Effective Date: 31-07-2025
1. Introduction
1.1. Overview
This Policy is developed in alignment with the Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) and other related regulations and Czech regulatory requirements. This Policy is submitted as part of Canis’s application for VASP licensing pursuant to Article 62(2) of MiCA.
1.2. Purpose
This Commercial Policy (“Policy”) is issued by Canis s.r.o. (“Canis” or “the Company”) in compliance with Article 77 of Regulation (EU) 2023/1114 (Markets in Crypto-Assets Regulation, MiCA). It sets out the terms and conditions under which Canis provides exchange services between fiat currency and crypto-assets, as well as between different crypto-assets.
1.3. Scope
The Policy is intended for submission to the Czech National Bank and anticipated requirements of draft RTS 305,Article 14. In particular, this policy establishes:
A fair and non-discriminatory commercial policy defining the client categories and onboarding conditions.
A transparent pricing policy, detailing how prices are quoted, determined, and disclosed (including any applicable limits or rebates).
Order execution terms, specifying when a client’s order becomes final and ensuring execution at the displayed quote, subject to system availability and applicable limits.
Post-execution transparency measures, describing the scope of disclosed transactional data and the method of publication in compliance with regulatory expectations.
This Policy strictly adheres to Canis’s actual business model as described in its MiCA business plan and financial forecast. No additional services, features, or assumptions beyond those documented are included. The Policy aligns with the European Securities and Markets Authority (ESMA) supervisory briefing on CASP authorisation, particularly regarding pricing transparency, execution finality, and reporting disclosures, to ensure full regulatory compliance and clarity for the Czech National Bank.
1.4. Approval
This Policy has been reviewed and approved by the Management Board of Canis. Any amendments require formal Management Board approval and must be documented to ensure transparency and compliance. This Policy will be reviewed at least annually, or at any time in case of material changes.
2. Scope of Services
Canis’s Licensed Services: Canis is applying as a Class 2 Crypto-Asset Service Provider under MiCA, authorised to provide two services: (a) exchange of crypto-assets against fiat currency, and (b) exchange of crypto-assets for other crypto-assets. These services are offered exclusively to corporate clients for all type of conversions, including stablecoin-to-fiat, fiat-to-stablecoin, and stablecoin-to-stablecoin swaps. In line with its business plan, Canis supports the conversion from and to MiCA-licensed stablecoins, such as USD Coin (USDC) and Euro Coin (EURC), and fiat currencies, such as, Czech Koruna (CZK), Euro (EUR), US Dollar (USD), Malaysian Ringgit (MYR) and Indonesian Rupiah (IDR). Canis also facilitates direct swaps between approved stablecoins (e.g. USDC ⇄ EURC) to serve cross-border payment and treasury needs.
Non-Custodial, B2B Platform: All Canis services are provided on a non-custodial basis – the Company never holds client crypto-assets or fiat funds at any point. Clients maintain control of their assets throughout the transaction flow, with on-chain transfers executed under the client’s authorization and fiat flows handled by licensed banking partners. Canis has rails with licensed credit institutions for fiat settlement; fiat funds are released from licensed credit institutions directly to the client’s bank account upon a successful crypto conversion. Likewise, stablecoin-to-stablecoin swaps are executed through licensed OTC trading platforms without Canis taking custody or market positions. This focused “conversion-only” infrastructure means Canis operates solely as an exchange facilitator - not as a trading venue or broker-dealer holding inventory.
Excluded Services: Canis’s business model does not include any retail-facing or speculative services. The platform’s architecture, pricing, and risk controls are built exclusively for corporate (B2B) usage, and retail users are out of scope. Canis provides no crypto-asset custody, no portfolio management or investment advice, and it does not operate a trading platform for crypto-assets. Canis also does not offer standalone “transfer of crypto-assets” services to the general public – any blockchain transfers occur only as part of an exchange transaction initiated by a client and are subject to the exchange process controls. By limiting its activities in this way, Canis keeps its regulatory permissions and risk profile tightly aligned with MiCA’s requirements for exchange services (MiCA Article 3(1)(9) points (a) and (b)). All services are provided through a secure web-based dashboard and API, available only to eligible corporate clients (no mobile app or open retail portal). This ensures a controlled environment tailored to business process integration, security, and compliance.
