Prepared in accordance with the Rules on the Licensing of Crypto-Asset Service Providers, approved by Resolution No. 03-157 of the Board of the Bank of Lithuania of 17 December 2024, point 7.
UTRG UAB follows a transparent, fair commercial policy for its crypto exchange services, fully meeting Article 77 requirements. In practice, this means all clients are treated fairly and pricing is applied in a consistent manner. We ensure you get clear, upfront pricing for buying and selling crypto-assetsfor buying or selling crypto-assets, and that no client receives hidden advantages or is unfairly disadvantaged. The key elements of this policy are as follows:
Equal Service for Eligible Clients: UTRG UAB serves all clients who meet our eligibility criteria (such as required Know-Your-Customer verification, acceptable risk profile, and jurisdiction requirements) on an equal footing. We publicly disclose what client categories we serve and any conditions for service, and all clients who satisfy these conditions are offered the same pricing methodology without any preferential treatment. There are no secret rates or undisclosed agreements – our commercial policy strictly prohibits unjust discrimination.. In other words, the prices and fees you see are the same as those offered to any other client in a comparable situation.
Transparent Price Quotations: We operate on a principle of price transparency. UTRG UAB We openly publish all exchange rates on our platform, so you always know the price before trading. The price quote you receive for a transaction includes any applicable markup or fees, and we also indicate any limits (such as minimum or maximum order sizes, or daily volume limits per client tier) that might apply. All the parameters of an exchange transaction – the rate, the amount of crypto and fiat, any service fees, etc. – are clearly shown to you before you finalise the trade. Additionally, these pricing terms are documented in our client-facing materials (like user agreements and FAQs), so you can understand how prices are determined. This commitment to transparency allows you to make informed decisions and eliminates surprises.
Firm Quotes and Final Execution: When you initiate an exchange transaction, Our system presents a firm quote that remains valid for a short acceptance period. You are given a chance to review the rate and confirm the trade. Once you accept the quoted price and submit your order, UTRG UAB will execute the order at that exact price, provided you meet any necessary conditions (for instance, you have sufficient funds and have passed all compliance checks). We clearly inform you at which point an order becomes irrevocable – typically, that is the moment you confirm the transaction on our interface. After execution, we send you a confirmation with all the details (the amount exchanged, the final price, fees, timestamp, etc.), for your records. This process guarantees that you get the price you agreed to. We do not engage in practices like altering the price after your confirmation or executing your order at a worse price; doing so would violate both our policy and regulatory obligations. In short, once you lock in a trade, it will be honoured at the agreed-upon price.
Market-Based Pricing Sources: UTRG UAB’s exchange rates are derived from reliable market data to ensure fairness. We obtain reference prices from multiple veriffied liquidity providers, including major crypto exchanges and professional market-makers, rather than relying on a single source. Our pricing system collects market data from multiple sources and calculates a fair average price. It also automatically filters out any abnormal or outlying quotes that deviate significantly from the market norm (for example, stale data or erroneous spikes). By using a broad set of sources and algorithmic validation, we provide you with exchange rates that reflect the true market value of the crypto-asset at any given moment. Our system also has redundancy – if one data source fails or lags, others ensure continuity – so that pricing remains accurate and up-to-date. This approach ensures that all clients receive a fair market price for their trades.
Fair and Consistent Spreads: Like any exchange service, UTRG UAB includes a spread or small markup in the price quotation to cover our costs and risks. Our pricing methodology applies this spread in transparently and consistently for all clients. . Typically, the exchange rate we offer you is the current market mid-price plus a fixed percentage or fee that represents our service charge. The spread may vary depending on the liquidity of the asset and the size of the transaction (for instance, very large or illiquid trades might incur a slightly higher spread to account for execution risk), but it is determined by a predefined algorithm – not arbitrary judgment. We continuously monitor market volatility and industry rates to ensure our spreads remain reasonable and competitive. Importantly, when we display the quote to you, it already includes the spread or fee. The “final reference price” you see incorporates any markup, so you know exactly what you’re getting and what cost is involved. We do not add hidden surcharges later. This standardised approach to pricing means that whether you are exchanging €100 or €10,000 worth of crypto, the method for calculating your price is the same and is fully disclosed to you upfront.
Slippage Control and Repricing Mechanism: We protect clients from excessive market volatility during the trading process through slippage controls. When you receive a quote, it is typically valid for a brief window (e.g. 15 seconds), during which normal minor market fluctuations are tolerated. However, if the market moves significantly beyond a set threshold in the moment before your order is executed (for example, due to a sudden price jump or drop), our system will refresh the quote so you trade at a fair current rate. Instead, it will require a refreshed quote to ensure you trade at a fair current rate. In practical terms, if there’s a sharp price movement while you’re in the process of confirming a trade, we may cancel the old quote and present a new one for you to accept (this is called repricing). Similarly, if you attempt an unusually large trade that cannot be filled at the quoted price due to liquidity constraints, we might need to adjust the order – for instance, offering to fill part of the order or providing a new price for the full size. We will always communicate the reason if an order is not filled immediately at the original quote (common reasons might be “market moved beyond tolerance” or “requested size exceeds available liquidity”). This policy ensures you’re not subject to unfair “slippage” costs; you maintain control to decide if you accept a new price in volatile conditions. In the event of any order rejection or requote, an explanation is provided, and you have the choice to proceed or not. This approach aligns with regulatory expectations that clients only trade at prices they have knowingly accepted, and it maintains fairness during unpredictable market situations.
No Conflict of Interest in Pricing: UTRG UAB acts as a principal to your trades, meaning we fulfil your orders directly, but we have built-in safeguards to eliminate conflicts of interest between the Company and our clients. We do not engage in proprietary speculative trading against client orders, nor do we “front-run” client trades (using knowledge of your order to our advantage). Our exchange service’s sole purpose is to execute your transactions at the disclosed price. We also keep client assets strictly segregated (as described in our segregation policy) – for example, the crypto or fiat funds involved in your trade are not mixed with UTRG UAB’s own operating funds and cannot be used for our own trading activities. Pricing decisions are made by our automated engine using objective market data, not by individual traders looking to profit at your expense. Additionally, there are no “special deals” behind the scenes: we do not give certain clients undisclosed rebates, and we don’t have affiliate arrangements that would undermine the standard pricing (any promotional fees or tiered discounts we may offer are transparently published and available to those who qualify). In summary, our commercial policy is structured so that UTRG UAB’s interests align with providing you a fair execution, and we avoid any practice that would create an unfair advantage or conflict.
Post-Trade Transparency and Auditing: In line with MiCA’s requirements for market integrity, UTRG UAB will periodically publish aggregated data on our exchange activity to promote transparency. For example, we may publish statistics such as total trading volumes and average prices on our website or in reports, so that clients and the public can see information about overall market activity on our platform. (No personal or private trade data is disclosed, just anonymised aggregate figures.) Internally, we maintain comprehensive records of every trade executed. This includes keeping logs of the quotes offered, the client’s acceptance, the final execution details, and timestamps for each step. All order and transaction data is stored in durable form and retained for at least the legally required period (8 years or more) as part of our recordkeeping rules. We have systems in place to ensure these records are tamper-proof and secure. Moreover, our Compliance team and Regular internal audits verify the operation of our pricing methodology. Internal Audit, in particular, conducts independent checks – they may sample random trades to verify that the prices and spreads applied were in line with our policy and that no irregularities occurred. Any findings are reported to management, and if any issues were ever discovered, we would take corrective action promptly. This oversight ensures that our non-discriminatory pricing commitments are continuously met in practice. As a client, you can be confident that our exchange service is run with transparency, fairness, and accountability at its core.