Laser Digital receives Financial Services Permission from ADGM’s Financial Services Regulatory Authority to provide services in both traditional and digital assets

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1. Introduction

  1. 1  Laser Digital Middle East FZE (“Laser Digital” or the “Firm”) is a Virtual Assets Services Provider (“VASP”) incorporated in the Emirate of Dubai ( the “Emirate”) and operates under the regulations of the Virtual Assets Regulatory Authority (“VARA”).

1. 2 The Firm provides Broker-Dealer and VA Management and Investment Services to Qualified and Institutional Investors. The Firm does not deal with Retail Investors.

1.3  WhilehandlingComplaints,theFirmwillconsideritsobligationsunderthePersonalData Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data.

2. Interpretation of Terms

2.1 Unless the context requires otherwise, all terms included in the Complaints Handling Procedure (“Procedure”) will have the meaning given to them herein. Where the context requires, (a) words importing the singular shall include the plural and vice versa, and (b) words importing the masculine shall include the feminine and vice versa.

3. Complaint Handling Procedure

3.1  The Procedure sets out the internal complaint resolution process and procedures the Firm has in place, maintains, and follows to ensure all complaints are investigated and resolved appropriately.

3.2  The Firm’s complaints handling procedures represent its client-focused approach and commitment to be fair and transparent and are designed to ensure that any significant expression of dissatisfaction, whether spoken or written, and whether justified or not, sent from a client to the Firm is investigated and resolved fairly, consistently, and promptly.

3.3  All complaints must be in writing (by submitting a completed complaint form) and addressed to the Compliance Officer and will be recorded on a complaint register. The complaint must outline the expression of dissatisfaction relating to the provision of services. All complaints received will be assigned a unique complaint reference number.

3.4  Complaints will be handled independently by a person unconnected with a complaint and will have sufficient authority to resolve it or access to someone with sufficient authority (the default handler will be the Compliance Officer). Employees of the Firm are unable to privately negotiate the settlement of any complaint.

3.5  The Firm will do its best to resolve complaints internally in a quick and effective manner.

4. Definition of a Complaint

     4.1  A complaint is an expression of dissatisfaction addressed to the Firm by a Client (a natural or legal person) relating to the provision of Virtual Asset activities under the VARA regulations.

4.2  A complainant can be a natural or legal person who is presumed to be eligible to have a complaint considered by the Firm and may have already lodged a complaint.

4.3  All complaints submitted to the Firm must include the following:

i.  The Client’s forename and surname.

ii. The Client’s account number.

iii. The date and time when the issue arose.

iv. The date that the issue arose and a description of the issue, and

v. An accurate description of the issue and any supporting evidence.

4.4  Complaints must be submitted in English and must not include offensive language directed either to the Firm or any of its employees.

5. Complaints Procedure

5.1  All complaints in respect of the services offered by Laser Digital must be in writing and must be addressed to the Compliance Officer of Laser Digital by way of:

i. The Complaint Form, which will be shared upon request and should be emailed to; or

ii. Laser Digital website, under the Contact Us methods available online; or
iii. By Post, address the letter “For the Attention of The Compliance Officer” to the following address: Laser Digital Middle East FZE, Office level 3, Offices 3, One

Central, Dubai, Dubai World Trade Centre, United Arab Emirates

5.2  Complaints will be handled independently by a person unconnected with the complaint and who will have the appropriate authority to resolve it or access to someone with sufficient authority (the default handler will be the Compliance Officer.

5.3  The Firm will not be able to investigate a complaint if the requirements within sections 4.2 and 4.3 have not been fulfilled, and in such instances, we will request the missing and/or additional information from the complainant.

5.4  An employee of the Firm may contact the complainant directly in order to obtain further clarifications and information relating to the complaint. Employees who receive a complaint, either in writing or verbally, must promptly record the complaint by completing the Client Complaint Record (which will generate a unique complaint reference) and forwarding it directly to the Compliance Officer. Any related correspondence must be attached to the Client Complaint Record. In the event a complaint is made verbally, Employees should request the complainant to submit the

complaint in writing via the channels outlined in 5.1. Notwithstanding, the written complaint should not delay Employees from notifying the Compliance Officer.

5.5  All data related to complaints are stored in an internal CRM system. The Compliance Officer has access at each stage to both CRM and all communication between the client and the Firm, and the Compliance Officer will prepare the response. The Compliance Officer should be kept informed of the status of the complaints. Upon receipt of the complaint, the Compliance Officer will record the complaint in the complaints register.

