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Laser Digital Middle East (LDME) VA Management and Investment Services Disclosure

July 2023

  • Potential Conflicts of Interests: At the date of this disclosure, LDME intends to act as investment manager in respect of one or more funds having as founder shareholder entities within LDME group which may also invest into such funds as investors – specific rights and conditions may be applied to such investments. Furthermore, individuals covering management roles in LDME and/or Laser Digital Group may also hold executive roles within the aforementioned funds and/or be involved in its operations and distribution. Funds managed/to be managed by LDME may appoint as service providers one or more entity forming part Laser Digital Group (including Nomura Group) and avail of such services performed by these counterparties (including for the purposes of trade execution) – the terms of such arrangements will be either negotiated at arm’s length or otherwise entered into at conditions which are deemed to be more favorable for clients then those otherwise available in the open market. A detailed disclosure of such potential conflict of interests is detailed within the offering documentation of the aforementioned funds as well as in the contractual documentation entered into with the aforementioned funds. Control functions within the funds and within LDME are independent from the business units involved in the provision of regulated activities. While asset valuation is performed by a separate entity from LDME and from individuals other than those involved in the performance of portfolio management activities, the external valuer is an entity forming part of Laser Digital Group. Such risks are mitigate by the establishment of a valuation framework, disclosed in the offering documentation of the fund, the appointment of an independent auditor as well as the appointment of an independent fund administrator entrusted with the calculation of the fund(s) NAV. Moreover, LDME has in place a conflict of interest policy detailing, amongst others, how it intends to handle potential or actual conflict of interests. Further information on the conflict of interest management approach adopted by LDME are available upon written demand.
  • Policies:
    • Complaints: Our complaints handling policy can be found on our website: Complaints Handling Policy
    • Internal whistleblowing policy: you can write to for a copy of our whistleblowing policy.
  • Withdrawal of assets: LDME intends to face as clients, when performing VA management services,funds and similar collective investment vehicles. VA invested into by LDME on behalf of such funds are held in custody by 3rd party Regulated custodian (Komainu or similar) for the handling of digital assets in a fully segregated fashion and, for fiat, regulated credit institutions. No co-mingling of LDME own assets and fund’s assets will take place. In this respect, underlying investors in each fund may place redemptions in accordance with the redemption policies of the aforementioned funds which are duly disclosed in the offering documentation of such funds. Redemption gates, lock-ups and similar arrangements are put in place according to market standards in order to avoid prejudice to the funds and/or disorderly liquidation of assets which may be ultimately prejudicial to investors in instances of extreme volatility and these may vary from fund to fund depending on the type of the strategy. Redemptions may range ranging daily, weekly to monthly redemptions.
  • Use of virtual assets: LDME intends to manage virtual assets in accordance with the provisions set out in the offering documentation of each fund under management in view of each specific investment strategies and objective featuring such funds. Activities may include the purchase, sale, borrowing, lending or otherwise disposal, including by means of pledging/rehypothecating such assets. Disclosure to this end are included in the relevant agreement with the fund(s) as well as in the offering documentation made available to investors. Virtual assets forming part of the fund’s portfolio will not be used for LDME own purposes nor co-mingled with LDME own assets.
  • Protection of counterparty risks and protection of clients assets: LDME shall adopt its best efforts to manage counterparty risks in adherence to industry standards. Among the key arrangements envisaged to this end, LDME shall select, in agreement with the fund, providers only after having performed a solid due diligence entailing analysis on the regulatory status of the parties involved, well-defined and structured internal approvals processes as well as adopting strong risk management practices, including when trading on crypto exchanges/ routing to regulated execution desks. LDME intends to appoint only entities ensuring asset segregation or equivalent safeguards for long-term custody purposes. LDME itself does not and shall not keep custody of virtual assets. However, counterparty risks may be faced and these risks are extensively described in the offering documentation of each fund.
  • Risks: Virtual Assets purchased by LDME on behalf of its fund(s) under management may be at risk. These risks range from market, operational (including legal, regulatory and reputational), financial, liquidity, (cyber)security, ICT, and currency risks. The likelihood of such risks may be higher for funds investing in virtual assets than for traditional assets due to the current development of the market as well as due to the inner features of such asset class. Investors in the fund may lose part or all of the capital invested. An extensive description of the key risks which the fund and/or its end investors may be exposed to is provided in full transparency within the offering documentation of each product. .
  • Order Execution: LDME adopts an order execution policy which may be made available to clients on demand. As a general disclosure, orders may be executed with one or more counterparties, including, where applicable, through DeFI arrangements. Such counterparties may also involve other entities forming part of Laser Digital Group, to the extent that such transactions are entered into at
  • Liquidity Risks: LDME and/or the funds managed may be subject to different liquidity risks depending on the strategy pursued and the relevant features of such funds (e.g. redemption policies and dealing frequency). Liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing a fund from selling out of these illiquid investments at an advantageous price, or at all. Thin markets can also amplify volatility. Any markets for these investments can be expected to involve wider price spreads and more sensitivity to buying and selling pressures than is found in more active markets. Virtual Assets may be illiquid investments that are not easily and readily convertible into fiat currencies, and some Virtual Asset markets may be thinner than others. Accordingly, any purchase of Virtual Assets by a fund is likely to increase the proportion of the fund’s portfolio that is comprised of illiquid investments. Though the fund will manage liquidity risks across all investments on an ongoing basis, greater exposure to Digital Assets increases the possibility that, as at any redemption day, the fund might lack sufficient liquid assets to fund the payment of redemption proceeds to any redeeming shareholders. Additionally, the fund may be forced to dispose of other more liquid assets in order to fund redemptions, meaning that remaining shareholders have increased exposure to the digital asset investments and the risks associated therewith. or otherwise entered into at conditions which are deemed to be more favorable for clients then those arm’s length otherwise available in the open market. Execution may occur involving LDME trading/execution desks and/or automated algorithms developed for such purposes and operated by LDME and/or group entities. Specific provision concerning the discretion of executing orders and related risks are provided in the offering documentation of each fund under management.
  • Other disclosure: No senior management has been involved in any conviction/prosecution to be disclosed in accordance with VARA rules. LDME has in place, at group level, multiple arrangements to deal with potential risks of market offences, ranging from personal account dealing framework, trade surveillance arrangements, communication monitoring and recording, as well as similar measures entailing internal and external audit.


Laser Digital Middle East VA Management and Investment Services Disclosure


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

By proceeding and accessing to this Site, you confirm your access is not the result of or subsequent to any advertisement, article, notice or other communication published in any newspaper, magazine or similar media or broadcast over television or radio, or presented at any seminar or meeting accessible to the public, or any solicitation of a subscription by a person not previously known to you in connection with investments generally. Furthermore, by proceeding and accessing to this Site, you hereby confirm the following representation and warranties are accurate and correct:

  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.
  4. The decision to avail of your services/products is/will be based solely on my own due diligence and review of information and materials received/to be received at my request.
  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.

Intellectual Property

All right, title, and interest in the Site is the exclusive property of Laser Digital Holdings AG except as otherwise stated.

You may not copy, reproduce, recompile, decompile, disassemble, reverse engineer, distribute, publish, display, perform, modify, upload, create derivative works from, transmit, or in any way exploit any part of the Site.

All trademarks, service marks, trade names, brand features, and logos displayed on the Site are proprietary to Laser Digital, its group members, and/or respective owners, except as noted. Nothing on the Site grants any license or right to use any trademark without written permission from Laser Digital or the respective owner. Unauthorized use may violate intellectual property laws, privacy, publicity, and communication laws.

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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