Enforcement Policy Statement

1. Scope

YouHodler Italy S.r.l. (the “Company”) provides its Clients, via an online Platform, in accordance with Regulation (EU) 2023/1114 (“MiCAR”), with the service of executing orders relating to crypto-assets on behalf of clients (Article 3(1)(21) MiCAR) (“Execution Services”).

The Company does not provide investment advice, portfolio management or discretionary services. The Client remains solely responsible for their own trading decisions.

The Company uses a limited number of execution venues authorised to provide, pursuant to Article 59 of MiCAR, the service of “operating a trading platform for crypto-assets”, as defined in Article 3(1)(18) of MiCAR (“Authorised Execution Venues”), carefully selected for the execution of clients’ orders in crypto-assets.

The Company also provides for the possibility that client orders may be executed outside the Authorised Execution Venues (for example, OTC venues or third-country trading platforms, hereinafter “External Execution Venues”, together with the Authorised Execution Venues, hereinafter “Execution Venues”).

2. Client consent to the Execution Policy

Before accessing the Execution Services, the Client is required to review and accept the applicable contractual documentation, including the terms and conditions of service (“T&Cs”) and the Execution Policy, provided as an annex to the execution agreement. Acceptance of these documents is a necessary condition for accessing the Platform’s functionality.

Pursuant to Article 78(5) of MiCAR, the Client is informed that orders may also be executed at an External Execution Venue. In such cases, the Company obtains the Client’s express consent to this method of execution.

Following initial acceptance, each individual transaction (“Order”) requires specific confirmation from the Client, who must (i) confirm the accuracy of the Order parameters; and (ii) agree that the transaction is executed in accordance with the execution model on the Client’s behalf.

In order to ensure the security of transactions, the Company requires the Client’s authentication via multi-factor authentication mechanisms (2FA or 3FA), designed to prevent unauthorised access.

Prior to confirmation of the Order, the Platform provides clear and comprehensive information on (i) the execution price (or exchange rate); (ii) the Company’s commissions; and (iii) any applicable costs.

The Company may update or amend the Execution Policy or the T&Cs of the service. Amendments are communicated to Clients via the Platform or other electronic channels, and explicit acceptance of the updated version is required to continue using the services.

3. List of trading platforms and evaluation criteria

Orders to buy, sell or convert crypto-assets are transmitted to the Execution Venues integrated into the Platform via secure API connections.

The Company executes Client Orders exclusively through selected Execution Venues, which are capable of contributing to the achievement of the best possible result for the Client, in accordance with Article 78 of MiFID II and the Execution Policy ( ), and in respect of which the Company has conducted a structured due diligence process aimed at verifying that they meet appropriate requirements in terms of execution quality, security, operational reliability and regulatory compliance.

The list of Execution Venues used is reviewed daily in order to ensure the Client’s right to information regarding executions at External Execution Venues. 

4. Execution methods and Smart Order Routing

The Company uses an automated Smart Order Routing (SOR) system, integrated into the Order Management System (OMS), which allows for real-time comparison of prices and liquidity conditions available at the Execution Venues.

The Company does not apply a static hierarchy of Execution Venues. Selection is dynamic and based on objective criteria, including (i) price and total costs; (ii) available liquidity; (iii) speed and probability of execution; (iv) operational and settlement reliability. 

5. Platforms by type of crypto-asset

The services referred to in the Execution Policy apply exclusively to transactions involving:

• crypto-assets covered by the Platform’s services; and 
• with a value exceeding the relevant operational threshold, currently set at €50,000.00 per transaction (“Operational Threshold”).

Reaching the Operational Threshold is calculated on a per-order basis.

Transactions below the Operational Threshold are covered by the Exchange Services. The Company reserves the right to execute a Client Order via the Exchange Service even if it exceeds the Operational Threshold, provided that this serves the Client’s best interests in terms of the total cost of the transaction to the Client. 

The Operational Threshold is subject to periodic review.

6. No Inducements

The Company does not receive or accept any form of benefit, whether monetary or non-monetary, from third parties in relation to the routing of Orders to specific Execution Venues.

The Company guarantees that any contractual or commercial relationships with Execution Venues do not compromise the independence of the decision-making process regarding the execution of Orders.

The procedures for identifying, preventing and managing conflicts of interest are governed by the specific policy on conflicts of interest, to which reference should be made.

7. Execution factors and best execution

The Company takes all necessary measures to obtain the best possible result for the Client in the execution of Orders, in accordance with Article 78 of MiFID II.

The execution price is generally the most relevant factor. For each Order, the Company determines the most favourable price available across Execution Venues, taking into account: (i) executable bid and ask prices; (ii) commissions charged by Execution Venues; (iii) the Company’s commissions; (iv) expected slippage; (v) total transaction costs. The price is determined based on real-time market data obtained from multiple Execution Venues via secure API connections. 

