As an authorised crypto-asset service provider under the Markets in Crypto Assets Regulation, MoonPay Europe is required to identify and mitigate conflicts of interest that may cause harm to its customers.
The following passages outline the general nature of MoonPay Europe's conflicts of interest and the efforts undertaken to mitigate against potential consumer harm. Where MoonPay Europe cannot sufficiently mitigate a conflict, we are required to publish the conflict on our website.
Conflicts of interest can occur:
As a general matter, conflicts of interest may arise between the following parties:
- MoonPay Europe and its shareholder,
- MoonPay Europe and persons directly or indirectly linked to MoonPay Europe,
- Board members,
- Employees,
- Customers.
In identifying conflicting interests, MoonPay Europe takes into account whether a party:
a) is likely to make a financial gain, or avoid a financial loss, at the expense of MoonPay Europe;
b) has an interest in the outcome of a crypto-asset service provided on an activity carried out or decision taken by MoonPay Europe, which is distinct from MoonPay Europe's interest in that outcome;
c) carries out the same business as MoonPay Europe or is a client, consultant, adviser, delegatee, outsourcee or other supplier (including subcontractors) of MoonPay Europe and it can be reasonably deemed from objective circumstances that there may be a conflict of interests with MoonPay Europe.
Types of conflicts of interest and mitigating measures
At this time, MoonPay Europe has not identified any conflicts of interest that have not been sufficiently mitigated. Below the general nature of its conflicts and the measures taken to mitigate them.
- Personal transactions: Personal transactions of employees and other connected persons, may conflict with the interest of MoonPay Europe. MoonPay Europe has controls to prevent connected persons from engaging in such. Employees receive mandatory training, are subject to compliance checks and must acknowledge relevant policies. All personal transactions are monitored, recorded, and managed through compliance oversight and record-keeping systems
- Dual hatting: Individuals of MoonPay Group, with a sufficient level of seniority or decision making ability, may influence MoonPay Europe in ways that may harm MoonPay Europe or its customers. Potential or actual conflicts of interest must be disclosed to MoonPay Europe, which will take action as needed. Other examples related to dual hatting include; outsourcing, connected individuals and internal promotions.
- Gifts & Entertainment: The giving or accepting of gifts and entertainment by employees of MoonPay Europe may give rise to a potential conflict of interest. This can result in inappropriate relationships, with the potential to do harm to the interests of MoonPay Europe or it's customers. MoonPay Europe has an MoonPay Group Anti-Bribery & Corruption Policy in place and maintains a gifts register and provides regular training.
- Renumeration: The level of renumeration offered to staff of MoonPay Europe may give rise to conflicts of interest, resulting in potential harm to MoonPay Europe or its customers. MoonPay Europe maintains its Renumeration Policy which adopted a renumeration structure that is balanced between fixed and variable components.