3. Client Eligibility and Non-Discriminatory Access
Eligible Client Profile: Canis’s services are available solely to institutional and corporate clients that meet defined eligibility criteria. The Company’s commercial policy is non-discriminatory – any client that is a legal entity and fulfills the entry conditions may access the platform on equal terms. In practice, target clients include businesses such as merchants, fintech companies, payment platforms, financial institutions, and other organizations with stablecoin transaction needs. Natural persons (retail customers) are not accepted under this Policy. By restricting to vetted corporate clients, Canis ensures compliance with MiCA and AML/CFT regulations and provides a tailored service level for professional users. There is no discrimination on the basis of nationality or industry, provided they meet the standards outlined below.
Entry Conditions: All prospective clients must undergo a rigorous onboarding process before accessing Canis’s platform. The entry requirements include:
KYC/KYB Verification: Each client must complete Know-Your-Customer/Know-Your-Business due diligence as determined by the company. This entails providing corporate registration documents, identification of directors and ultimate beneficial owners, and passing anti-money laundering (AML) and counter-terrorism financing (CTF) checks. Canis uses third-party verification tools (e.g. Sumsub) to perform corporate KYC, KYB and sanctions screening. Only entities that successfully clear these checks (and periodically refresh them) are allowed on the platform.
Agreement to Terms: Clients are required to execute Canis’s standard Service Agreement, which incorporates all related terms (fees, trading rules, data disclosures, etc.). By signing the agreement, the client agrees to abide by Canis’s operating rules and confirms that they understand the risks of crypto-asset transactions. Thereafter, clients are provided secure credentials to access the web dashboard and API.
Operational Setup: The client must have the operational capability to use the service. This includes maintaining a fiat bank account (with IBAN) under the client’s name to receive fiat payouts from the licensed credit institution, and a digital wallet or custody solution for initiating or receiving stablecoin transfers. Canis’s platform will only interact with wallets that have been registered and verified for the client (to prevent unauthorized redirections). Additionally, clients should integrate with Canis’s API or interface to initiate orders and download reports; technical support is provided for onboarding to ensure smooth integration.
These criteria are applied uniformly.
Non-Discrimination: Canis imposes no arbitrary barriers or favoritism among clients who meet the conditions. There are no hidden “invite-only” tiers or discriminatory access rules– all eligible business clients receive equal access to the same services, pricing schedule, and support levels. The Company’s policy forbids discrimination based on factors such as the client’s size, or the volume of activity, except where required by objective risk assessments or legal obligations. (For example, higher-risk jurisdictions or industries may undergo enhanced due diligence as required by AML laws, but this is a risk-based compliance measure, not commercial discrimination.) Entry is granted on a first-come, first-served basis and through transparent procedures: every applicant is subject to the same verification and approval workflow, and any refusal of service (e.g. due to failed KYC or sanctions hit) will be communicated with clear reasons.
Monitoring and risk management: After onboarding, clients must continue to adhere to Canis’s compliance standards. Canis monitors transactions for suspicious activity (using blockchain analytics and AML software) and may impose risk-based transaction limits or request additional information from clients as needed.
Suspension and termination: If a client no longer meets the eligibility criteria or violates the terms (for instance, engaging in prohibited activities or losing regulatory good standing), Canis reserves the right to suspend or terminate access in a non-discriminatory manner, in line with contractual provisions and applicable law. Any such actions are based on predefined criteria (e.g. AML risk, security concerns) and not on arbitrary preference.
4. Pricing Policy and Quote Transparency
Transparent All-Inclusive Pricing: Canis employs a fixed-percentage pricing model, as a transaction fee, that is fully transparent to clients. Clients are always quoted a single “all-in” price for each crypto-asset exchange transaction, inclusive of all fees and costs. There are no hidden surcharges, no add-on commissions after the trade, and no separate account maintenance or custody fees (since Canis holds no client assets). The price quote given to the client is the total price they pay (or receive) for the conversion, subject only to a small minimum fee described below. This simplifies cost calculation for clients and ensures predictable conversion costs without surprise charges. The full fee schedule underpinning these quotes is documented in Annex 1 and is also provided in the client’s Service Agreement and available on the client dashboard, in accordance with MiCA’s cost transparency obligations (MiCA Article 60).
