General Disclosures
Licence Number Issued by Virtual Assets Regulatory Authority (VARA): This information will be updated as required post-licence issuance.
Licensed Virtual Asset (VA) Activities: First Crypto is authorized to provide the following services:
- Arranging orders for the purchase and sale of Virtual Assets between two Clients
- Soliciting or accepting orders for Virtual Assets and accepting fiat currency, or other Virtual Assets, for such orders
- Facilitating the matching of transactions in Virtual Assets between buyers and sellers
- Entering into Virtual Asset transactions as a dealer on behalf of the Client for its own account
- Making a market in Virtual Assets using Clients' assets
Responsible Individuals:
- Herman Nazarenko, Founder & Chairman of the Board
- Zunair Ali, Compliance Officer/MLRO/Head of Risk
VA Broker-Dealer Activity-Specific Disclosures
1. Conflicts of Interest
Description of Conflicts: A conflict of interest arises when personal, financial or external interests can influence or appear to influence the impartiality of decisions made on behalf of First Crypto. Such conflicts can undermine trust, violate ethical standards and affect the credibility of our work.
Management of Conflicts: First Crypto ensures the distribution of job responsibilities of employees in such a way as to exclude conflicts of interest and the conditions for their occurrence. The Compliance Department collects information on potential conflicts during candidate evaluation and analyzes requests to assess risks and select appropriate resolution forms.
Identified Conflicts: To date, no material conflicts of interest have been identified. Should any conflicts arise, they will be promptly disclosed and managed in accordance with our internal policies and VARA requirements.
2. Virtual Asset Information
First Crypto supports the following virtual assets:
Asset Overview
| Symbol | Issuance | Market Cap | FDV | Max Supply | Circulating | % of Max |
|---|---|---|---|---|---|---|
| BTC | 2009 | $1,945,000,000,000 | $2,050,000,000,000 | 21,000,000 BTC | 19.98M BTC | 95.1% |
| ETH | 2015 | $367,000,000,000 | $367,000,000,000 | No maximum supply | 120.47M ETH | N/A |
| USDT | 2014 | $137,000,000,000 | $137,000,000,000 | No maximum supply | 137B USDT | N/A |
| TRX | 2017 | $24,000,000,000 | $24,600,000,000 | 100,850,743,812 TRX | 94.7B TRX | 93.9% |
Smart Contract / Protocol Audit Status
| Symbol | Audit Status | Most Recent Audit Date |
|---|---|---|
| BTC | N/A - Layer 1 blockchain protocol | N/A |
| ETH | Multiple independent audits | Ongoing |
| USDT | Quarterly attestations by BDO Italia | Q4 2025 |
| TRX | Protocol audit by Least Authority | Mar 2020 |
Historical Price Data
| Symbol | All-Time High | ATH Date | % from Current | All-Time Low | ATL Date | % from Current |
|---|---|---|---|---|---|---|
| BTC | $108,268 | Dec 2024 | -10% | $0.0009 | Oct 2009 | +10,800,000% |
| ETH | $4,891 | Nov 2021 | -38% | $0.42 | Oct 2015 | +720,000% |
| USDT | $1.22 | Feb 2015 | -18% | $0.57 | Mar 2015 | +75% |
| TRX | $0.30 | Dec 2024 | -1% | $0.001 | Sep 2017 | +29,900% |
Largest Price Reductions (Drawdowns)
| Symbol | Daily Max Drawdown | Monthly Max Drawdown | Yearly Max Drawdown | |||
|---|---|---|---|---|---|---|
| Amount | Date/Period | Amount | Period | Amount | Period | |
| BTC | -24% | Jan 14, 2015 | -40% | Mar 2020 | -77% | 2022 |
| ETH | -18% | Mar 12, 2020 | -45% | Jun 2022 | -82% | 2022 |
| USDT | -3% | Oct 15, 2018 | -5% | Oct 2018 | -8% | 2018 |
| TRX | -15% | May 19, 2021 | -35% | Jun 2022 | -92% | 2018 |
*Data as of January 15, 2026. Market capitalization, FDV, and supply figures are subject to change based on market conditions. Drawdown data represents historical maximum reductions from high to low for each time period. Sources: CoinMarketCap, CoinGecko.
3. Virtual Asset Pricing
First Crypto strives for the most efficient execution of its clients' orders, therefore, when calculating the price, before making a decision to execute an order, we evaluate the current market supply and demand, the trading volume and market capitalization of each virtual asset, the number of active users of the network, and the difficulty of mining the asset. The firm uses technical valuation methods and analyzes fundamental factors including macroeconomic conditions, political events, regulation, and innovative developments.
4. Order Routing Practices
First Crypto solicits quotes from multiple liquidity providers and, upon receipt, selects a provider to route the order. This automated selection process considers factors such as latency, quote expiration time, historical fill data, token characteristics, volatility, and additional relevant metrics. First Crypto applies a markup to the quote received from the chosen liquidity provider.
First Crypto collaborates with multiple liquidity providers to secure quotes for its customers, considering various factors, including price, latency, historical fill data, token specifics, and market volatility. Our primary liquidity partners include:
ARP Digital: A regulated Virtual Asset Service Provider (VASP) based in Bahrain. The contractual arrangement ensures compliance with VARA's Best Execution standards applicable to making a market in Virtual Assets using client assets and dealing as principal.
Fasset: A VARA-licensed Virtual Asset Service Provider operating in the UAE, providing additional liquidity and execution capabilities.
All order routing decisions are made with the objective of achieving the best possible outcome for clients, considering factors such as price, costs, speed, and likelihood of execution.
5. Holding and Clearing Services for Other VASPs
First Crypto Does Not Hold or Maintain Funds/Virtual Assets or Provide Clearing Services for Other VASPs: First Crypto does not hold or maintain funds or Virtual Assets, nor does it provide clearing services for other Virtual Asset Service Providers (VASPs) offering Broker-Dealer services. First Crypto's services are focused solely on providing trading and liquidity access to its customers and do not include custodial or clearing functions for other VASPs.
6. Protection of Clients' Assets & Their Ownership Rights
At First Crypto, ensuring the protection of clients' virtual assets and the unequivocal protection of their ownership rights is a core priority. The firm affirms that clients retain full ownership of virtual assets at all times. These assets are held in secure environments but remain the exclusive property of the client and are never transferred to the ownership of First Crypto or any third-party service providers.
The firm adheres to VARA's requirements for arrangements protecting client ownership of assets, maintaining trust, security, and accountability.
7. Referrals or Introductions to Other Entities
First Crypto Does Not Hold or Maintain Funds/Virtual Assets or Provide Clearing Services for Other VASPs: First Crypto does not hold or maintain funds or Virtual Assets, nor does it provide clearing services for other Virtual Asset Service Providers (VASPs) offering Broker-Dealer services. First Crypto's services are focused solely on providing trading access to its customers and do not include custodial or clearing functions for other VASPs.
8. Third-Party Accounts, Funds, or Virtual Assets
First Crypto maintains Client Money Accounts in Zand Bank PJSC (Zand), a licensed bank registered in the UAE and regulated by the CBUAE.
In accordance with VARA's mandate for secure custody of Virtual Assets, First Crypto engages Fireblocks UK INT'L Limited as its certified third-party Custody Services Provider. All Virtual Assets are held in secure digital custody solution, including cold-wallet storage technology. Assets are distinctly segregated from company operating funds and aligned with VARA's rules.
9. Other Disclosable Matters
Past Convictions or Prosecutions of Senior Management or Board Members: No past convictions or prosecutions of Senior Management or Board Members.
Additional Information as Required by VARA: n/a