5.6  The Firm will treat each complaint with due care and ensure a fair outcome is reached.

5.7  The Firm will make its best endeavors to resolve all complaints and provide a final response to the client within four [4] weeks, if possible, and no later than eight[8] weeks from the date of receipt of submission.

5.8  Once a complaint has been received, a response will be provided to the client within one [1] week of acknowledgement of safe receipt of the complaint, along with a unique reference number. The following information will be enclosed within the acknowledgement:

     i.  The contact details of any individual(s) or departments responsible for handling the complaint.

ii. Key particulars of the complaints handling procedures and

iii. A statement that a copy of the procedures is available free of charge upon request in accordance with VARA Market Conduct Rulebook – Rule III.A.4.; and considers the subject matter of the complaint.

5.9 Throughout the complaints process, the unique reference number must be quoted on all correspondences with the Firm.

  5.10  A response letter will be sent within four [4] weeks, explaining how the complaint will be resolved or if more time is required to investigate the complaint. If additional time is required to investigate the complaint, and it cannot be resolved within six [6] weeks from the date of receipt of submission, a holding response will be sent, making clear that the matter is still under investigation, and an update with respect to the complaint will be made within six [6] weeks from the date of receipt of submission. An update in respect to the complaint will be made within eight [8] weeks from the date of receipt of submission.

5.11  All complaints will be resolved within eight [8] weeks from the date of receipt of submission.

5.12  Once a conclusion has been reached from the investigation (within the timeframe of 4 weeks, 6 weeks or 8 weeks), the following notification will be provided:

i. The outcome of the investigation, along with the reasons for reaching such a decision, will be provided in writing.

    ii. The Firm will Provide clear terms of redress, if applicable; and

iii. The terms of redress if accepted. (Any terms of redress are only valid for seven

(7) days from the date the terms have been offered).

5.13  Upon conclusion of the investigation, the client must be informed of the resolution in writing as soon as possible and, at the very least within the timeframe, communicated to the client. In coordination with the Compliance Officer and depending on the severance, the relevant individual is responsible for sending responses to the clients.

5.14  The Firm will provide its response no later than eight [8] weels from the submission of the complaint.

5.15  The Complainant reserves the right to take any legal action; such a right remains unaffected by the existence and/or use of any complaint’s procedures referred to above.

6. Complaints involving third-party entity

6.1  If the Firm considers that a third-party entity is entirely or partly responsible for the matter complained of, it may refer the complaint to that entity, in line with the following:

(a)  inform the complainant promptly and in writing that it would like to refer the complaint, either entirely or in part, to the third-party entity and obtain the complainant’s written consent to do so;

(b)  if consent is granted, refer the complaint in writing to the third-party entity concerned;

(c)  inform the complainant promptly, in writing, that the referral has been made together with adequate contact details of the individual at that entity; and

(d)  remain responsible for the resolution of such complaints.

  1. 6.2  If the referral of any complaint to another entity will involve the transfer of Personal Data, the Firm will ensure its compliance with the Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data

7. External Dispute Resolution

  1. 7.1  If the complainant is not satisfied with the Firm’s final response or a final decision (including the offer of any compensation), then the complainant can take other steps which may warrant further action.
  2. 7.2  The complainant may refer the complaint to the VARA. For more information, they can contact the VARA via their website
  1. Other steps a complainant can take include an external dispute resolution scheme, arbitration or the Dubai Courts. Also, note that additional provisions may apply.
  2. When submitting a complaint to either Firm, the VARA or to an external dispute resolution scheme, arbitration or the Dubai Courts, the unique complaint number must be provided to all correspondences; the number can be found on the official acknowledgement and/ or response email/letter.

9.1 A copy of the Firm’s complaints leaflet can be provided free of charge upon request.

9.2  If a complaint is resolved in favour of the Complainant, the Firm will promptly ensure the full and appropriate level of redress is offered without any delay.