Transaction Fee & Conversion fee:
• The primary fee applied is a transaction fee calculated as a percentage of the total transaction volume. This fee is agreed in advance with the merchant and clearly stipulated in the merchant agreement. It is applied to each executed trade and deducted from the transaction amount. In addition to the transaction fee, a fixed €5 conversion fee applies per transaction.
• Pricing is fully transparent: each transaction consists of a clearly disclosed percentage-based fee plus a fixed €5 conversion fee. No other hidden or variable charges apply.
• The applicable fee is always clearly disclosed upfront, via API and the client dashboard, prior to order confirmation. No additional fees are charged beyond this disclosed transaction fee and conversion fee (see Price Determination Methodology below).
Price Determination Methodology:
Canis is committed to offering transparent and fair currency conversions by using widely recognized reference exchange rates without any embedded markup. All conversions are executed at either the mid-market rate or live rate, depending on the client’s preference as stipulated in the agreement. These reference rates are clearly displayed to clients before transaction execution, ensuring full visibility into prevailing market pricing.
Rather than incorporating markups into the exchange rate, Canis applies a straightforward fee model agreed upon with each merchant during contract signing. This fee — expressed as a fixed percentage of the transaction value — is determined based on several key factors, including:
• Anticipated transaction volumes
• Average trade size
• Liquidity characteristics of the most commonly traded currency corridors
This approach allows for commercial flexibility while maintaining fairness and predictability in pricing. All clients are informed of the applicable rate and fees before each transaction, and a transaction only proceeds after client acceptance, ensuring transparency and informed consent.
In addition to the transaction fee, Canis charges a flat €5 conversion fee per transaction. This fee primarily covers operational expenses such as blockchain gas and network fees and any other compliance costs. Canis absorbs these costs internally and does not pass any variable blockchain fees directly onto clients, ensuring cost stability and simplicity.
Canis maintains strict non-discriminatory pricing practices, applying consistent fee structures to clients with comparable transaction profiles. Fee-setting is based on objective commercial parameters and is not influenced by nationality, entity type, or individual client relationship, ensuring regulatory fairness and pricing integrity.
For exceptionally large orders that exceed standard available liquidity, Canis may:
• propose partial execution, or
• delay execution to avoid market disruption.
In such cases, Canis will agree any special execution terms with the client before proceeding. This ensures that clients are fully aware of any implications on pricing and maintain control over transaction approval.
Together, this pricing strategy balances market transparency, client-centric fairness, and operational efficiency, and aligns with MiCA compliance expectations.
Other Considerations:
• Network (Blockchain) Fees: Canis absorbs all blockchain network fees (e.g., gas fees for token transfers) associated with the execution of standard transactions. These costs are not passed on to the client and are covered by the flat €5 conversion fee charged per transaction.
• However, if a transaction is cancelled after funds have already been transmitted on-chain — and a refund to the client becomes necessary — the blockchain network fees incurred in processing the return will be borne by the client. This ensures operational efficiency while maintaining fairness in exceptional cases requiring reversal.
• Maximum Quote Validity: (Policy Note: Canis’s business plan implies real-time execution; however, for risk management, quotes typically have a validity window.)Each price quote delivered via the platform is valid only for a short period (e.g. 60 seconds) or for a maximum specified amount, as indicated to the client. If the client does not accept the quote within the validity window, it will expire and a new quote must be generated. This ensures that rapidly changing market prices do not render the quote stale. The platform clearly communicates quote expirations
(countdown timer or timestamp). Once a quote is accepted, the order process locks in that price (see Section 5).
In summary, Canis’s pricing policy is built on transparency, predictability, and fairness. Every fee component is disclosed and justified by underlying costs. Clients can readily calculate the cost of their conversions and trust that they are getting the displayed quote with no surprise fees post-trade . The full fee schedule is attached (Annex 1) and made availableon the client portal, fulfilling MiCA’s requirement to publish information on pricing determination. Any changes to fees would be communicated in advance and updated in this Policy and the Service Agreement – however, Canis does not anticipate significant changes, as the model is tied to fixed spreads and market-driven components rather than arbitrary adjustments.
