California Digital Financial Asset Conflict of Interest Disclosure

Last updated: June 17, 2026

1. Purpose And Scope

This California Digital Financial Asset Conflict of Interest Disclosure (this “Disclosure”) is provided to California residents by CEX.IO Corp. (“CEX.IO”, “we”, “us” or “our”) in connection with CEX.IO’s digital financial asset exchange activities under California Financial Code section 3505 and 10 CCR § 1250.

This Disclosure describes material actual and potential conflicts of interest that may arise in connection with the digital financial assets listed or offered through the CEX.IO platform for California residents. It should be read together with the User Agreement, Risk Disclosure, Fee Schedule, Privacy Notice, supported-asset disclosures and any product- or transaction-specific disclosures made available through the platform.

This Disclosure is intended to provide full and fair disclosure of material facts relating to conflicts of interest associated with CEX.IO and the digital financial assets that CEX.IO lists or offers, as required by applicable California law. It does not constitute investment, financial, legal, tax or other professional advice, and it is not a recommendation to buy, sell, hold, exchange or otherwise transact in any digital financial asset.

2. Statutory Definitions

In alignment with the California Digital Financial Assets Law (DFAL) and for purposes of this Disclosure:

“Covered Exchange” means a covered person that exchanges or holds itself out as being able to exchange a digital financial asset for a resident.
“Conflict of Interest” means an interest that might incline a covered exchange, or a natural person who is an associated person of a covered exchange to make a recommendation that is not disinterested.

3. Types Of Conflicts Of Interest

Conflicts of interest may arise in the course of the provision of the Services and that such conflicts may be actual, potential, or perceived. Conflicts of interest may occur between CEX.IO and the User, between different Users, or between the interests of CEX.IO and those of its Affiliates, shareholders, directors, officers, employees, representatives, service providers, liquidity providers, issuers, commercial partners or other associated persons.

Such circumstances may include, without limitation, situations where:

CEX.IO or its Affiliates derive financial, commercial, or strategic benefits from the execution, non-execution, pricing, timing, routing, availability, suspension or restriction of a Transaction;
CEX.IO or its Affiliates act, where applicable, as principal, counterparty, liquidity provider, order-routing venue, technology provider, custody or wallet infrastructure provider, or other service provider in connection with a User transaction;
CEX.IO or its Affiliates hold, acquire, dispose of, trade in, receive or otherwise have an economic interest in Digital Assets that are listed, offered or considered for listing on the platform;
CEX.IO receives, or is entitled to receive, fees, commissions, spreads, rebates, incentives or other monetary or non-monetary benefits from third parties, including Affiliates, service providers, liquidity providers, issuers or other commercial partners, which may influence, or appear to influence, the provision of the Services;
CEX.IO directors, officers, employees, contractors, representatives or other relevant personnel of CEX.IO may hold, acquire, dispose of, trade in or otherwise have an interest in Digital Assets listed, offered or considered for listing on the platform;
Relationships with Affiliates, group entities, or external business partners may result in preferential treatment, bias, or restrictions in the Services;
Relationships with Affiliates, group entities, service providers, liquidity providers, issuers or other external business partners may give rise to actual or perceived preferential treatment, bias, restrictions, incentives or commercial dependencies in connection with the Services;
CEX.IO’s commercial, financial or contractual interests may diverge from the interests of Users or from applicable legal, regulatory, contractual or operational standards applicable to the Services;
different Users, account types, transaction types, asset types, liquidity sources, fee tiers, compliance statuses or service channels are subject to different limits, fees, execution arrangements, availability, access criteria or operational treatment; or
Users seek to transact in the same Digital Asset in circumstances where market conditions, liquidity, transaction size, timing, technical constraints, compliance restrictions or other operational factors may affect execution, availability, pricing or access.

