the order, the Firm will provide a quote, and the customer will explicitly instruct the order at that price.

Orders are executed exclusively under predefined conditions, without any possibility for the Client to customize execution parameters other than amount purchased / sold.

Once confirmed, the Firm will execute the order based on the order execution factors.

4.3 Target orders

The Firm executes customer target orders based on the customer’s specific instructions including with respect to price.

Target orders are an order from the customer to buy or sell a particular amount of fiat or crypto-asset, at a designated price set by the customer. If that price is reached, the Firm will execute that order.

Customers may specify an expiration, being the time period for which the order is valid (for example 24 hours, 7 days, 30 days, or ‘open until cancelled’), and may cancel the target order at any time before it is executed.

Once the Target Order price condition is met, the Firm will execute the order at that price based on the order execution factors.

Orders are executed exclusively under predefined conditions, without any possibility for the Client to customize execution parameters other than amount purchased / sold, the target price, and the expiry.

4.4 Recurring orders

The Firm executes recurring orders based on the customer’s specific instructions. The customer will specify:

  • the amount;
  • the frequency (e.g. hourly, daily, weekly, bi-weekly, monthly) the order should recur;

and when (date and time) the recurring order should start and end.

Orders are executed exclusively under predefined conditions, without any possibility for the Client to customize execution parameters other than amount purchased / sold, and the time(s).

The Firm will execute the order on the instructed schedule and at the instructed times and amounts, based on the order execution factors.

4.5 Cancellation

The Firm has a clear and transparent process for cancelling unexecuted orders. This applies to unexecuted Target Orders and future (unexecuted) Recurring Orders. Standard buy/sell orders once confirmed are executed immediately and cannot be cancelled.

5. Selecting and assessing execution venues

When initially selecting an execution venue, and when assessing the performance of execution venues on an ongoing basis, the Firm assesses, on at least an annual basis, the various execution factors detailed below. Initially, this assessment is based on expected performance of execution venues based on available information. Thereafter, this assessment is supplemented by performance monitoring data.

The Firm assesses the following factors:

  • The location (jurisdiction) of the venue;

  • The regulatory status of the venue;

  • The track record and reputation of the venue;

  • Liquidity available for the relevant crypto-asset and/or funds in question;

  • Speed and execution of settlement at the venue;

  • Execution quality (anticipated, or observed, as applicable) of the venue; and

  • Pricing and costs associated with the venue for the relevant trading pair.

Execution venues selected by the Firm are expected to be liquidity providers and market makers able to provide high quality execution and reliable liquidity (“liquidity partners” or “LPs”), but in most cases LPs are not authorised as a “trading platform” under MiCA (i.e. they are principal firms and market makers providing execution, and not multilateral systems bringing together multiple third party purchasing and selling interests). References to “execution venue” in this Policy is to the LPs currently utilised by the Firm for its execution of client orders. The Firm considers that a high quality LP may offer equivalent or superior execution compared with a trading platform, when considering the factors listed in this section as well as the best execution factors. Therefore all orders executed with an execution venue that is an LP will be executed outside a trading platform. For the purposes of Article 78(5) MiCA, clients are informed that their orders will be executed outside a trading platform, and a general agreement is obtained as part of the Firm’s terms of service agreed to by all clients.

6. Order routing

The Firm expects to be connected with and have the ability to execute orders with multiple execution venues. This connectivity is designed to provide operational resilience and continuity of service, including redundancy in the event that one execution venue is unavailable or impaired, and to enable the Firm to determine the most appropriate execution venue based on prevailing market conditions and prices quoted by that execution venue.

Client orders are routed through the Firm’s order routing engine, also referred to as its Order Routing engine. The Order Routing engine is an automated process that sources executable quotes from multiple available execution venues available to the Firm in respect of the given order or pair (e.g. BTC/EUR) in parallel for a given client order, rather than pre-determining a single execution venue in advance.

For each order, the Firm’s systems request quotes from all eligible execution venues that are available at the time the order is received. The quotes received are evaluated, and the Firm determines:

  • the price presented to the client; and

  • the execution venue with which the Firm executes the corresponding transaction.

