Commercial Policy

BVNK EU - Summary of Commercial Policy

System Pay Services (Malta) Limited, trading as BVNK (“BVNK”, “we” or “us”) is a private limited liability company incorporated in Malta, with company registration number C66961 and registered address at Ruby Workspaces Office 3, Pendergardens, Triq Sant’Andrija, San Giljan STJ9023, Malta.
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BVNK is authorised by the Malta Financial Services Authority (“MFSA”) as a crypto-asset service provider (“CASP”) under the Markets in Crypto-Assets Act (Chapter 647 of the Laws of Malta), in accordance with Article 3(15) of Regulation (EU) 2023/1114 (“MiCA”).|
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This summary of our Commercial Policy (“Policy”) outlines our non-discriminatory framework governing how we engage with customers for the provision of Exchange Services (exchanging crypto-assets for funds or other crypto-assets).
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In compliance with our regulatory obligations, this document defines:

• Client Eligibility: The objective criteria we use to determine which customers we are prepared to onboard.
• Non-Discrimination: Our commitment to ensuring fair access to our crypto-asset Exchange Services without arbitrary or unjustified barriers.
• ‍Pricing Transparency: In accordance with Article 77(2) of MiCA, how we publish a firm price or disclose the methodology used to determine the price for exchange transactions.

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Our commercial practices are grounded in integrity and consistency. This Policy is designed to provide our customers with a clear understanding of what to expect when engaging with BVNK’s regulated Exchange Services in the European Union.

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Client Eligibility and Access

We apply a consistent, objective, and risk-based framework to evaluate all prospective and existing customers. Eligibility for our services is determined by customer category and the specific services required. While BVNK primarily engages directly with legal entities, individual customers are eligible to access our services through specific channels.

Our onboarding process applies uniform, risk-based criteria to all applicants - individuals and legal entities alike. Customers undergo due diligence based on objective factors such as jurisdiction, service type, and risk profile. While some customers may undergo enhanced checks due to regulatory requirements or risk exposure, these steps are implemented transparently and proportionately.

We do not provide preferential access or treatment unless it is objectively justified, such as through specific service needs, tailored agreements, or compliance obligations. All decisions around access are subject to internal oversight and review.

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Transparent Pricing

BVNK is committed to providing clear pricing for all transactions. We publish firm prices or disclose the methodology used to determine the price for exchange transactions. 

To ensure fairness and consistency, our fees for Exchange Services are categorised as follows:

1. Standardised Fees: These apply uniformly across similar customer categories for standard services. They ensure customers can anticipate charges in a consistent and transparent manner.
2. Differentiated Fees: In certain situations, pricing may vary based on specific, documented criteria. Examples include:
   
   • Higher compliance or operational costs associated with a particular service
   • Enhanced risk controls required for certain jurisdictions or customer types
   • Tailored pricing based on the nature of a custom service agreement

Before entering into any agreement or transaction, customers will be provided with clear information regarding the applicable exchange rate, fees, and any potential risks associated with the service.

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Commitment to Non-Discriminatory Practices

Access to our services and our pricing is governed strictly by objective, risk-based, and regulatory factors. We do not discriminate on the basis of nationality, customer size, industry, or any other personal or business characteristic not relevant to our risk assessment. 

However, to maintain the integrity of our services,  we reserve the right to decline or restrict services to certain customers or jurisdictions (e.g., under sanctions laws or regulatory prohibitions). Any such exclusions are clearly defined, documented, and communicated.

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Clear and Accessible Communication

We strive to make all customer-facing information easy to understand, accurate, and timely. This includes:

• Pre-Service Information: Details on services, pricing, onboarding requirements, and potential risks are made available prior to any agreement.
• Marketing and Educational Content: All promotional material is reviewed to ensure it is fair, accurate, and non-misleading. Benefits are never overstated, and risks are prominently disclosed.
• Ongoing Updates: Customers are notified of any changes to services, terms, or conditions in a timely and transparent manner.
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All communications follow a plain-language approach, designed to support informed decision-making.

Customer Support and Service

BVNK maintains a dedicated support function to assist with onboarding, account management, and technical queries. We offer help through various channels, including email and online chat. Our team is trained to:

• Respond promptly and respectfully
• Escalate issues where needed
• Provide accurate and clear guidance
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We also offer educational materials to help customers understand crypto-asset risks and service mechanics.

This policy reflects the commitments outlined in our internal Commercial Policy and Best Interest of Client Policy. It serves as a public assurance of the values and standards that guide every customer interaction with BVNK.

For information about raising a concern or making a complaint, please visit our dedicated Complaints page.