5. Order Execution Finality and Terms
5.1. Order Initiation:
Clients initiate a conversion transaction on Canis’s platform via a secure web dashboard or API interface by selecting the desired conversion type (e.g., EUR to USDC) and entering the transaction details. The platform then prompts the client to transfer the funds to a designated Canis bank account or wallet address (depending on whether it is a fiat or crypto conversion). This step includes presenting a unique reference and transfer instructions to ensure proper allocation of incoming funds.
5.2. Offer Generation:
Once the funds are received (in accordance with specified SLAs for fiat or crypto fund receipts), Canis verifies the deposit and then generates a real-time exchange quote. This quote reflects the applicable rate and any associated fees, and is made available to the client through the dashboard or API. Quotes are valid for 60 seconds from issuance; if not accepted within this time, they expire automatically.
5.3. Finality of Orders:
A transaction becomes final and binding once the client explicitly accepts the offer provided after funds have been received. At this point, the contract is formed at the quoted rate and the transaction proceeds to execution. Canis then releases the corresponding converted funds to the client’s specified bank account or wallet. The offer is only valid for a limited period after receipt of funds, and clients must act promptly to accept or request a refreshed quote.
If the client declines the offer or fails to respond in time, the transaction is cancelled and funds may be returned, subject to applicable fees and compliance checks. If no action is taken within three days of fund receipt (for fiat fund receipts), the transaction is also cancelled automatically.
5.4. Order Integrity and Compliance:
The order process is designed to ensure price transparency and client consent before execution. By only locking in the price after receiving funds and obtaining explicit acceptance, Canis ensures both parties are protected against market volatility and operational risks. The order is only valid if the client's payment is received in full and passes compliance verification.
After this point, the order cannot be cancelled by the client and the price will not change. The conditions under which an order is deemed final are made transparent to clients (this Policy and the Service Agreement detail that once you initiate the transfer and accept a quote, you are locked in). Execution at Displayed Price: In compliance with Article 77(2) of MiCA, Canis guarantees that all final client orders are executed at the exact price that was displayed at the time the order became final. This means once the client accepts the quote (locking in, say, a rate of 1 EURC = 0.99 EUR), the client will receive that full amount without any repricing. Even if market prices move in the brief period during settlement, the client’s rate is fixed at confirmation. Canis hedges and manages liquidity in the back-end to honor the quoted price. The “displayed time” is clearly defined: for online dashboard users, it’s the timestamp of acceptance; for API users, it’s the moment the quote acceptance is received by our server. The platform issues an order confirmation record at that time, which includes the locked-in price and terms. From there, Canis will not adjust the price regardless of later fluctuations – the client is fully shielded from market movements after confirmation (positive or negative). This policy ensures fairness and reliability, preventing any “bait-and-switch” or slippage. Settlement Process: Once an order is final, Canis executes the exchange promptly:
For crypto-to-fiat (off-ramp) orders: the client’s transfer of stablecoins is monitored on-chain. As soon as the crypto is received in the provided address and passes the on-chain analytics check (e.g. Sumsub KYT score), Canis triggers the fiat payout. The partnered licensed credit institution, holding the client’s fiat currency in a safeguarded account, is instructed to release the fiat funds to the client’s bank account. The timing is generally near-instant for euro SEPA transfers (if using SEPA Instant) or within the same business day for standard transfers. In all cases, MiCA requires timely settlement; Canis’s policy is to complete fiat settlement on the same day the crypto is received (typically within minutes/hours). If an order is confirmed outside banking hours, the fiat leg will be queued and sent at the start of the next banking day at the locked-in rate.
For fiat-to-crypto (on-ramp) orders: the client initiates a fiat payment (e.g. via instant bank transfer). Upon confirmation that the fiat funds are in the licensed credit institutions, Canis releases the corresponding stablecoins to the client’s designated blockchain address. The stablecoins may be sourced from OTC desks; the swap occurs and the crypto is delivered on-chain to the client. The client thus receives the stablecoins in their own wallet, and the order is complete.
