Information concerning Crypto-asset Services

Valid from 25.02.2026

1. General description of LHV’s crypto services

   AS LHV Pank (LHV) offers its customers the service of holding and managing crypto assets and receiving and transmitting orders. The customer can hold, buy, and sell crypto assets brokered by LHV in LHV’s Mobile and Internet Bank. Orders can be submitted 24/7 and LHV forwards them to foreign partners for execution at the time the crypto markets are open (generally around the clock).

   LHV does not execute customer orders on its own, nor does it operate the crypto asset trading platform. LHV accepts the customer’s order and forwards it to a third party for execution. LHV does not provide any advice on crypto assets or any crypto asset portfolio management services. All investment decisions are made by the customer. Before trading, make sure you are familiar with the information materials on crypto assets, and understand the nature and risks of crypto assets.

2. Regulation and licensing

   Licensing and supervision
   LHV holds a credit institution licence issued on 06/05/2009 by the Management Board of Finantsinspektsioon with decision No. 4.1-1/37 (Sakala 4, 15030 Tallinn; tel. 668 0500; e-mail info@fi.ee; web www.fi.ee). Finantsinspektsioon conducts supervision over the activities of LHV Bank and the protection of customer assets.

   MiCA and applicable legislation
   LHV provides crypto asset services in accordance with Regulation (EU) 2023/1114 of the European Parliament and of the Council (MiCA) and Estonian legislation. Its customer relations are governed by the laws of the Republic of Estonia.

   Type of assets provided
   The crypto assets currently offered by LHV are classified as ‘other crypto assets’ (not e-money tokens or asset-based tokens) under the MiCA.

   Asset Information
   LHV publishes a brief description of each crypto asset being brokered on the respective product page and encourages customers to familiarise themselves with the information materials available (white papers, project websites). A white paper is required under MiCA when a crypto asset is publicly offered or is requested to be admitted to trading. LHV is not an issuer and does not operate the trading platform. LHV refers to the white paper of the issuer/project when possible.

   Sustainability indicators
   LHV publishes the required sustainability indicators (e.g. climate and environmental impacts of the consensus mechanism) for all the crypto assets that LHV provides on its website.

3. Risks involved in investing in crypto assets

   Crypto assets are high risk assets and are not suitable for everybody. Below, we will highlight the main risks associated with crypto assets:

   Volatility (price fluctuations)
   Crypto asset prices can fluctuate significantly in a very short period of time – both up and down. The value may experience double-digit or greater percentage changes in a single day. You can lose a large part or even all of the money invested: the preservation or growth of the value of crypto assets is not guaranteed. The price often depends on the confidence and demand of market participants; there may be a lack of intrinsic value or collateral, therefore, in the event of a loss of interest from market participants or due to negative news, the value of an asset can quickly fall even close to zero.

   Market and liquidity risk
   The crypto market is younger and less regulated than traditional financial markets. The market situation can deteriorate rapidly: a general drop in price or a decrease in trading volumes can make it difficult to sell an asset at the desired time or price. In the absence of liquidity, it may not be possible to find a counterparty quickly or the asset may have to be sold at a significantly lower price. Occasionally, exchange platforms (including the exchanges used by the operators used by LHV) may temporarily suspend trading or limit withdrawals, so it may not be possible to buy or sell crypto assets for a certain period of time. Since the crypto market is relatively dynamic and in a constant development, investors should be prepared to accept some measure of unpredictability. Crypto assets with smaller market capitalisations have an extremely high risk of becoming illiquid. In summary, it can be said that investing in crypto assets is highly risky and the behaviour of the market is unpredictable.

   Risks regarding cybersecurity
   Holding and trading crypto assets involves significant cybersecurity risks. Platforms, wallets, and exchange platforms are threatened by hacker attacks, data fraud, and other cyber security incidents. LHV implements strict information security measures and its partners use higher level protection, but no system is 100% secure. Be on the lookout for scams (phishing, promises of ‘guaranteed returns’, social media groups providing recommendations on how to place money in crypto assets, influencer recommendations, etc.). Keep the passwords and authentication tools in a safe place, use only the official LHV channels and ensure regular security updates on your devices. Large-scale cyber incidents can result in service interruptions or financial damage.