10. Principles

10.1.1  All complaints will be treated confidentially.

10.1.2  The Firm will handle each complaint in a timely and fair manner.

10.1.3  The Firm will take all reasonable steps to investigate and respond promptly to any complaints.

10.1.4  The Firm will make its best endeavors to provide the best service to its clients.

11. Record Keeping

11.1.1 The Firm has established, maintains, and updates the complaints register with details of all the complaints received per month for a period of six (8) years. The following information is recorded in the complaints register:

    i. Date of the complaint.

ii. Unique Reference Number.

iii. Identification of the complainant.

iv. Complaint cause.

v. Substance of the complaint.

vi. Actions are taken by the Firm to resolve each complaint.

vii. Settlement date, if applicable, and

viii. Anycommentsthereof.



Laser Digital Middle East Complaints Handling Procedure


This site, (“Site“), and/or any other Laser Digital group websites linked from this Site, contain information produced by and/or for Laser Digital group entities, some of which operate under different regulatory regimes. By using the Site or Laser Digital services or products, you agree to the following terms of use as well as the terms contained in the dedicated section headed Terms of Use below (“Terms of Use“). Please read them carefully and, if you do not agree with part or all of these Terms of Use, you shall not use this Site.

These Terms of Use apply generally to the Site and are subject to any other agreement (including client agreements) between you and any Laser Digital group entities, as well as any specific terms, legal notices, or disclaimers applicable to particular sections of the Site you access.

All references in these Terms of Use to “Laser Digital” refer to Laser Digital Holdings AG and/or any entity controlled, directly or indirectly, by it (each a “Laser Digital Group” member).

The Laser Digital Group may revise these Terms of Use at any time without notice. Any revisions or additions to these Terms of Use shall become effective and binding when you continue to use the Site after such revisions or additions.

Geographical Restrictions

The Site is not directed at any person in any jurisdiction where its publication or availability is prohibited. Those subject to such prohibitions must not access the Site. Further information on specific jurisdictions are set out below.

US: THE INFORMATION ON THE SITE IS NOT INTENDED AS AN OFFER OR SOLICITATION FOR THE PURCHASE OF ANY SECURITY OR FINANCIAL INSTRUMENT, OR TO PROVIDE ANY INVESTMENT SERVICE OR INVESTMENT ADVICE IN THE UNITED STATES. The information on this website is not appropriate for any person (natural, corporate or otherwise) who is a US Person as defined under Regulation S of the United States Securities Act of 1933, as amended (which such definition includes, for the avoidance of doubt, any US resident, corporation, company, partnership or other entity established under the laws of the United States). Accordingly, this information should not be distributed to, used by or relied upon by any US Person. Laser Digital does not offer any services and/or products to US Persons. 

Laser Digital does not represent that any materials on the Site, any investment services available on the Site, or anything else on the Site, are appropriate or permitted by local laws in all jurisdictions and some of the services and/or products referred to herein are or may be subject to restrictions on the basis of, amongst others, your client categorization, residence, domicile, nationality or specific circumstances. Users accessing the Site do so on their own initiative and are responsible for compliance with local laws or regulations. Legal advice should be sought in cases of doubt. Users may not necessarily be able to deal directly with all or any Laser Digital Group members and should only deal with those appropriately licensed or exempt under local laws and regulations. Information or material on the Site may not have been approved, reviewed, or verified by any relevant regulator in any jurisdiction. Accessing to this Site does not render you nor creates a client relationship with Laser Digital. Laser Digital reserves the right to limit access to the Site to any person, geographic region or jurisdiction. By proceeding to access the information, you are deemed to have represented and warranted that the applicable laws and regulations of your relevant jurisdiction allow you to do so.

In particular, this Site (and any product/service described herein) is not directed to, or intended for distribution to or use by, any person or entity who is a citizen or resident of, or located in, any locality, state, country or other jurisdiction where such distribution, publication, availability or use would be contrary to law or regulation or is prohibited without obtaining the necessary licences or authorisations and such licences or authorisations have not been obtained. None of the products/services referred to herein are available for retail investors in any jurisdictions. No key information document will be prepared in respect of any product in accordance with Regulation (EU) No 1286/2014 on key information documents for packaged retail and insurance-based investment products (PRIIPs) (and, in the case of the United Kingdom, such regulation as it forms part of the domestic law of the United Kingdom). Accordingly, no product/service are available to, and no person may advise on, offer or sell any product/service for or to, any retail client (as defined in MiFID 2) in any jurisdiction, including, but not limited to, any EEA Member State, Switzerland, Japan, the UAE or the United Kingdom.