For crypto-to-crypto orders: the client sends in the source stablecoin (e.g. USDC) to a provided address; once received and verified, Canis facilitates the conversion through an OTC desk (swapping USDC to EURC, for instance). The target stablecoin (EURC in this example) is then sent to the client’s wallet. Both legs (inbound and outbound crypto) occur on-chain. Typically this is fast (within one or two block confirmations on each chain).
While the settlement steps above reflect the operational flow of each order type, it is important to note that the price quote is only accepted and locked in after the client’s funds (fiat or crypto) are received and verified. This means that the contractual rate and execution obligation are confirmed only after Canis receives the incoming funds, ensuring alignment with regulatory requirements and protecting both parties from market volatility. This model applies across fiat-to-crypto, crypto-to-fiat, and crypto-to-crypto flows.
Throughout execution, Canis never commingles client assets with its own. Crypto assets flow from the client to OTC trading platforms, and then to the client’s target wallet. Fiat flows within the licensed credit institutions segregated accounts structure. Canis’s internal systems track the order and facilitate communications between the OTC trading platform and licensed credit institution, but at no time does Canis take possession – fulfilling the non-custodial promise and reducing settlement risk. An outline of the flow is provided in Annex 3 for clarity. See Annex 3: Transaction Reporting Format & Data.
Compliance Checks and Rejection: All orders are subject to certain automated compliance checks at execution. For instance, upon receiving crypto, Canis’s system performs a “Travel Rule” and KYT check – verifying the funds are not from a blacklisted address and that required originator/beneficiary information is attached if above thresholds. If a transfer fails these checks (e.g. high risk score or sanctions hit), Canis may pause execution and potentially return the funds after investigation, consistent with AML obligations. Similarly, if a fiat payment is suspected fraudulent or from an unverified account, it may be blocked. Such cases are exceptional and handled per legal requirements; the commercial policy primarily deals with legitimate orders which are processed without discrimination or delay.
If an order is cancelled or not executed due to compliance reasons or client default, Canis will notify the client and, reverse the transaction (e.g. return crypto to sender) according to the Service Agreement terms. The client would not be charged the fees in such case (except costs incurred while returning the funds). These provisions protect the platform integrity and comply with AML/CTF laws, and they apply equally to all clients.
In summary, once a client’s order is finalized at a quoted price, Canis executes it promptly at that price with no deviation. The client receives a confirmation of execution (detailed in Section 6) and can rely on the finality of their trade. The processes above ensure a clear point of no-return (client acceptance) and a robust fulfillment of the quote through integrated partners. Conditions for finality and execution are fully disclosed to clients as part of this Policy (fulfilling MiCA’s requirement to publish information on how orders are deemed final and executed).
6. Post-Execution Transparency and Reporting
Canis is committed to post-trade transparency for the benefit of clients, regulators, and market integrity. After executing a transaction, Canis provides information at two levels: individual transaction reporting to the client, and aggregate market data publication.
Transaction Confirmation and Client Report: For each completed exchange order, the client is provided with a detailed transaction report available immediately through the dashboard and via API download. This report serves as the trade confirmation and contains all key details needed for the client’s reconciliation, auditing, and compliance records. Specifically, the standard report includes:
The date and timestamp of execution (in UTC) and a unique transaction ID/reference number.
The asset pair and amounts exchanged: e.g. “Converted 100,000 USDC to 2,300,000 CZK”.
The exchange rate applied
The Transaction fees charged
The conversion fees charged
The network fee charged for the crypto transfer (if any). While these costs are absorbed by Canis, they are still displayed in the transaction report – e.g., ‘Blockchain fee: 15 USDC’ – together with the blockchain transaction hash or identifier.”
Any reference to the client’s original order ID
All of this information is delivered in a user-friendly format (on-screen and downloadable PDF/CSV). The report is available immediately once the trade is done, ensuring the client has near real-time visibility. This level of detail provides full post-trade transparency. The client can see exactly how the price was determined (via the fee and source info), confirm that they got the agreed rate, and have evidence (like the transaction hash) of execution. These reports also help clients with their own regulatory reporting or audits, as they contain time-stamped records and confirm Canis’s role as a regulated CASP counterparty.
