Dated: 19 August 2026
B2C2 Europe S.à r.l. ("we", "us", "our", "B2C2 Europe") is incorporated in the Grand Duchy of Luxembourg with company number B265273. Our registered office is at 1 rue Jean Piret, L-2350 Luxembourg and our principal place of business is at 33 Boulevard Prince Henri, L-1724 Luxembourg.
We are a crypto-asset service provider with licence number N00000007, authorised and regulated by the Luxembourg financial regulator, the Commission de Surveillance du Secteur Financier ("CSSF"), under Regulation (EU) 2023/1114 on markets in crypto-assets ("MiCA").
We are permitted to exchange crypto-assets for funds and to exchange crypto-assets for other crypto-assets. We are a principal liquidity provider operating as an over-the-counter (OTC) trading firm: we act as the counterparty to every client transaction and deal on our own account.
This Non-Discriminatory Commercial Policy (the "Policy") has been prepared in accordance with Article 77 of MiCA and applies to the exchange of crypto-assets for funds and the exchange of crypto-assets for other crypto-assets, provided by us on a principal basis.
This Policy does not apply to any other service or product we offer.
The conflicts of interest that arise from our activities, and the measures we take to manage them, are described separately in our Conflict of Interest Disclosure.
This Policy is subject to the terms and conditions set out in the Client Trading Master Agreement. In the event of any discrepancy between this Policy and the Client Trading Master Agreement, the Client Trading Master Agreement shall prevail.
Capitalised terms used in this Policy have the meanings given to them in the Client Trading Master Agreement.
Our services are available only to clients who have completed our onboarding process and entered into a Client Trading Master Agreement with us. We transact with two categories of client:
We do not offer our services to retail or unsophisticated clients. Our services are not available to any person who has not completed onboarding, including the required due diligence, or whose account has restricted functionality under the Client Trading Master Agreement.
Our core focus is serving EEA-based clients. We may accept clients established outside the EEA only where they have approached us on their own exclusive initiative; we do not actively market, promote or solicit our services outside the EEA.
The following conditions apply uniformly to all applicants and must be satisfied before a client can transact with us:
Applicants who do not meet these conditions are refused or suspended on a uniform basis, applying clear and objective criteria. We notify the client of our decision in writing, subject to any legal or regulatory restriction on what we may disclose.
The service is provided in accordance with Schedule 1, Clause 1 (Trading) of the Client Trading Master Agreement and, where transactions are carried out over our OTC Platform, Schedule 4 (Electronic Trading Terms of Service).
We quote a single all-in price for the exchange of crypto-assets for funds or other crypto-assets. That price incorporates the relevant execution factors and associated costs, including a spread. Charges, commissions or fees may be included in the price we quote rather than charged separately, and we may receive remuneration from third parties in connection with our dealing.
The spread is determined by reference to defined risk parameters, including volatility, order type, size, maturity and direction, market transparency, observable liquidity, and hedging, funding and settlement costs. An additional spread may apply during periods of increased market volatility; it is calculated dynamically in real time based on prevailing market conditions and the specific crypto-asset traded, and reflects the increased market risk during high volatility or sudden price movements. In low-volatility markets this additional spread reduces to zero.
Because we quote a single price at which we are willing to deal, and we bear the execution risk of the resulting position, the total cost of a transaction may be higher than it would be on a venue where the client bears that risk itself.
We do not offer preferential pricing, priority execution or other advantages to particular clients or groups of clients, unless objectively justified, for example by volume tier, time of receipt of the order, available liquidity or a regulatory requirement. Where such differentiation applies, the criteria are applied consistently to every client who meets them.
Transaction limits apply to the amount that can be exchanged. Depending on the product, additional assessments may be required based on applicable collateral requirements and risk or financial thresholds. Transaction limits may also vary based on your verification status, our credit and risk exposure to you, and other applicable legal or regulatory requirements. The limits applicable to you are available on our OTC Platform and from your relationship manager, and may change from time to time.
Quotations are determined by us taking into account a number of factors. While our prices take account of market data from a range of sources, they are not taken directly from any single third-party source and may therefore differ from prices available on other platforms or exchanges. Transactions are executed on the basis of the quotation provided on our OTC Platform, not on prices quoted elsewhere.
A transaction is entered into when we provide you with a quotation, you send us an order in response, and we accept that order. Your order must match the details of our quotation and must be sent while the quotation is still valid. We may decline to provide a quotation, and we are not obliged to accept an order. Where we do accept your order, the resulting transaction will be at a price no worse than the price you requested. The transaction is binding once we have accepted your order, and we confirm the agreed terms to you.
While we strive to provide accurate and up-to-date quotations, prices may change due to market movements or technical factors, including network latency, connectivity issues, or delays in data transmission. As a result, the price available when you submit a transaction request may differ from the price at which the transaction is executed.
In certain circumstances, including periods of significant market volatility, technical disruptions, or limited market data availability, quotations may be temporarily unavailable, updated, or withdrawn. Where a quotation is no longer valid, a revised quotation may be provided before a transaction can be completed.
The exchange of crypto-assets for funds or other crypto-assets is offered to clients on all days and at any time of day. Nothing prevents or restricts our right to extend or reduce trading hours, generally or in relation to any crypto-asset, during the course of any business day.
We reserve the right to limit or suspend our support for specific or all crypto-assets, and for the exchange service itself, at any time and without prior notice. This includes removing crypto-assets from availability for purchase or sale, adjusting the blockchains we support, adjusting trading hours, or discontinuing the service entirely. We are under no obligation to provide these services on a continuous or ongoing basis.
Any such limitation or suspension is applied on a non-discriminatory basis to all affected clients.
We may be unable to provide a quotation or to execute a transaction where a legal or regulatory restriction, including applicable sanctions, prevents us from doing so.
We do not withhold or restrict our services on the basis of factors unrelated to an objective risk assessment or to regulatory compliance. In particular, we do not discriminate against clients on the grounds of nationality, place of residence or place of establishment within the EU. Our services are available to eligible clients throughout the EEA without territorial restriction, except where prohibited by applicable local law or by sanctions.
We apply uniform rules and procedures to all clients, and our internal systems and controls are designed to prevent undue preference, discrimination and information asymmetry between clients.
Any client who considers that they have been treated unfairly or unequally may raise the matter with their relationship manager or with our compliance team at compliance@b2c2.com. Concerns about perceived discrimination are investigated within five business days.
Complaints are otherwise handled in accordance with our Complaints Policy.
This Policy is reviewed on a periodic basis, and in any event at least annually, or where there is a material change. Any modification or amendment is made in writing and becomes effective once approved by the management body.
The most recent version of this Policy is made available on our website. This Policy may be changed at any time.
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B2C2 does not transact with or provide any service to any retail investor or consumer. By subscribing to our content, you represent that you are not a retail investor or consumer. Please refer to our disclaimer for further information.
