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Transfer Policy Summary

At Coinmerce, we prioritise the safety, efficiency, and transparency of all Client asset transfers. Our Transfer Policy is designed to provide clear guidelines on how transfers of crypto-assets are handled, ensuring compliance with regulatory standards under the Markets in Crypto-Assets Regulation (MiCAR). Below you find a summary of our policy.

1. Secure Transfer Process
Coinmerce employs a secure and streamlined process for all asset Transfers, ensuring that Client funds are moved promptly and safely. Transfers are supported by robust security protocols, including two-factor authentication (2FA), encryption, and multi-signature authorisations, to protect assets from unauthorised access and potential cyber threats.

2. Transfer Requests and Timing
Clients can initiate transfers through their Coinmerce User Interface. Upon submission of a transfer request, the transaction is processed as quickly as possible, generally within moments. Transfer times may vary depending on network congestion and security verification processes, but Coinmerce strives to maintain timely processing.

3. General Information Provided Prior to Transfer Services
Coinmerce ensures that all clients have access to essential pre-contractual information regarding our transfer services. This information includes:

  • Identity of Service Provider: Coinmerce operates as your trusted Crypto-Asset Service Provider (CASP).
  • DLT Networks Used: We specify the Distributed Ledger Technology (DLT) networks used for each Transfer, so Clients understand which blockchain protocol their assets are transferred on.
  • Service Costs: Clear information on any fees associated with Transfer Services.
  • Transfer Initiation: Instructions on how Clients can initiate a Transfer, including the necessary steps and any security verification required.

    This approach allows clients to make informed choices about transfer services and determine if Coinmerce‘s offering meets their needs.

    • 4. Information on Individual Crypto-Asset Transfers
    When clients submit a transfer instruction, Coinmerce provides important transaction details to ensure transparency and allow clients to track each transfer. This includes:

  • Transaction Confirmation: Details on the amount, type of crypto asset, and a unique reference code for tracking each transfer.
  • Irreversibility Notice: An alert when a transfer becomes irreversible on the blockchain or is probabilistically irreversible. This ensures clients are aware of the point where they can no longer cancel or modify a transaction.
  • Fees Disclosure: A breakdown of all charges associated with the transfer, disclosed clearly at the time of transaction initiation.
  • Transfer Status Updates: If a transfer is rejected, returned, or suspended, Coinmerce will notify the client with the reason and steps to resolve the issue. This includes actions required to complete the transfer.

    • 5. Execution Times
    We set maximum execution times based on the blockchain‘s specific requirements (e.g., number of confirmations needed for finality). These details are provided to the Client to ensure full transparency on expected processing times once the Transfer is initiated.

    We provide an oversight of the expected amount of required block confirmations for Transferring a particular Crypto Asset on our Website.

    6. Transfer Limits
    To ensure compliance and security, Coinmerce sets Account limits that apply to Transfers, which may vary based on the Client‘s account level. Additional verification steps may be required for larger transfers or transactions that raise specific compliance flags. This ensures that we meet regulatory standards while providing clients with safe and efficient transfer options.

    For more information, please refer to Account Limits.

    7. Costs Associated with Transfers
    Coinmerce is committed to transparent pricing, and any fees related to Transfers are clearly stated before the Client provides us with an Order.
    Clients are informed of any applicable fees based on the type of Transfer (e.g. a Deposit or Withdrawal). For more information about applicable Fees, please consult our Fee Schedule.

    8. Compliance and Reporting
    All Transfers are conducted in compliance with Applicable Laws and Regulations. Coinmerce monitors Transfers to detect and prevent unauthorised or suspicious activity, and we report any necessary information to relevant authorities to maintain full regulatory compliance.

    Travel Rule (hosted wallets)
    In case a Client provides an Order to Transfer Crypto Assets to a hosted wallet (meaning the private keys are held by a third party not being the Client), Coinmerce is required to ensure that initiation or execution of the transfer does not take place before adequate steps have been taken to ensure compliance with applicable provisions of the Travel Rule, and for this purpose request and confirm the following information:
    ● the names of the originator and the beneficiary;
    ● the originator‘s distributed ledger address or crypto asset account number;
    ● the beneficiary‘s distributed ledger address or crypto asset account number.

    Travel Rule (unhosted wallets)
    In case a Client provides an Order to Transfer Crypto Assets to an unhosted wallet (meaning the private keys are held by the Client), Coinmerce is required to verify ownership of the external wallet. In order to do so, Coinmerce will require you to verify ownership of the wallet by means of:
     ● completing the required verification steps in the User Interface, which includes providing a screenshot of your external wallet.

    9. Rejection and Suspension of Transfers
    In line with ESMA and MiCAR guidelines, Coinmerce has implemented risk-based policies to determine if a transfer should be rejected, returned, or suspended. These procedures are designed to prevent unauthorised or suspicious activity, including anti-money laundering (AML) and counter-terrorist financing (CTF) measures, to safeguard both client assets and regulatory compliance.

    In the event of a rejected, returned, or suspended transfer, Coinmerce will provide clear information to the Client, including the reason(s) for the action and the steps required to resolve the issue.

    10. Liability for Unauthorised or Incorrect Transfers
    Coinmerce cannot be held liable for unauthorised or incorrect Transfers initiated through the Client‘s Account. For more information, please refer to Section 17.1 Damage and Limitation of Liability of the Terms and Conditions.

    11. Client Support
    For assistance with Transfers or questions regarding this policy, our support team is available to help. Coinmerce is committed to providing clear, accessible, and efficient support for all Transfer-related inquiries.