Publication of Transaction Details: In accordance with MiCA Article 77(3), Canis will publish aggregated information on executed transactions, including volumes and prices, in a transparent manner. The goal is to contribute to market transparency so that the public or participants can gauge the activity and pricing on our platform. Canis will implement this by regularly (at least bi-annually, and potentially more frequently) publishing anonymized trading statistics. The published data may include total volume exchanged on the platform (e.g. monthly volume in EUR), breakdowns by crypto-asset pair (e.g. USDC/EUR volume, USDC/CZK volume, USDC/EURC volume), average or indicative prices/rates for major pairs, and number of transactions. We will include price information such as high/low or average execution price over the period for each pair, to demonstrate that clients are getting fair market rates. Individual transaction prices and volumes are not published with client identities, of course; confidentiality is maintained. Instead, data is either aggregated or anonymized. For example, Canis might publish on its website: “In Q1 2026, Canis facilitated €50 million in stablecoin exchanges. Average execution price for USDC/EUR was 0.9991, with a total of 500 trades.” These disclosures will be made in a public section of Canis’s website or via public reports, accessible to anyone (including market observers and the regulator). The format and content of published data will meet any standards set by ESMA or the Czech National Bank for post-trade transparency. By publishing transaction details (volumes and price metrics), Canis satisfies MiCA’s requirement to Ensure post trade transparency. It helps prevent information asymmetry and demonstrates that Canis’s pricing is consistent with broader market conditions.
Data Retention and Regulatory Access: In addition to public transparency, Canis maintains comprehensive records of all orders and transactions (including times, amounts, client identities, etc.) to comply with record-keeping obligations. These records are kept for at least 10 years in immutable form. Detailed data can be made available to the Czech National Bank or ESMA upon request for supervisory purposes. Canis’s internal systems tag each transaction with all required details (order time, finalization time, etc.) so that it can reconstruct the execution lifecycle for audit.
Client Account Statements: Beyond individual trade confirmations, corporate clients receive periodic account statements from Canis summarizing their activity (for example, monthly statements showing total volume, fees paid, rebate earned, etc.). These statements complement the per-trade reports and help clients verify that all trades are accurately recorded. They also provide transparency on fees in aggregate, aligning with the spirit of MiCA’s cost transparency rules.
Changes and Accessibility: This Commercial Policy, including the pricing and transparency commitments, is a public document. It will be made available on Canis’s official website and provided to all clients as part of onboarding. Any updates (e.g. changes to the fee structure or publishing frequency) will be promptly communicated and the revised Policy published. Canis will review this Policy at least annually, or sooner if required by changes in MiCA or delegated acts, to ensure ongoing compliance and accuracy.
By adhering to the above practices, Canis ensures that its clients and the market are kept fully informed about how it conducts its exchange business – from who can access, on what terms, at what prices, to what is reported afterward. This comprehensive transparency fosters trust and allows the Czech National Bank to supervise Canis’s activities effectively.
Annex 1: Pricing Model Details
This Annex provides a concise summary of Canis’s pricing components and schedule, as referenced in Section 4.
Transaction fee as a % of notional transaction value. This is the total fee charged as a percentage of transaction value presented to the client. It includes all costs and profit margin for Canis.
Conversion Fee: €5.00 per order. This fee is designed to cover operational expenses such as blockchain gas and network fees and any other compliance costs. Canis absorbs these costs internally and does not pass any variable blockchain fees directly onto clients, ensuring cost stability and simplicity.
Supported Assets: (For reference in pricing) Currently supported crypto-assets are major fiat-backed stablecoins such as USDC and EURC, and supported fiat currencies are EUR, CZK, USD, MYR, IDR. Canis’s spreads are calibrated for these assets. New assets may be added in the future with regulatory approval and would be accompanied by an updated fee schedule if different.
Quote Validity: Each price quote is typically valid for a short window (e.g. 60 seconds) and for the specified amount. After expiration, a new quote may be required. All quotes and subsequent executions adhere to the above fee terms.
(All the above fee terms are disclosed to clients in the Service Agreement and on the platform. Canis does not impose any other charges (no registration fees, no account fees, no withdrawal fees) aside from those listed here. This Annex may be updated from time to time and publicly available to ensure clients have the latest information.)
