Fee & Charge

Last updated: 20/08/2026

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Scintilla is committed to clear, transparent, and fair execution pricing. The prices quoted to clients for Virtual Assets are determined in accordance with the following pricing mechanics:
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· Mid-Market Reference Aggregation: Quoted prices are derived from real-time pricing feeds aggregated across top-tier primary spot exchanges and institutional liquidity venues.

· Spread & Mark-up Mechanics: Scintilla applies a fixed or percentage-based spread to the underlying mid-market reference price. This spread reflects market volatility, asset liquidity, execution risk, and operational costs. The total spread or commission is explicitly disclosed to the client on the user interface/trading portal prior to order execution and confirmed in post-trade execution statements.

· Over-the-Counter (OTC) & Primary Issuances: For large-block OTC trades or primary token distributions/issuances managed by Scintilla, execution quotes are determined via direct order-book matching or volume-weighted average price (VWAP) algorithms, agreed upon mutually prior to trade confirmation.
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2. Order Routing Practices & Liquidity Sources

Scintilla executes client orders on a agency or riskless-principal basis in accordance with its Best Execution Policy.

Orders are routed to achieve the best possible result for the client, taking into consideration price, execution speed, probability of settlement, and market impact.
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3. Custody & Clearing Services Provided to Other VASPs

Scintilla explicitly declares its operational scope regarding B2B services as follows:

· No B2B Clearing or Secondary Custody: Scintilla does not hold or maintain funds or Virtual Assets on behalf of, nor does it provide clearing services for, other licensed Virtual Asset Service Providers (VASPs) offering Broker-Dealer Services.

· Scintilla operates exclusively to service its own direct institutional and retail client base.
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4. Protection & Safeguarding of Client Legal Ownership

Scintilla maintains strict operational and legal structures to ensure that client assets remain fully protected and segregated from proprietary assets at all times:

· Legal Title & Segregation: Client Virtual Assets and fiat funds are held by Scintilla on a trust or fiduciary basis. Clients retain full legal and beneficial ownership of their assets at all times.

· Bankruptcy Remoteness: Client assets do not form part of Scintilla’s general estate and are immune from claims by Scintilla’s general creditors in the event of insolvency, liquidation, or regulatory resolution.

· Internal Ledger Reconciliation: Scintilla maintains continuous, automated real-time sub-ledger accounting to map every client asset unit to its individual beneficial owner. Off-chain and on-chain holdings are reconciled daily.

· Designated Client Money Accounts: All fiat currency received from clients is held in separate, designated Client Money Accounts with regulated financial institutions in the UAE or approved overseas jurisdictions.
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5. Referral & Introduction Arrangements

Scintilla maintains clear guidelines governing client introductions, referral programs, and fee-sharing mechanics:

· Client Referral Framework: Scintilla may enter into formal introductory agreements with approved third-party introducers or corporate partners who refer clients to Scintilla’s platform.

· Retrocessions & Compensation Terms: Where an introducer or partner refers a client, Scintilla may pay a fixed introductory fee or share a percentage of the transaction commissions generated by the referred client. All such arrangements are subject to prior written agreement.

· No Hidden Costs: Referral compensations are paid out of Scintilla’s standard earned fees and do not result in additional charges, markups, or higher execution costs for the referred client.
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6. Identity of Named Third-Party Custodians & Banking Partners (Rule I.B.1.i)

Pursuant to Rule I.B.1.i, Scintilla explicitly discloses the identity of the third-party custodians and banking institutions where client accounts, fiat funds, or Virtual Assets are held or maintained:

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