   Legal and regulatory risks
   The legal framework is still evolving and may change. The changes may affect your ability to use the crypto asset in the future or impact its value (e.g. prohibitions, taxes, reporting obligations). Some crypto assets may be classified as an instrument in the future, which will entail additional restrictions and obligations. Crypto assets are not covered by the Guarantee Fund’s deposit protection or other similar state guarantees. Although LHV operates under Estonian and European Union legislation, and holds a credit institution license, consumer protection in crypto transactions is limited. If necessary, we recommend that you consult, among other things, a tax advisor or lawyer, and follow the regulator’s (e.g. Finantsinspektsioon’s) instructions.

   Product-specific and technological risks
   Each crypto asset is unique, and the risks depend on the nature of the project. For example, developers or the community may terminate a project or make unexpected changes. Technology-related risks (such as smart contract or protocol errors) can lead to hacking and asset theft. A fork in the network can generate new tokens or change the rules – LHV follows its policy in such situations to protect the interests of the customer (as a rule, the customer has the right to a proportional participation in new tokens in accordance with the MiCA). LHV or its intermediaries (including managers) may not be able to convey all the events to the customer. Information about a particular crypto asset can be limited or misleading; it may not always be clear what the token is designed for, what provides value, or what are the prospects for success. Crypto assets have no guaranteed return – the possibility of profit always goes hand in hand with the risk of a loss.

   General warning
   Crypto assets are high-risk instruments. Before making a transaction, you should weigh its financial, legal, and tax-related implications. Invest only the money that you are willing to lose. Past performance does not guarantee future returns. If in doubt, ask for independent advice or refrain from investing.

4. Suitability / relevance assessment

   MiCA does not require a suitability or relevance assessment for the services LHV provides (holding and managing crypto assets and receiving and transmitting orders). The customer suitability assessment applies to the crypto asset advisory and crypto asset portfolio management service, which is not provided by LHV.

   Before the first transaction, we may ask you to complete a short risk awareness questionnaire to help you consider:

   • the volatility and risks of crypto assets;
   • the market structure and trading mechanisms;
   • the risks of ensuring the holding of the assets, and their recovery.

   If the answers indicate that you do not have sufficient knowledge and experience, we will warn you clearly. However, you decide whether to continue.

5. Prices, costs, and fees

   Transaction fee
   A fee is applied to a transaction for the purchase and sale of a crypto asset as a percentage of the transaction amount. This fee is always found in the Price List and is also displayed in the transaction preview. It is a one-time fee – it is charged at the time of the transaction, either added to the purchase amount or deducted from the sale. The transaction fee is calculated in euros and reserved from your account during the transaction.

   Holding
   Holding crypto assets at LHV is free – there are no separate management fees. Opening and closing an account is also free of charge. The only fee is a 0.5% transaction fee; there are no permanent or recurring fees.

   Transparency
   When confirming the transaction, we will always display both the price quote for the crypto asset and the service fee on a separate line.

   Currency and limits

   • Transactions are made in euros; sales revenue is credited to your account in euros.
   • Minimum amounts: purchase EUR 20, sale EUR 10.
   • Maximum transaction amount: EUR 100,000 per transaction.
   • LHV may impose additional limits on the number or volume of transactions due to security or regulatory restrictions; we will notify you prior to the transaction.

   Settlement in money
   To purchase crypto assets, your LHV account must have a sufficient balance in euros. In the case of a purchase, the amount together with the service fee will be debited immediately; in the event of a sale, your account will be credited with the euros received from the sale, from which the service fee has been deducted.

   The transfer of euros to the account for the purchase and the withdrawal of the euros received from the sale takes place in the form of standard bank payments – transfers within LHV are free of charge, payments to other banks are based on LHV’s price list.

   Price list
   LHV’s price list is publicly available and includes up-to-date information on crypto transaction fees. In accordance with legislation, LHV notifies its customers in advance about changes to the price list.

