PUBLIC DISCLOSURES
WUBU FZCO (“Wubu”) provides ‘Broker Dealer Services’ for virtual assets and is licensed by the Virtual Assets Regulatory Authority (“VARA”) in Dubai, United Arab Emirates. These public disclosures (“Public Disclosures”) have been developed for Wubu. These Public Disclosures are reviewed annually, unless there is a change in regulation or Wubu’s business that requires to implement an earlier update.
-
LICENSE DETAILS
Wubu is applying for a Virtual Asset Service Provider (“VASP”) license from VARA.
-
CONFLICT OF INTEREST
Wubu is committed to conducting its business according to the principle that it must manage any conflicts of interest appropriately. At present there are no actual or potential, identified conflicts of interest arising out of Wubu’s Broker Dealer Services. Wubu has and will continue to identify potential conflicts of interest on all fronts, including those arising out of its outsourcing arrangements with group entities. Wubu has put in place internal policies, mechanisms and guardrails to ensure that no actual conflicts arise or are adequately managed should they arise.
-
PRIVACY
Wubu appreciates you trusting us with your personal data. We are committed to protecting your privacy. For more details on how we collect and process your personal data, you can access our Privacy Policy at https://www.wubu.com/pp.
-
COMPLAINTS AND WHISTLEBLOWING
-
Complaints: Wubu is committed to promptly, fairly, consistently and efficiently resolving all complaints received by clients and/or other stakeholders. Wubu views complaints as an opportunity to continually improve the quality of its offerings. To that end, Wubu has formulated and implemented a comprehensive complaint handling procedure. If you seek to make any complaints, you can write to us at help@wubu.com or fill out this form at https://www.wubu.com/help. For further details on our complaints handling procedure and policy, you can read our complaints handling policy at https://www.wubu.com/complaint.
-
Whistleblowing: Wubu strives to maintain the highest standards of integrity, accountability, and transparency, by being responsive to all employees and stakeholders, and treating its employees with respect. Wubu also demonstrates commitment to its own policies and applicable laws and regulations. To facilitate such ethic in the organization, Wubu has formulated a whistleblowing mechanism to enable voicing of concerns in a responsible and effective manner. For further details on our whistleblowing policy, you can read our whistleblowing policy on the Company’s website. If you seek to raise any concerns, you can write to us at help@wubu.com anonymously. You can also write to service@wubu.com for a copy of our whistleblowing policy.
-
-
RISK
Virtual assets and their transactions are subject to several risks, including but not limited to market risks, credit risks, liquidity risks, and technology risks. Please read our detailed Risk Disclosure Statement at https://www.wubu.com/rd for more information on the risks associated with virtual asset.
-
SERVICES
Wubu provides Broker Dealer Services in relation to fiat-referenced virtual assets, namely USD Coin (USDC), USD Tether (USDT), USD Binance (BUSD) (“Virtual Assets”). Wubu does so by arranging orders for the purchase and sale of Virtual Assets between two entities or persons; soliciting or accepting orders for Virtual Assets by accepting fiat currency or other Virtual Assets for such orders; and entering into virtual asset transactions as a dealer on behalf of an entity for its own account (collectively the “Services”).
The list of Virtual Assets and Services offered by Wubu is constantly evolving and if we add, modify, amend or otherwise change a Service, or amend the list of supported Virtual Assets, in whole or in part, we will update the website accordingly. Currently Wubu trades in the Virtual Assets as detailed below:
Sr. no.
Virtual Asset and symbol
Issuance Date
Market capitalisation and fully diluted
value
Circulating supply
Date of last independent smart
contract audit
Largest price reduction
1.
USDC
September 26, 2018
Market Cap:
$34,150,270,813
Fully Diluted:
$34,144,392,339
34,148,205,417
USDC (100%)
May 31, 2024
Dropped to
$0.9769 on 18/03/2020 (2.31%)
2.