Access at your initiative

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  1. I am a professional investor, market counterparty or equivalent definition as set out under the applicable law in my country of residence/registration and I am eligible, in accordance with the applicable law, to request such information and/or be offered/avail of one or more of the products/services indicated herein
  2. I have approached Laser on my own exclusive initiative and that this approach does not come about as a result of any direct or indirect contact, solicitation, intervention, marketing and/or pre-marketing, arranging, advice, offering or placement efforts nor as result of any form of general solicitation or advertising such as media advertising or public seminars by or on behalf of Laser and its Affiliates.
  3. To the extent I have already received any of the information, documentation above and/or any other communication concerning Laser, these information, documentation, including link to this website and/or communication was sent to the undersigned at and after my request and otherwise only upon my own initiative.
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  5. Shall any of the above become untrue or inaccurate, I will promptly inform you in writing, acknowledging that this may cause Laser to stop or otherwise refrain from providing me with its services/products.

No Offering, Non-Reliance 

No offering: Nothing in this Site amounts to, or should be construed as, an offer, placement, invitation or general solicitation to invest in any product or to buy or sell securities, digital assets, or to engage in any other related or unrelated transactions. This Site was not prepared in compliance with applicable provisions of law designed to promote the independence of financial analysis and is not subject to a prohibition on trading following the distribution of financial research. This Site does not purport to contain all of the information that may be required to evaluate any potential transaction and should not be relied on in connection with any such potential transaction. Any future offers to invest in any product will be subject to the relevant contractual terms and/or offering documentation. 

Non-reliance: The content of this Site is not a recommendation and should not be relied upon as accounting, legal, tax or investment advice. You should consult your tax, legal, accounting or other advisers separately. Neither this Site nor the information contained in it is for publication or distribution, directly or indirectly, in or into any jurisdiction where to do so might constitute a violation of applicable law. None of Nomura, Laser Digital, their group companies or any of their respective directors, officers, employees, partners, shareholders, advisers, agents or affiliates (together the “Sponsor Parties”) make any representation or warranty, express or implied, as to the accuracy or completeness of the information contained in this website, and nothing contained in it shall be relied upon as a promise or representation whether as to past or future performance. To the maximum extent permitted by law, none of the Sponsor Parties shall be liable (including in negligence) for direct, indirect or consequential losses, damages, costs or expenses arising out of or in connection with the use of or reliance on this website. The information contained in this website is unaudited. It is published for the assistance of recipients, but is not to be relied upon as authoritative and is not to be substituted for the exercise of one’s own judgment. 

Digital assets

Digital Assets regulation is still developing across all jurisdictions and governments may in the future restrict the use and exchange of any or all digital assets. Digital Assets are generally not backed nor supported by any government or central bank, are not insured by depositor nor investor guarantees schemes and do not have the same protections countries’ bank deposits may have and are more volatile than traditional currencies and/or other investments. Transacting in Digital Assets carries the risk of market manipulation and cybersecurity failures such as the risk of hacking, theft, programming bugs, and accidental loss. Differing forms of Digital Assets may carry different risks. In certain circumstances it may not be possible to liquidate a digital assets position in a timely manner at a reasonable price. The volatility and unpredictability of the price of digital assets may lead to significant and immediate losses. 

Investment Risks 

An investment in any of the products mentioned herein involves significant risks, including loss of an investor’s entire capital investment. Alternative investment strategies are intended only for investors who understand and accept the risks associated with investments in such products and these products are not suitable for all investors. Investments in Digital Assets are high-risk investments and you should not expect to be protected if something goes wrong. The volatility and unpredictability of the price of Digital Assets may lead to significant and immediate losses. You are invited to do all the necessary research and learn before investing in Digital Assets. In considering any performance data in this website, you should bear in mind that past or targeted performance is not indicative of future results, and there can be no assurance that any of the products would achieve its investment objectives, comparable results or that target returns would be met. Past performance is not a guide to future performance, future returns are not guarantees and a loss of original capital may occur. The price and value of investments referred to in this website may fluctuate. Current performance may be lower or higher than the performance data quoted. Where not relevant or representative, outliers may be excluded. Any future performance is subject to taxation which depends on the personal situation of each investor and which may change in the future.


