MDF AG — Modern Digital Finance
Freigutstrasse 22, 8002 Zurich, Switzerland
Version 2.0 | May 2026
Please read this Best Execution Policy carefully before placing any order with MDF AG. By opening an MDF AG Account or placing an order through our platform, you confirm that you have read, understood, and agree to the arrangements described in this Policy. This Policy forms part of your agreement with MDF AG and supplements our Terms and Conditions.
1.1 This Best Execution Policy (referred to in this document as the Policy) sets out the arrangements by which MDF AG (referred to as the Company, we, us, or our) achieves best execution in the handling of client orders for virtual assets and crypto-assets.
1.2 MDF AG is a Virtual Asset Service Provider incorporated in Switzerland (company registration number CHE-323.398.672), affiliated with a Swiss self-regulatory organisation and subject to Swiss supervisory standards applicable to financial intermediaries. This Policy reflects those standards and is designed to ensure that we consistently act in your best interest when executing or arranging the execution of your orders.
1.3 This Policy is approved by the Management Board and is reviewed at least annually. If changes occur that materially affect our execution arrangements, the Management Board will consider updating the Policy accordingly. We will notify you of any material changes through our website or by email to the address registered to your account.
1.4 This Policy is an integral part of your agreement with MDF AG. Information about our best execution arrangements is available on our website. Any changes to execution procedures will be made in accordance with the process set out in our Terms and Conditions. By placing an order with MDF AG following receipt of this Policy, you acknowledge and agree to its content.
1.5 You may at any time request additional information about this Policy or about the execution of a specific order. We will respond clearly and within a reasonable time to any such request.
2.1 The following terms are used in this Policy:
Account — Your personal account on the MDF AG platform, enabling you to access and use our services.
Blockchain Network — A decentralised digital ledger used as the settlement layer for crypto-asset transactions.
Centralised Exchange (CEX) — A custodial trading platform operated by a centralised entity, used as an execution venue providing order matching, custody, and fiat-to-digital asset conversion services.
Crypto-Asset — A digital representation of value or rights that can be transferred and stored electronically using distributed ledger technology or similar technology, as supported by MDF AG from time to time.
Gas Fees — Network transaction fees paid to blockchain validators to process crypto-asset transactions on-chain.
Order — A request submitted by you to purchase, sell, transfer, or exchange a Crypto-Asset through our platform.
OTC (Over-the-Counter) — A non-public execution arrangement for crypto-asset trades, typically involving direct settlement between parties without impacting exchange order books.
OTC Crypto-Assets — Crypto-assets that are not actively traded on centralised exchanges or similar venues.
Prime Liquidity Provider — An institutional counterparty selected by MDF AG to supply liquidity and facilitate order execution across one or more trading venues.
Sizable Order — An order that is large in size relative to the liquidity currently available in the relevant market.
Specific Instruction — An order submitted by a client with predetermined parameters, such as a specified price, quantity, or venue.
Terms and Conditions — The terms and conditions governing our services, published on our website.
Trading Venue — Any venue or mechanism through which crypto-asset orders are executed, including centralised exchanges, OTC desks, liquidity aggregators, or blockchain protocols.
2.2 Client classification. For the purposes of this Policy, all retail, commercial, and corporate clients are assessed individually and are subject to our internal eligibility process. Where clients are assessed as having the experience, knowledge, and expertise to make their own decisions and assess the risks involved, they may be treated accordingly in the execution of their orders. We will inform you of your classification upon onboarding.
2.3 Terms not defined in this Policy or in our Terms and Conditions shall be understood in the sense ordinarily used in the virtual asset services industry.
3. Our Obligation to You
3.1 MDF AG is committed to taking all sufficient steps to achieve the best possible result for clients when executing or transmitting orders. In fulfilling this commitment, we consider a range of factors including price, total costs, speed of execution, likelihood of execution and settlement, order size, the type of crypto-asset, and any other information relevant to the efficient handling of your order.
3.2 Price and total consideration are generally given the highest weight when determining what constitutes the best possible result. However, depending on the characteristics of your order, the crypto-asset involved, prevailing market and liquidity conditions, or any specific instructions you have provided, other factors may take precedence in order to achieve the best outcome for you.
3.3 We have implemented processes and procedures that, in our assessment, are sufficient to ensure that best execution outcomes can be achieved on an ongoing basis. These include: the selection and assessment of Prime Liquidity Providers and other execution counterparties; the selection and monitoring of Trading Venues; client classification; and the regular review of our execution arrangements.
3.4 Clients must be clearly informed about our execution arrangements before orders are placed, and your agreement to this Policy constitutes that understanding. Where orders may be executed outside a centralised trading venue, we will ensure you are informed accordingly.
3.5 We regularly monitor and assess the effectiveness of our execution arrangements and make adjustments as necessary. We are prepared to demonstrate compliance with best execution standards to you upon request.