The price displayed to the Client prior to confirmation is an indicative price that remains valid for a limited time window communicated to the Client and designed to mitigate the risk of slippage. Following the Client’s confirmation of the Order, the Order is transmitted to the selected Execution Venue, whilst the final execution price is that actually obtained on the market at the time of execution. The final price may differ from the indicative price due to volatility, liquidity conditions or latency.

The Company’s remuneration is shown separately as a service fee prior to confirmation of the Order.

The Company does not guarantee that the absolute best theoretical price available on the market will be obtained in all circumstances, but undertakes to achieve the best possible overall result under prevailing market conditions.

8. Execution costs

Costs include all charges associated with the transaction, whether explicit or implicit, including: (i) execution venue fees; (ii) network fees (gas); (iii) payment intermediary or bank fees; (iv) the Company’s fees. 

Fees are generally calculated as a percentage of the Order value and are applied at the time of execution and crediting to the Client’s account.

9. Client-specific instructions

The Company executes Orders in accordance with the parameters and instructions provided by the Client via the Platform. Should the Client issue specific instructions relating to one or more elements of the Order, the Company shall execute the Order in accordance with such instructions, even if this may result in an outcome different from that which would otherwise have been achieved by fully applying the best execution principles, or render it impossible to execute the Order.

Specific instructions apply exclusively to those aspects of the Order to which they relate. For all other elements not covered by such instructions, the Company continues to apply the principles set out in the Execution Policy in order to achieve the best possible result. 

The Company reserves the right to refuse to execute an Order if it conflicts with: (i) the conflicts of interest policy; (ii) market abuse regulations; (iii) the AML/CFT framework; (iv) other applicable legal or regulatory obligations. 

The execution of an Order requires the Client to enter the required parameters via the Platform; once entered, the Platform displays the indicative execution price, determined in accordance with the Company’s pricing methodology; this remains valid for a limited time window. Once this period has elapsed without confirmation, the price automatically expires and is updated based on current market conditions.

The Order is executed only following the Client’s confirmation of the transaction parameters and applicable costs. If the parameters entered are incomplete, inconsistent or incompatible with market conditions, the Order cannot be executed.

The Company may carry out additional checks on Orders, in particular where there are: (i) anomalies relating to the size or nature of the Order; (ii) requirements arising from the application of AML/CFT controls; (iii) other compliance requirements. 

In such cases, execution may be suspended or delayed until the checks have been completed.

Orders may only be amended or cancelled prior to their confirmation. Given the automated nature of the process and the speed of the markets, Orders are generally executed immediately upon confirmation. Once executed or settled, the Order is irreversible.

If a cancellation request is received immediately after confirmation but before execution, the Company may attempt, without guarantee of success, to halt or withdraw the Order.

The Client is informed of the status of the Order via the Platform (executed, partially executed, cancelled or rejected).

The Platform may allow the placement of limit-to-market orders, which are executed only upon reaching a price level specified by the Client.

10. Rejection or cancellation of Orders

The Company may reject or cancel an Order if it is not possible to execute it in accordance with regulatory, operational or market requirements. Circumstances may include: (i) insufficient funds or crypto-assets; (ii) failure to comply with AML/CFT controls or sanctions; (iii) abnormal market conditions or operational disruptions; (iv) suspected market abuse; (v) technical malfunctions or loss of connectivity; inconsistency of the Order parameters with market conditions. 

The Client is promptly informed of the rejection or cancellation, subject to any restrictions arising from legal obligations.

The Company retains records of rejected or cancelled Orders for traceability and compliance purposes.

11. Abnormal market conditions and system disruptions

The execution of Orders may be affected by exceptional circumstances, including: (i) high volatility; (ii) a significant reduction in liquidity; (iii) disruptions affecting liquidity providers; (iv) congestion on blockchain networks; (v) internal technical incidents. 

In such circumstances, the Company may take measures to ensure the orderly management of Orders, including: (i) temporary suspension of order routing; (ii) delays in execution; (iii) redirection to alternative venues; and (iv) cancellation of Orders, where necessary. 

The Company will inform Clients via the Platform in the event of significant impacts on execution.

The Company reserves the right to deviate from its Execution Policy in the event of adverse market conditions, where strict adherence to the Policy may compromise the client’s interests, market integrity or operational stability.

12. Order recording and execution priority

All Orders are recorded in a complete and traceable manner, indicating the stages of receipt, transmission, execution and confirmation. The records include timestamps and internal identifiers, as well as references to Orders executed at the Execution Venues.

Comparable Orders are generally executed in the order in which they are received, unless objective conditions dictate otherwise.

13. Monitoring of the Execution Policy of Execution Venues

The Company regularly monitors the effectiveness of the Execution Policy and the methods used to execute orders aimed at achieving best execution, in order to identify and, where appropriate, correct any shortcomings.

The Company continuously monitors the performance of Execution Venues, including through periodic reviews at least quarterly, which include analyses of liquidity, quantitative assessments (prices, slippage, speed, execution rates) and qualitative assessments (operational stability, security, governance).

In the event of significant shortcomings, the Company may take corrective measures, including changing the routing parameters or removing the Execution Venue from the approved list.