4. Asset-Specific Conflicts

In addition to the general conflicts described above, certain Digital Assets may involve asset-specific conflicts of interest. These may include, without limitation, relationships or arrangements involving an issuer, sponsor, promoter, foundation, protocol developer, liquidity provider, market maker, validator, staking provider, technology provider, affiliate or other person connected with the relevant Digital Asset.

Before listing or offering a Digital Asset to California residents, CEX.IO assesses conflicts of interest associated with the relevant Digital Asset as part of its listing and risk assessment process. Where CEX.IO identifies a material conflict of interest associated with the platform and a specific Digital Asset, CEX.IO will provide written disclosure of the material facts relating to that conflict through this Disclosure, an asset-specific disclosure, a supported-asset page, a user notice, the User Agreement, product disclosures or another legally permitted disclosure channel.

Where no asset-specific material conflict has been identified beyond the general conflict categories described in this Disclosure, CEX.IO may rely on this Disclosure and its internal listing records to document the conflict assessment for the relevant Digital Asset.

5. Identification and Management of Conflicts

CEX.IO maintains risk-based internal policies, organizational arrangements and administrative procedures designed to identify, assess, escalate, disclose, manage and, where appropriate, mitigate actual and potential conflicts of interest. These measures may include, depending on the nature of the relevant conflict::

governance, review and approval procedures for relevant business, product, listing, delisting and service decisions;
segregation of duties and role-based responsibility allocations;
information barriers, role-based access controls and need-to-know restrictions designed to protect confidential, commercially sensitive or non-public information;
personal trading restrictions and/or pre-clearance, monitoring or disclosure requirements for relevant personnel, as applicable;
policies restricting, requiring disclosure or approval of, or prohibiting gifts, inducements or other benefits that could give rise to a material conflict of interest;
remuneration and incentive arrangements designed to reduce inappropriate incentives that could give rise to material conflicts;
periodic review, escalation and recordkeeping procedures; and
training, attestations or other compliance procedures for relevant personnel, as applicable.

These measures are intended to reduce the risk that conflicts of interest adversely affect Users or the fair and compliant operation of the platform. They do not eliminate all conflicts, guarantee that a conflict will not arise, or guarantee that any particular transaction, listing decision, price, liquidity condition, service availability or operational outcome will be unaffected by a conflict.

6. Disclosure of Material Conflicts

Where CEX.IO identifies a material conflict of interest associated with the platform and a Digital Asset listed or offered through the platform, CEX.IO will provide written disclosure of the material facts relating to that conflict in a clear and timely manner, as required by applicable law. The form, timing and channel of disclosure may depend on the nature of the conflict and the relevant Service, Digital Asset or transaction.

Disclosure may be provided through this page, asset-specific disclosures, supported-asset pages, product disclosures, user notices, transaction flows, the User Agreement or other legally permitted disclosure channels. Where required by applicable law, CEX.IO may restrict, suspend, cease listing or offering, or otherwise take action in relation to a Digital Asset or Service if a material conflict cannot be appropriately managed or disclosed.

7. Continued Listing Review and Cessation Procedures

CEX.IO maintains policies and procedures to reevaluate the appropriateness of the continued listing or offering of Digital Assets, including where material changes occur in relation to a Digital Asset, its issuer or sponsor, its protocol, market conditions, regulatory treatment, cybersecurity risk, operational risk, liquidity, market integrity, or other relevant factors.

CEX.IO also maintains policies and procedures to cease listing or offering a Digital Asset where required or appropriate, including notification to affected Users and counterparties where required by applicable law. Any such decision may be subject to legal, regulatory, operational, technical, market, liquidity, risk management, consumer protection and other relevant considerations.

8. Ongoing Monitoring and Disclosure Updates

CEX.IO shall ensure that any material conflict of interest that cannot be fully prevented is disclosed to the User in a clear and timely manner. In compliance with Financial Code section 3505(a)(1)(D), CEX.IO regularly reevaluates the appropriateness of continued listing for all assets. Should a new material conflict arise, this page and the associated asset certifications will be updated accordingly.