Reception and Transmission of Orders Policy

Last updated: July 1, 2025

1. Introduction

At Veli UAB (“Veli”, “we”, or “the Company”), we aim to ensure that every client order is handled promptly, fairly, and in the client’s best interest.

This Reception and Transmission of Orders Policy explains how your orders are processed when you trade crypto-assets through Veli’s platform.

We operate in accordance with Article 80 of the Markets in Crypto-Assets Regulation (MiCA), which sets out rules for the fair handling and transmission of client orders.

Veli provides advisory and portfolio management services for crypto-assets and does not execute orders directly.

Instead, all orders are securely transmitted to approved liquidity providers for execution, ensuring reliable and transparent trading for every client.

2. Purpose and Scope

This policy describes how Veli:

  • Receives and transmits client orders for crypto-assets;
  • Ensures fairness, accuracy, and timeliness in order handling;
  • Works only with trusted and compliant liquidity providers; and
  • Protects clients from conflicts of interest and unfair treatment.

It applies to all clients using our trading or portfolio services, whether orders are placed manually or automatically through managed accounts.

3. How We Handle Client Orders

We are committed to processing every order efficiently and without unnecessary delay.

Orders are handled in the sequence they are received, unless special circumstances (such as market volatility or client instructions) require a different approach.

We always act in the best interest of the client — never giving preference to any individual, group, or counterparty.

Once validated, orders are transmitted securely to an approved liquidity provider or trading venue.

Clients receive confirmation when their order has been accepted and executed.

Our goal is to ensure smooth order transmission and execution that reflects real-time market conditions.

4. Approved Liquidity Providers

All orders are transmitted only to pre-approved liquidity providers that meet our standards for:

  • Regulatory compliance and licensing;
  • Strong operational and cybersecurity measures;
  • Execution reliability and fair pricing; and
  • Financial and reputational soundness.

We continuously monitor the performance and integrity of our providers to ensure they continue to meet these standards.

If a provider no longer meets our requirements, it may be suspended or replaced to protect our clients’ interests.

5. Client Instructions and Order Processing

Clients may provide specific instructions (such as asset type, price limit, or order size) or authorize us under a portfolio management agreement to act on their behalf within agreed parameters.

Before transmitting any order, Veli ensures that:

  • The order details are complete, accurate, and consistent with the client’s profile and mandate;
  • The order complies with all applicable regulations and internal controls; and
  • The transmission channel (API or secure system) is functioning properly.

 

Once the order is sent, Veli receives and records confirmation from the liquidity provider, including order status and execution details.

Clients are informed of execution outcomes as soon as they are received.

6. Conflicts of Interest

We have robust measures in place to avoid and manage conflicts of interest.

Orders are routed solely based on what is best for the client — not commercial arrangements, rebates, or incentives.

We do not accept commissions, discounts, or non-monetary benefits from third parties that could compromise fairness.

If a potential conflict of interest arises, we disclose it to the client before providing the service.

Veli’s primary duty is always to act honestly, fairly, and professionally in the best interests of its clients.

7. Record Keeping and Transparency

To ensure accountability and traceability, we maintain detailed records of every client order, including:

  • The date and time of receipt;
  • The order details and parameters;
  • The liquidity provider or venue to which the order was transmitted; and
  • The confirmation of execution.

 

All records are securely stored for at least five years and are available for regulatory inspection if required.

This transparency allows us to verify every step of the order-handling process and safeguard our clients’ trust.

8. Market Integrity and Oversight

We continuously monitor our order-handling environment to ensure fairness and detect any signs of market abuse, data manipulation, or irregular trading activity.

We also monitor relevant market and regulatory updates to protect clients from emerging risks or unusual conditions that may affect crypto-asset trading.

If we detect suspicious activity or receive a valid concern, we take immediate steps to assess, investigate, and, if needed, report it to the appropriate authority.

9. Client Confidence and Contact Information

Veli is dedicated to providing an open and fair trading environment where every order is handled with professionalism and integrity.

We value transparency and encourage clients to contact us if they have any concerns about how their orders are received or transmitted.

For questions or concerns regarding this policy, please contact our Compliance Team:
compliance@veli.io