Annex 2: Client Eligibility Criteria
(This annex details the eligibility conditions from Section 3 in a checklist format for clarity.)
To be accepted as a client and maintain an account with Canis, an applicant must meet all the following criteria:
Legal Entity : The client must be a juridical person (company or organization) legally incorporated. Proof of incorporation (e.g. extract from commercial register) and registered office is required. Canis does not serve natural persons (consumers) or entities from outside the EU/EEA under this Policy.
Non-Consumer Business Use: The client’s intended use of the platform must be for business or institutional purposes (e.g. treasury operations, merchant settlement, liquidity management) and not for personal investment or consumer needs. Canis may require a description of expected use cases during onboarding to ensure fit with its B2B services.
KYC/KYB and AML Compliance: The client must undergo and pass Canis’s KYC/KYB due diligence. This includes:
Providing identification information for the entity (certificate of incorporation, registered address, etc.).
Identifying all owners with >25% stake and controlling persons (beneficial owners) and providing their identification (passport, etc.).
Undergoing sanctions screening and PEP (Politically Exposed Person) checks for the entity and key persons.
Undergoing an AML risk assessment – certain high-risk industries or geographies may require enhanced checks or be declined in accordance with AML laws.
Ongoing: agreeing to periodic updates of KYC information and continuous monitoring (transaction monitoring, sanctions screening on transfers). Clients must not be involved in prohibited activities (e.g. dark net markets, fraud, etc.) as per Canis’s AML policy.
Agree to Terms and Policies: The client must review and accept the Service Agreement and all annexed policies (including this Commercial Policy, the Platform Terms of Use, Privacy Policy, etc.). This contract governs the relationship. By signing, the client agrees to abide by Canis’s rules, including no misuse of the platform for illicit purposes, adherence to market conduct rules (no market manipulation, etc.), and acceptance of fees. Corporate resolution or authorisation may be required to ensure the person signing has authority.
Designated Account & Wallet: The client must have:
At least one fiat bank account in its name, capable of receiving EUR (and CZK if needed) via standard banking channels. This is necessary for fiat payouts from the licensed credit institution. The IBAN and bank details must be provided and verified (e.g. via a penny test transfer).
At least one crypto wallet address (or custody account) under its control for each stablecoin it plans to transact. These addresses must be provided to Canis and will be whitelisted for payouts. Canis will only ever send crypto to the client’s verified addresses. (The client can update these with proper procedure.)
An API integration or dashboard access setup. This means the client’s technical team should generate API keys on the platform if using API, or ensure the authorized users can access the GUI. Multi-factor authentication is required for login.
No Retail Distribution: The client must not be using Canis to intermediate on behalf of unverified retail customers. Canis’s service is not a white-label for unregulated downstream retail services. (If the client is an intermediary like an EMI or broker that will offer crypto conversion to its own clients, that setup must be disclosed and approved, and those end users those end users would not have direct access to Canis’s platform.)
Compliance with Laws: The client must certify and maintain that it complies with all applicable laws (including AML/CFT, tax laws, etc.) in its home jurisdiction. For example, a regulated financial institution using Canis must confirm it has any necessary approvals to handle crypto, etc. Canis may request evidence of relevant licenses if applicable. The client also agrees not to use the service in violation of any sanctions or for any illicit trade.
Financial Solvency and Capacity: The client should be solvent and able to meet its financial obligations. Canis might perform basic credit or background checks for large corporate clients. Clients must fund their transactions (fiat or crypto) from legitimate sources and not expect credit or forward settlement from Canis (no leverage is offered).
Non-Discrimination Clause: These criteria are applied equally to all applicants. If an applicant meets all the above, Canis will not refuse service except for justified regulatory reasons. There is no bias with regard to specific industry (barring illegal industries) or size. If any criteria is not met, Canis will provide an explanation (e.g. “Your jurisdiction is not supported” or “Failed KYC due to ...”).