The Firm’s current Order Routing logic prioritises price as the primary factor in achieving best execution. In normal market conditions, the Firm will execute the trade with the execution venue offering the most favourable economic outcome for the client, to enhance its execution quality, defined as:

  • for client orders to buy crypto-assets with fiat (e.g. buy BTC with EUR), the quote resulting in the highest net quantity of crypto-assets received by the client; and

  • for client orders to sell crypto-assets for fiat (e.g. sell BTC for EUR), the quote resulting in the highest net amount of fiat currency received by the client.

Where two or more execution venues offer the same best price for a given order, the Firm may select the execution venue in its discretion, and it may take into account various considerations.

The Firm keeps its order routing and Order Routing arrangements under ongoing review and may refine the execution factors considered over time, including by incorporating additional parameters such as execution reliability or likelihood of settlement, where appropriate. Any material changes to these arrangements will be reflected in updates to this Policy.

7. No remuneration, discount or non-monetary benefit

The Firm does not receive any form of remuneration, discount or non-monetary benefit in return for routing orders to a particular trading platform where the same transaction could be executed at multiple venues.

8. Ongoing Monitoring

The Firm will as part of its internal processes monitor the effectiveness of its order execution arrangements and order execution policy in order to identify and, where appropriate, correct any deficiencies in that respect. This will be carried out by the Firm by monitoring the prices obtained, any spreads evident in those prices, the split between different execution venues as a result of order routing, any execution failures, or settlement failures. This will also monitor the reliability of the execution venues, for instance any system downtime or system failures evident in respect of that execution venue relating to the services they provide the Firm.

This ongoing monitoring will enable the Firm to assess, on a regular basis, whether the execution venues included in the order execution policy provide for the best possible result for clients or whether they need to make changes to their order execution arrangements.

9. Vendor due diligence

All execution venues (LPs) utilised by the Firm are subject to vendor due diligence at the outset, and on an ongoing basis. This includes an assessment of:

  • Location and licences
  • Operational resilience and technological capabilities
  • Scale
  • Transparency
  • Liquidity
  • Execution quality (speed, likelihood, price etc.)
  • Financial crime controls and market abuse (including its own regulatory obligations)
  • IT security

10. Client communication

The Firm’s clients are provided with relevant details of its Order Execution Policy when they are first onboarded as part of its terms of service, available on its website. If there are any material changes to the order execution policy this will be communicated to clients via an update to the applicable terms of service.

11. Demonstration

The Firm will ensure that it has internal records suitable to demonstrate that an order has been executed in accordance with the Order Execution Policy.

12. Misuse of information

The Firm has robust controls, policies and procedures in place to prevent the misuse of information relating to pending orders. These controls include:

  • Access controls and information barriers: to prevent unauthorised individuals having access to information about pending orders – the only individuals able to access this information are those where such access is required to carry out their day to day responsibilities;

  • Monitoring: monitoring of all orders received and executed;

  • Personal account dealing: ensures all staff are aware of their responsibilities and monitors for potential abuse;

  • Reporting and escalation: various routes are available internally and externally for staff to report wrong doing.

13. Record Keeping

The Firm will maintain records of orders as required by MiCA, under the Firm’s Record Keeping and Data Retention Policy.

14. Customer eligibility

14.1 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.

“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.

14.2 Onboarding; CDD

The Firm will only execute an order for a client that meets the eligibility criteria established by the Firm, be duly onboarded and approved by the Firm in accordance with its policies and procedures, including passing applicable customer acceptance and due diligence (CDD) procedures including sanctions screening and verification, and being within the Firm’s risk appetite.

14.3 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. 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.

15. Fees

Conversions (when executed) are subject to fees, which are disclosed to the relevant client both in the App, and on the Firm’s website, along with any other costs. 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 and costs in the App and on the website).

16. Governance and Oversight

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

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.

17. Updates and Review

This Policy will be reviewed at least annually.