6. Handling and execution of Crypto-asset orders

   When a customer submits a crypto asset order at LHV, it is immediately transmitted to the respective platform (manager) for execution. There is no manual intervention or internal trading at LHV. LHV does not consolidate customer orders or wait for a ‘better price’. Each order is transmitted correctly and without delay.

   Referral benefits
   LHV does not receive compensation for directing orders to a specific platform, and information on unfulfilled customer orders is not misused.

   Types of orders
   Our customers can make market and limit price orders. A market price order will be executed against the liquidity available on the platform at the best possible price at the moment; a limit price order will be executed at the price you specify or at a better price, depending on the liquidity and time advantage of the platform. Unexecuted limit price orders can be cancelled. In the case of limit price orders, the customer prioritises price over immediate execution of the order and it may remain unsettled if the price does not reach the specified level. In the case of market price orders, the customer must take into account that for low-liquidity crypto assets, their order may negatively affect their execution price.

   Rules for the ‘best execution’ of orders
   Since LHV only transmits orders and does not carry them out itself, LHV is not bound by the obligation to develop a best settlement procedure; however, it monitors its transmission process and its partners to ensure reliability and quality of service. The price is formed and the quality of the settlement determined based on the rules of the partner’s platform. In some transactions, LHV’s partners may be counterparties to the transaction themselves. LHV regularly assesses whether the partners meet the established criteria and adhere to the best execution rules.

   Partners used by LHV

   • Bitstamp Europe S.A
   • Coinbase Luxembourg, S.A.
   • Coinbase Ireland Limited.

7. Conflicts of interests

   In providing crypto services, LHV shall act honestly, fairly, and professionally in accordance with the best interests of its customers. However, situations may arise where the interests of LHV conflict with the interests of customers or where the interests of different customers conflict with each other. This section describes the main potential conflicts of interest and how they may affect the customer.

   Conflicts of interest related to the holding and management of crypto assets

   • LHV may hold customers’ assets in collective wallets (omnibus wallets) or through third parties or custodians associated with LHV, which may bring economic or operational benefits to LHV.
   • In the event of forks, airdrops, protocol changes or similar events, LHV may decide at its own discretion whether and how to support, transfer to the customer’s account, sell or store the resulting assets; this may create financial advantages for LHV.

   Conflicts of interest in receiving and transmitting orders

   • LHV employees may have personal crypto asset positions that may generate incentives that are not in line with the interests of the customers.
   • LHV as the receiver and transmitter of crypto asset orders on behalf of the customer, does not receive any fee, discount or non-monetary reward for the referral of orders received from its customers to a specific crypto asset trading platform or other crypto service provider.

   Common conflicts of interests

   • LHV may use the transaction history or information about the customer’s crypto assets to develop products, pricing strategies or business partnerships that benefit LHV.
   • Customers may have conflicting interests regarding the timing, pricing or handling of the orders, and LHV’s decisions may sometimes favour some customers over others.
   • LHV’s management or employees may have financial interests in third parties (e.g. token issuers, validators, service providers) related to the crypto assets handled by LHV.
   • LHV may provide services to the same third parties whose services LHV is using in the provision of crypto services.

   Marketing vs. education
   As a reliable bank, LHV’s marketing and educational materials (seminars, articles) have a great influence. The conflict of interest lies in the fact that LHV has a commercial interest in increasing trading volumes and generating higher profits. This may create an incentive to produce marketing content that, while factually correct, overemphasises the opportunities for crypto trading and does not give equivalent attention to its extreme risks. The line between educational and mercantile content may blur.

   Operational and technological conflicts of interest
   These conflicts arise from the technical implementation of the service.

   System latency and price volatility (slippage). LHV’s system acts as an intermediary. There is a delay between clicking the ‘Buy’ button in the LHV app and internet bank and the actual execution of the order on the partner platform (Coinbase/Bitstamp). In a volatile market, the final execution price may differ from the price displayed to the customer (slippage). Conflict of interests: LHV may be interested in reducing investments to fast, low-latency solutions to save costs. It is directly contrary to the customer’s interest for the order to be fulfilled as soon as possible at the price expected by the customer.