All clients must continue to meet these criteria for the duration of the relationship. Material changes (e.g. change of ownership of the client, change of business activity) must be notified so Canis can reassess eligibility. Canis reserves the right to suspend or terminate clients that fall out of compliance, in a fair and consistent manner. The above criteria ensure Canis’s services are restricted to a qualified, vetted client base in line with its B2B, non-discriminatory commercial focus.
Annex 3: Transaction Reporting Format & Data
(This annex outlines the format and content of the transaction reports and disclosures, as referenced in Section 6.)
For each executed exchange transaction, Canis will record and report the following information:
Transaction Timestamp: The date and time when the transaction was executed/finalized (in ISO 8601 format, e.g.2025-08-15T14:03:22Z) . This corresponds to when the order became final and locked-in.
Unique Transaction ID: An internal reference code or UUID assigned by Canis to identify the transaction. This ID is used for any support queries or audit trail.
Client ID/Account: (In client-visible reports, this might be implicit as the report is delivered to the client, but internally and in any data provided to regulators, the client’s identifier is attached.)
Trade Details: A description of the exchange performed, including:
Asset Pair: e.g. USDC/EUR, EUR/EURC, etc., indicating what was sold and what was bought.
Input Amount and Asset: e.g. 100,000 USDC (what the client provided).
Output Amount and Asset: e.g. 2,300,000 CZK (what the client received). This is calculated using the locked-in rate.
Exchange Rate/Price: The price at which the trade was executed. This can be shown as one unit of crypto in terms of fiat (or vice versa). E.g. 1 USDC = 23.00 CZK. e.g.
Transaction Fee: The % fee applied on the transaction value, which is pre-determined in the client agreement and applied to consistently to every transaction.This gives the client transparency on fees paid.
Total Fees in Fiat: Optionally, the report might also state the total fee amount in EUR (or in the transacted currency) that the client paid. For instance, “Fee: €500 (included in the rate)”. This helps clarity.
Blockchain Transaction Hash: For any crypto transfer that occurred (either from client to Canis’s partner or from Canis’s partner to client), the TX hash or ID on the blockchain is provided. For example: “Ethereum tx hash: 0xABC123... (clickable link)”. This lets the client verify on-chain that the transaction indeed took place for the correct amount to the correct address.
Network Fee: The amount of crypto paid as network fee for the transaction (if applicable). E.g. “Network fee: 12.5 USDC”. This might be included in the TX details as well, but it’s stated for clarity on costs. These are absorbed by Canis and not passed on to the client.
Timestamp of On-Chain Settlement: Optionally, the time the crypto was confirmed on-chain and/or the time the fiat was sent. Optionally, separate timestamps may be recorded for on-chain confirmation and for fiat settlement. All the above information is provided to the client in a confirmation report right after execution. The format is concise and clear, often in a tabular or bullet layout. This level of detail ensures auditability – the client (and regulators, if needed) can trace every aspect of the trade. The inclusion of the all charges as well as those waived demonstrates compliance with the obligation to be transparent about price formation. The transaction ID and timestamps ensure an audit trail.
Regulatory Reporting Format: In addition to client-facing reports, Canis will maintain logs of transactions in a format that meets any reporting standards set by authorities (for example, if required under MiCA or other regulations to report trades to a central repository or upon regulator request). This might include formatting data in a CSV or XML with fields like those above plus client LEI, etc. (MiCA will introduce some transaction reporting obligations via regulatory technical standards – Canis is prepared to comply by capturing all necessary data points such as client IDs, timestamps, asset identifiers, etc., as seen in the confirmation details.)
Periodic Public Statistics: As noted, aggregated transaction details (volumes, etc.) will be published without client-specific data. For example, a public report might state: “Total volume in Q1 2026: €50,000,000; Average USDC/EUR rate: 0.999; Largest single transaction: €1,000,000; Number of transactions: 1,200.” This does not reveal any particular client’s activity but gives the market useful info. The published data will at minimum fulfill the requirement of disclosing transaction volumes and prices in aggregate.
By providing both granular reports to clients and high-level data to the public, Canis meets all post-execution transparency obligations. Clients have the information needed to trust and verify each transaction, and the market/regulators have the data to observe Canis’s fair and orderly operation. This comprehensive reporting framework is an integral part of Canis’s Commercial Policy and will be maintained as the business grows.