USDT
2014
Market Cap:
112,259,808,785
March 31,
Dropped to
$112,245,160,36
USDT (96.71%)
2024
$0.6051 on
4 Fully Diluted:
$116,059,870,085
03/03/2015
(39.39%)
3.
BUSD
September 5, 2019
Market Cap:
$69,566,598
Fully Diluted:
$69,566,793
69,511,448 BUSD
(100%)
May 31, 2024
Dropped to
$0.9714 on 18/03/2024 (2.86%)
-
RESPONSIBLE INDIVIDUALS
In accordance with applicable laws and regulations, Wubu has appointed the following two (2) individuals who are senior officials at Wubu as responsible parties to ensure Wubu’s compliance with all legal and regulatory obligations:
Sr. no.
Name
Designation
E-mail
1.
Mr. Youcun Chen
Chief Financial
Officer/Chief Operations Officer
2.
Mr Tariq Abu Ragheb
Chief Executive Officer
-
PRICING
The prices of the Virtual Assets quotes to our clients are determined by Wubu, considering the following: a. External price sources from liquidity providers;
-
The current risk position of Wubu; and
-
Per-client configurations, determined by Wubu or, in some cases, at the request of the client.
-
-
EXECUTION & REFERRALS
Client orders will always be executed by Wubu on execution venues which Wubu chooses. Wubu may act as an agent or as a principal to fulfil its client orders. The decision to act either as an agent or a principal is determined by a multitude of factors, which are listed in our internal policies. Wubu will notify its clients with whom it has an ongoing business relationship of any material changes to its order execution policy or arrangements.
A description of Wubu’s order execution and routing practices may be sought by clients by writing to service@wubu.com.
In the event Wubu routes twenty percent (20%) or more of its orders to any single liquidity provider, the identity of such sources will be updated below:
|
Sr. No. |
Legal Name |
Trading Name |
Volume (Last three months) |
|
1. |
|
|
|
|
2. |
|
|
|
Wubu does not introduce or refer its clients to any other entities including other virtual asset service providers.
10. HOLDING AND CONTROLLING CLIENT MONEY
Wubu does not offer custody services in relation to virtual assets for its clients. However, in the process of providing its services, Wubu may hold or control Client Money (as defined in the VARA Compliance and Risk Management Rulebook). This Client Money will be held in dedicated Client Accounts (as defined in the VARA Compliance and Risk Management Rulebook) in accordance with applicable laws and regulation. Client Money held with desginated licensed financial institutions licensed
in the UAE, that are well versed with handling of Client Money. Wubu shall ensure that Client Money is always identifiable and secure. Wubu shall ensure compliance with all applicable law and regulations in handling and controlling Client Money including formulating and implementing the necessary policies, systems and controls, appropriate to the nature and scale of Wubu’s operations. Wubu’s own operational funds accounts will not be commingled with the Client Money.
11. HOLDING AND CONTROLLING CLIENT ASSETS
Wubu does not offer custody of Client VAs (as defined in the VARA Compliance and Risk Management Rulebook).
Wubu uses licensed third-party service providers, as an external custodian to safeguard Client VAs. Fireblocks LLC custodies Client VAs in line with its own regulatory approvals. Wubu only takes custody of Client VAs in the course of providing its Broker Dealer Services.
Among the key arrangements envisaged to this end, Wubu selects custodians only after having performed due diligence on such service providers. This entails an analysis on the regulatory status, internal approvals processes, and risk management practices. Wubu intends to appoint only entities ensuring asset segregation or equivalent safeguards for long-term custody purposes. Wubu will conduct such due diligence on its service providers on a regular basis, to ensure the regulatory status of the service provider.
12. STATEMENTS BY WUBU
Wubu does not hold or maintain funds or virtual assets or provide clearing services for other VASPs.
13. PAST CONVICTIONS
Wubu and any members of its senior management or board have not been previously convicted or prosecuted, either before the courts of the UAE or the courts of another jurisdiction.