   Handling system outages or errors. If the LHV platform or the connection with a partner is interrupted during a sharp market downturn, customers will not be able to sell their positions. Conflict of interests: It is in LHV’s interest to limit its financial liability for the losses incurred by customers during the interruption. This is contrary to the customer’s expectation that the platform will be available and that losses resulting from technical failures will be compensated. Another point of conflict is also what constitutes an error subject to compensation.

   Management of conflicts of interest
   To manage these conflicts, LHV implements policies and procedures aimed at:

   • identifying and documenting conflicts of interest;
   • preventing or limiting their impact where possible;
   • implementing the division of labour and information barriers;
   • ensuring transparent pricing and best execution;
   • ensuring equal treatment of all customers; and
   • revealing conflicts that cannot be completely avoided.

   Confirmation
   By using LHV’s services, you confirm that:

   • you may encounter conflicts of interest described above;
   • it may not be possible to completely eliminate all conflicts; and
   • if conflicts cannot be avoided, LHV will disclose them and we will act in accordance with the applicable legislation and our internal policies.

8. Settlement of transactions

   If an external partner of LHV settles a customer’s order, in the case of a purchase, crypto assets and in the case of a sale, euros will be reflected in the customer’s account. Settlement is usually almost instantaneous in LHV’s external partner systems. For purchases, euros are debited at the time of the transaction, and for sales, euros are credited after the settlement.

9. Summary of customer’s crypto asset holding policy

   Legal separation and protection
   LHV keeps the customer’s crypto assets strictly separate from the bank’s own assets and other customers’ assets. The customer’s crypto assets are not included in LHV’s balance sheet or bankruptcy assets. In the event of the possible insolvency of LHV, they cannot be used to satisfy the claims of LHV’s creditors.

   Restriction on the use of customer assets
   LHV does not use the customer’s crypto assets for its own account or for other purposes – the customer’s assets are intact and held solely in the customer’s interest.

   Managers and infrastructure
   To hold the customer’s assets, we use carefully selected third party professional managers who have the respective license to operate in the European Economic Area. The crypto assets are held in a special account (omnibus account) opened in the name of LHV with partners such as Bitstamp Europe S.A. and Coinbase Luxembourg S.A. The partners shall implement institutional-level security measures (e.g. multi-signature, cold storage, strict access control) and have insurance protections that help reduce damage from loss of assets due to fraud, cyber-attacks or negligence. The bank regularly evaluates its managers.

   Reporting
   LHV’s internal account system accurately reflects the positions of each customer at any given time and this data is checked regularly (including daily comparison with the manager’s balances). The customer can see their current balances in the Internet and Mobile Bank, and also check the status as at any prior date. LHV deems that MiCA’s requirement to provide an extract from the customer’s assets at least once a quarter has been met by making the statement available in the Internet and/or Mobile Bank.

   Liability in case of loss of customer’s crypto assets
   LHV shall be liable under MiCA for the loss of the customer’s crypto assets or the means of access to them to the extent that the loss is attributable to LHV. Liability is limited to the market value of the assets at the time of the loss.

   Transfer of crypto assets
   It is possible to buy and sell crypto assets as part of the LHV crypto asset service, but the transfer of crypto assets from LHV to an external wallet (and vice versa) is not allowed. The customer’s crypto assets remain in the environment managed by LHV until they are sold, after which the customer receives the corresponding amount in euros.

   Additional checks
   LHV complies with all customer asset protection requirements arising from the MiCA and implements additional controls specific to the credit institution (strong capital base, internal and external audits, risk management). The combination of these measures – legal separation of assets, technical security measures, trusted managers and regular reporting – helps to ensure an effective level of protection.

10. Complaints and disputes

    Filing a complaint is free of charge. LHV’s complaints handling procedure and standard form are published on the website. The customer can contact the Consumer Disputes Committee and Finantsinspektsioon.

11. Investor protection and guarantees

    Crypto assets are not protected by the deposit guarantee scheme of the Estonian Guarantee Fund or the investor compensation scheme that applies to certain securities services.

12. Taxation

    LHV shall issue a report on the customer’s crypto transactions, which helps with tax reporting, but tax accounting and declaration are the responsibility of the customer.