Please also note that Laser Digital is not obligated to disclose or consider the contents of this Site when advising customers or managing investments on their behalf. Information about how Laser Digital manages conflicts of interest is available upon request. It should be noted that Laser Digital companies may, from time to time, act as investors, market-makers, or advisers for Laser Digital products, including digital assets, and may be represented on the boards or other governing bodies of group entities. Additionally, Laser Digital companies may occasionally act as principal traders in the digital assets mentioned on this Site and may hold these (and other) Laser Digital products. Laser Digital personnel and/or any of its affiliates and/or persons connected to them, may also be exposed to Laser Digital product/services and/or any of the relevant underlying instruments, including Digital Assets. 

The views and opinions expressed by Laser Digital on this Site are subject to, in part or its entirety, change without notice. Laser Digital may periodically provide and publish additional information on this Site, which could differ from and/or even contradict the current content. Please note that Laser Digital is not obligated to inform any user of this Site about these updates and/or changes.

The prices and other information obtained from the data or services offered here may not represent the actual market prices or values at the provided time or when the user intends to buy or sell a specific security, Digital Asset or other instrument.

Forward-Looking Statements

The Site contains statements that may constitute, and from time to time Laser Digital’s management may make, “forward-looking statements”. These forward-looking statements are not historical facts but instead represent only our belief regarding future events, many of which, by their nature, are inherently uncertain and outside our control. Important factors that could cause actual results to differ from those in specific forward looking statements include, without limitation, economic and market conditions, political events and investor sentiments, liquidity of secondary markets, level and volatility of interest rates, currency exchange rates, security valuations, competitive conditions and size, and the number and timing of transactions. Past performance cannot be a guide to, or an indication of, future performance.

Governing Law and Consent to Jurisdiction

Applicable law and jurisdiction: These Terms of Use as well as the access to and use of this Site are exclusively subject to and shall be construed in accordance with Swiss law, with the courts of Zurich having sole jurisdiction on any contractual and/or pre-contractual matter.

Validity: If any provision of these Terms of Use is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavour to give effect to the parties’ intentions as reflected in the provision and the other provisions of the Terms of Use shall remain in full force and effect.


Third party sites or pages that are linked to the Site are for information purposes only and may not have been reviewed or verified by Laser Digital. Laser Digital has no responsibility for the content of the third party sites or pages linked to or from the Site and no affiliation, sponsorship, approval, verification, investigation, monitoring or endorsement of any such sites or pages or of their content is implied. Following links to or from any other sites or pages shall be at your own risk and Laser Digital accepts no responsibility or liability, to the extent permitted by any law, for any losses or penalties whatsoever that may be incurred as a result of any linking to any location on any linked sites or pages.

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Downloading information from the Site obligates you not to copy it or remove/obscure any copyright or notices. You may not offer Site contents for sale or distribute them via any medium, including social media, TV or radio broadcast or on a computer network. The Site and its information, commentary, and materials may not be used to construct a database. You may not store the Site (in whole or part) in databases for access by you or any third party or distribute database sites containing all or part of the Site.

Regulatory Matters

Laser Digital Holdings AG is an unregulated limited company established in the Canton of Zurich, Switzerland, with registration number CHE-439.243.745 and its registered address at c/o Nomura Bank (Schweiz) AG, Kasernenstrasse 1, 8004 Zurich, Switzerland.


Laser Digital UK Ltd, FRN 1000108, is an appointed representative of Strata Global Ltd, which is authorised and regulated by the Financial Conduct Authority, FRN 563834. Strata Global Ltd is registered in England & Wales with company number 07707508 and whose registered office is at 7-11 Moorgate, London EC2R 6AF. The opportunity to avail of any services and/or invest in any product mentioned herein is only available to professional investors in the United Kingdom. All, or most, of the rules made under the FSMA for the protection of retail clients will not apply, and compensation under the United Kingdom Financial Services Compensation Scheme will not be available. In particular, please be informed that neither the Financial Ombudsman Service nor the Financial Services Compensation Scheme apply to transactions in digital assets entered into with Laser Digital, including where those transactions are arranged by or with Laser Digital UK Limited or have any other UK nexus

Laser Digital Middle East FZE (“LDME”). LDME is authorised and regulated by the Dubai Virtual Assets Regulatory Authority (“VARA”) with registered number VL/23/06/001. LDME is registered in Dubai, and only deal with or for Qualified Investors and Institutional Investors as defined by VARA. LDME registered office is located at One Central, Office 3, Level 53, Unit 512345, Dubai, UAE. Additional information on LDME and the relevant regulatory disclosures may be found at



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