Public Disclosure
Execution of orders for crypto-assets on behalf of clients
MiCA art. 78 Execution of orders for crypto-assets on behalf of clients
Version 2.0 Last updated: 06. May, 2026 - 16:00 (GMT+1)
This policy establishes the framework for our Crypto-assets execution service. The policy ensures fair, transparent, and non-discriminatory access to our services while maintaining compliance with regulatory requirements, particularly Regulation (EU) 2023/1114 (MiCA), article 78.
The purpose of this policy is to:
Firi Black is Firi's premium service designed for high-volume transactions exceeding 1 million NOK in a single trade. This specialized service offers personalized execution and customized Trading fee pricing for larger transactions, providing institutional and high-net-worth clients with efficient access to Crypto-assets currency markets. Firi Black clients and transactions are handled by the OTC Trading Desk.
Firi Black trading is offered as an execution service in accordance with MiCA article 78, cf article 3 (1) point (16) (e), cf point (20).
At present, FIri does not offer execution services trading outside of the criteria set above for Firi Black. If other execution-based services should be developed in the future, this policy and all other internal regulations related to execution services will apply to trades under such services.
An explicit confirmation of acceptance of Firi Black trading terms and this Execution Policy, including the fact that Firi Black trades are always executed outside a trading venue, is required from clients before they are able to use the service.
Firi Black transactions are handled manually through direct communication between the client and Firi's OTC desk. The communication with the client may be done via various channels, and for record-keeping purposes the client will always be asked to confirm the trade in writing, via the channels agreed between the client and Firi.4.1.2 Best Execution
Firi shall take all necessary steps to obtain the best possible result for our clients when executing orders. We shall consider factors of price, costs, speed, likelihood of execution and settlement, size, nature, conditions of custody of the Crypto-assets or any other consideration relevant to the execution of the order.
Monitoring of best execution shall be conducted in accordance with Section 6. Firi assesses the best trading partner regularly, based on available liquidity and execution readiness. The list of available partners is reviewed at least every 6 months and expanded or shrunk based on whether the relevant source provides competitive prices consistent with market benchmarks. Conflicts of interest and systematic deviations are handled accordingly.
The last updated review shall be available as a separate document together with “Best execution methodology applied at present”. If the review shows any deficiencies or non-competitive prices, Firi shall take the necessary measures, including considering other sources that may provide a better result for our client. In such events, the description under “Best execution methodology at present” shall be updated accordingly.
The Head of Markets is responsible for monitoring and verifying that the systems and procedures for order execution comply with the principle of best execution.
Firi determines custom Trading fee pricing for each Firi Black trade based on several factors:
This approach allows Firi to offer competitive pricing tailored to each customer’s specific circumstances and trading requirements. The customer will be informed about the trading fee for the transaction before any trade is made.
When a client requests a trade, Firi provides a custom price quote with a specified validity period.
Firi Black trades offer flexible settlement arrangements to accommodate larger transaction sizes. Two primary settlement methods are available:
All trades are executed directly with Firi as the counterparty, ensuring secure and reliable settlement according to the agreed terms.
The list of supported assets is subject to periodic review and may be updated based on market conditions, regulatory requirements, and risk assessments.
All transaction conditions are applied consistently and non-discriminatorily across all clients within each service category. Firi reserves the right to modify these conditions based on market conditions, risk management requirements, or regulatory obligations, with appropriate notice to clients.
Any specific trading instructions deviating from Firi’s best execution methodology will need to be documented in writing and accepted on a best-effort basis. The decision on whether to accept such instruction will also be communicated in writing to the client.
To ensure that our execution model is in line with regulatory requirements, including that it provides clients with the best possible result in accordance with Section 3.1.2, we regularly review the order execution processes, and the underlying liquidity sources (including third party trading partners).
A retrospective review and assessment shall be conducted at least every six months. The review shall include an assessment of the following:
The review shall be documented in writing and may lead to updates in the Best execution methodology applied at present, of Section 3.
Extraordinary assessments are conducted in the event of significant market events, changes in liquidity sources, or other major incidents.
If the review shows deficiencies or lack of efficiency, measures shall be taken. In the case of available liquidity sources not providing competitive prices, it shall be examined whether those sources should be replaced with other liquidity providers. The sources used in connection with the Firi Index Price shall be used as benchmarks to assess best execution. If conflicts of interest or systematic deviations are identified, a detailed internal investigation shall be conducted to surface the origin of these deviations and involved parties.
The Head of Markets is responsible for monitoring and verifying that the systems and procedures for order execution comply with the principle of best execution.
All employees involved in any trading operations are strictly forbidden to misuse information provided in pending transactions
To prevent misuse of information we have implemented control mechanisms to limit access to information: access to the OTC-account in the Intercom chat solution is limited to those members of the Markets team that are actively involved in trade execution; trade execution in the technical solution (the “OTC desk”) is limited to the same group.
The use of Firi Black services requires formal client registration and approval. All potential clients must complete our onboarding process and meet specific eligibility criteria before accessing any execution services.
Clients will be informed that all FIri Black orders are executed outside of trading platforms, and will be required to expressly consent to this before being eligible to use the Firi Black trading services.
In addition, FIri Black clients must meet the following criteria: