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Finary est agréé MiCA : investissez en crypto sur une plateforme régulée par l'AMF
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This policy on the best selection of intermediaries (the “Policy”) sets out the mechanism for selecting and assessing the entities to which Finary transmits its clients' orders for execution. It also specifies the due diligence carried out prior to entering into a relationship with an intermediary.
It applies to the orders transmitted by Finary's clients in the context of the reception and transmission of orders on behalf of third parties service, the only service concerned, across two perimeters:
Finary does not execute orders, is not a member of any market or trading venue, and is not authorised to provide the service of executing orders on behalf of third parties. Execution falls exclusively to the selected intermediaries, upon whom the best-execution obligation rests. Finary's obligation is an obligation of best selection of these intermediaries.
The Policy applies to professional and non-professional clients. It does not apply to orders that are the subject of specific client instructions, nor to eligible counterparties, with which Finary does not deal. Save in specific cases, the transmission of an order to Finary amounts to acceptance of the Policy.
In the context of its order reception and transmission activity, Finary takes all sufficient measures to serve the best interests of its clients. As it does not execute orders, Finary selects, for each activity and each asset class, the entities to which orders will be transmitted for execution, and ensures that these entities have execution arrangements enabling them to obtain the best possible result for Finary's clients.
Finary selects, on behalf of its clients, intermediaries that have taken all measures aimed at obtaining the best possible result throughout the execution of the orders transmitted to them. Third parties are selected taking into account price, cost, speed, likelihood of execution and settlement, the size and nature of the orders, and any other consideration relevant to execution, these factors being assessed for the purposes of the selection and monitoring of intermediaries, and not of an execution that Finary would itself carry out. The process rests on the documentation of all the steps and on a review, at least annually and upon each significant event, of the selection carried out, which may lead to the suspension or removal of a referenced counterparty.
The entry into relationship with a new entity is the subject of a formal review by Finary, on the basis of a summary sheet and a complete file. Compliance conducts, together with Operations, the due diligence and the first assessment against the criteria below. Finary's Management approves the final choice.
Financial instruments (PSI):
Intermediaries are selected and assessed on the basis of the following criteria, assessed in combination:
In accordance with the applicable regulations, the best possible result for non-professional clients is assessed on the basis of the total cost, corresponding to the price of the financial instrument plus the costs related to execution. The other criteria may be given primacy only to the extent that they contribute to obtaining the best result in terms of total cost.
Crypto-assets (PSCA):
Compliance collects, at a minimum: the intermediary's execution policy, its policy for the prevention and management of conflicts of interest, and its AML-CFT procedure. It may request any useful document to ensure that the execution factors are actually taken into account by the third party in order to obtain the best possible result for the client, that its financial situation is sound, that it has references in terms of reputation, and that it covers the markets offered by Finary to its clients.
Each intermediary is the subject of a summary sheet drawn up by Compliance, compiling the results of the due diligence and including a rating. The rating is carried out only after the due diligence has been performed and the file constituted. The assessment is renewed annually and makes it possible to verify that the intermediary continues to satisfy its best-execution obligation; it relies in particular on the execution quality reports provided by the intermediaries and on sample-based controls carried out by Finary's permanent control function.
Once the entity has been selected, an agreement is signed between the parties. Finary is classified therein by the intermediary in the appropriate category with regard to the applicable regulations, and the entity contractually undertakes to comply with best-execution obligations. Finary accepts no remuneration, rebate or benefit in consideration for the routing of orders to an intermediary or a platform.
Finary constantly takes sufficient measures to select intermediaries enabling the best possible execution of the orders transmitted on behalf of its clients; this arrangement constitutes a best-efforts obligation and not an obligation of result, the execution itself falling to the selected intermediaries. Finary may not be held liable for any failure to comply with the Policy resulting from a case of force majeure, market disruptions, the failure of a third party involved in the processing of orders, or the consequences of the transmission of specific client instructions.
As a matter of principle, orders are processed in the order of their receipt by Finary and of their transmission to the execution partners.
Aggregated orders: by way of derogation, orders may be aggregated for transmission if the aggregation has no negative effect on the price offered to clients. Aggregation is never applied to an immediate purchase; it is reserved for periodic investments scheduled on a fixed date.
Specific instructions: Finary transmits the client's instruction (venue, price or other characteristic) to the extent possible; the Policy may then not apply in full.
Other specific cases: directed orders (DMA); orders of unusual size (transmission adapted to minimise market impact in the client's interest); failure of a platform or an intermediary; exceptional market conditions; a degraded mode enabling the client to cancel their open orders.
This list is reviewed at least each year in order to examine the opportunities to access entities offering better execution conditions.