4. Factors Considered in Achieving Best Execution
4.1 When executing your orders, we consider the following factors in determining the best possible result:
4.2 The relative weighting of these factors may vary depending on the specific order, the market environment, and your instructions. We will always seek to achieve the result that, in our reasonable assessment, represents the best overall outcome for you in the circumstances.
5. Selection of Liquidity Providers and Execution Venues
5.1 MDF AG considers centralised exchanges, liquidity aggregators, and OTC desks as execution venues. The selection of venues is based on execution quality, asset liquidity, counterparty risk, settlement reliability, and security measures. We may also execute trades directly on blockchain protocols where this achieves a better result for you.
5.2 We select Prime Liquidity Providers on the basis of their execution quality, the breadth of their product offering, the availability of appropriate technical solutions, and their cost structures. We conduct regular reviews of each provider’s ability to deliver best execution and their capacity to support our obligations under this Policy.
5.3 Our OTC exchange services are structured at a margin positioned competitively relative to institutional OTC industry standards. We act as the primary venue for institutional block trading and OTC execution in CHF and major foreign currency pairs. Fiat currency settlement is available in CHF, USD, and GBP via SWIFT.
5.4 Prime Liquidity Providers are subject to approval by the Management Board. Other execution counterparties are subject to compliance review by our Compliance team and credit assessment by our risk function. The list of approved counterparties is reviewed regularly and updated at least annually.
5.5 For OTC transactions, the execution counterparty is selected on an ad hoc basis from our approved list, having regard to their indicative pricing, transaction costs, and our experience of trading similar assets with them.
5.6 You acknowledge and agree to our exchange fees before placing an order. Applicable fees and charges will be disclosed to you in advance in accordance with our Terms and Conditions and our published fee schedule.
6. General Order Handling
6.1 We execute client instructions and orders in the sequence in which they are received. We will ensure that your orders are promptly and accurately recorded and allocated, and that you are informed of any material difficulty relevant to the processing of your order.
6.2 We will carry out comparable client orders sequentially and promptly unless the characteristics of an order, prevailing market conditions, or the interests of clients make this impracticable. Following execution, we will inform you of where your order was executed.
6.3 We monitor our ability to settle on the expected date and take remedial action where this is at risk. We monitor and follow up on any undelivered assets outstanding on the settlement date.
7. Market Access Orders
7.1 Where you submit an order at market prices visible to other market participants — specifying price, quantity, and other parameters — MDF AG considers that its best execution obligation is satisfied in respect of those elements determined by your instructions. We will continue to seek best execution for any elements not specified by you.
7.2 MDF AG does not generally use proprietary automated order routing or algorithmic execution systems. We monitor client transactions on an ongoing basis to identify any irregularities.
8. OTC Execution
8.1 Unless you instruct us otherwise, placing an order with MDF AG constitutes your explicit agreement that the order may be executed on OTC markets where we determine that this is in your best interest and allows access to a wider range of execution venues.
8.2 For OTC crypto-asset transactions, indicative pricing is obtained from multiple sources, including institutional liquidity providers, market makers, and real-time exchange feeds. We ensure best execution by comparing spreads, counterparty standing, network fees, and expected slippage. All OTC executions are documented and reviewed for compliance purposes.
8.3 We commit to sourcing indicative pricing from at least three reputable counterparties or aggregators, unless market conditions — such as extreme volatility or low liquidity — make this impractical.
8.4 Where you have accepted an indicative price offered by MDF AG for an OTC transaction, we consider that best execution has been achieved in respect of that price. In setting the offered price, we take into account prevailing market conditions, our own costs and risks, and applicable fees.
8.5 You are advised that counterparty risk may arise where an order is executed outside a centralised Trading Venue. We will inform you of this risk in advance of any OTC execution where relevant.
9. Limit Orders and Market Orders
9.1 We encourage you to consider the use of limit orders in place of market orders. Market orders are susceptible to being filled at prices materially different from the displayed bid or ask, particularly in volatile market conditions, for large order sizes, or for less liquid crypto-assets.
9.2 To protect both you and MDF AG from losses associated with significant and rapidly changing prices, we may treat client market orders as subject to an execution cap, establishing a percentage limit beyond the current inside bid or ask. This cap is set to balance execution certainty with price risk management. In rare circumstances, this may result in a delay to execution or mean that execution does not take place.
9.3 Where you submit a limit order that cannot be immediately executed due to prevailing market conditions, we will make that order available to the market in an accessible manner to facilitate the earliest possible execution, unless you instruct us otherwise.
9.4 Limit orders that remain unexecuted will be cancelled after 90 calendar days unless executed earlier or you request a different arrangement.
10. Settlement
10.1 MDF AG is responsible for overseeing or arranging the settlement of executed orders. We will take all reasonable steps to ensure that any crypto-assets or funds received in settlement of an executed order are promptly and correctly delivered to the appropriate client account.
10.2 Settlement for crypto-asset transactions is conducted on the relevant blockchain network and achieves finality upon sufficient on-chain confirmations. We monitor on-chain confirmations and ensure the secure custody or transfer of assets to your wallet or account.
10.3 All crypto-asset transfer services are subject to our counterparty identification and transfer monitoring procedures. For all qualifying transfers, originator and beneficiary information is collected, retained, and transmitted in accordance with our Travel Rule compliance framework.
11. Sizable Orders
11.1 Where an order is large relative to the liquidity currently available in the relevant market, MDF AG will treat it as a Sizable Order.
11.2 The execution of a Sizable Order may affect market liquidity and pricing in a way that prevents the straightforward application of best execution procedures. MDF AG reserves the right to execute a Sizable Order in tranches, determining the appropriate proportions and timing to minimise market impact.
11.3 The parameters of what constitutes a Sizable Order, and the specific arrangements for its execution, are determined by our trading function or Management Board on a case-by-case basis having regard to the relevant instrument, market, and prevailing conditions.
12. Order Transmission Failures
12.1 Technical failures in our IT infrastructure may in rare circumstances restrict our ability to receive, transmit, or execute orders. Should this occur, we will notify you by the means set out in our Terms and Conditions as promptly as possible.
12.2 In the event of a transmission failure, all relevant personnel will act in accordance with our business continuity arrangements to restore normal service as quickly as possible.
13. Additional Risk Information
13.1 Crypto-asset trading carries a number of risks that may affect execution outcomes. These include, without limitation: extreme price volatility; cybersecurity risks; technology malfunctions; the possibility of exchange insolvency; and regulatory uncertainty. You should ensure you understand these risks before placing any order.
13.2 We cannot guarantee execution at expected prices due to rapidly changing market conditions. We will always seek the best available result in the circumstances but cannot guarantee outcomes in all scenarios.
14. Conflicts of Interest
14.1 The misuse of information relating to pending client orders is strictly prohibited. MDF AG takes all reasonable steps to prevent any person involved in our operations from misusing such information.
14.2 MDF AG and its associated persons are prohibited from receiving any remuneration, discount, or non-monetary benefit for routing client orders to a particular Trading Venue where this would give rise to a conflict of interest that is not managed in accordance with our conflicts of interest policy.
14.3 MDF AG does not structure or apply commissions in a manner that discriminates unfairly between execution venues. Where our fees differ depending on the venue used, we will explain those differences to you so that you can understand the advantages and disadvantages of each option.
14.4 Conflicts of interest management, information barriers, and conduct standards applicable to sales, marketing, and revenue generation activities are governed by our Internal Control Framework and Code of Conduct.
15. Third-Party Payments
15.1 Where MDF AG pays or receives monetary or non-monetary remuneration to or from third parties in connection with the provision of services to you, we will only do so where such remuneration is designed to enhance the quality of the service provided to you, does not impair our ability to act honestly, fairly, and professionally in your best interest, and does not create an unmanaged conflict of interest.
15.2 We will disclose to you, upon request, the existence and nature of any third-party payments that are relevant to the services provided to you.
16. Reporting to Clients
16.1 We will provide you with information, in periodic reports or upon request, on where your orders were executed and on the prices, costs, speed, and likelihood of execution applicable to your transactions.
16.2 At your request, and without undue delay, we will demonstrate that your order was executed in accordance with this Policy.
17. Record-Keeping
17.1 We maintain complete records of all orders received, executed, and transmitted, together with the rationale for execution decisions and details of all monetary and non-monetary remuneration paid or received in connection with order routing.
17.2 All transaction and client records are retained for a minimum of 10 years and are maintained in a format accessible for internal review and supervisory inspection.
17.3 We may publish periodic reports on our website regarding our execution quality and the venues used for executing client orders.
18. Monitoring and Control
18.1 MDF AG conducts regular reviews of its compliance with this Policy, including assessment of:
18.2 Where a failure to comply with this Policy or our execution standards is identified, it will be recorded as an incident and resolved in accordance with our Incident Management Policy.
18.3 Oversight of this Policy is exercised on a regular basis by the Management Board, our Compliance team, and our external auditor. Our supervisory body also conducts periodic reviews of our compliance framework, including our execution arrangements.
18.4 Our Compliance Officer maintains day-to-day oversight of compliance with this Policy and coordinates with our Group Chief Compliance Officer on group-level governance and policy alignment.
18.5 The head of our trading function is responsible for the investigation of any shortcomings identified in our execution arrangements and for ensuring that this Policy is updated in a timely manner.
19. Annual Review
19.1 This Policy is reviewed at least annually by the Management Board. We will assess whether the execution venues we use continue to provide the best possible result for our clients and will update our arrangements accordingly.
19.2 Any updates to this Policy arising from the annual review, or from material changes in our operations or the markets in which we operate, will be communicated to you in accordance with our standard notification process.
20. Changes to This Policy
20.1 We may update this Policy from time to time. We will notify you of any material changes by email to the address registered to your account or by notice on our website. Changes will take effect in accordance with the process set out in our Terms and Conditions.
20.2 The current version of this Policy is available at all times on our website and upon request from our Compliance team.
MDF AG | Version 2.0 | May 2026
