Governance & Compliance

Clarity
over claim.

Our regulatory position, anti-financial-crime framework, suitability process and risk disclosures, set out plainly. This page is updated as circumstances change.

Last updated 2026
Version 1.0
Entity Stratos Private Vault LLC · Abu Dhabi, UAE
01

Corporate Identity

Stratos Private Vault LLC ("Stratos Private Vault", "we" or "SPV") is a private limited liability company incorporated in the Emirate of Abu Dhabi, United Arab Emirates, and registered with the Abu Dhabi Department of Economic Development (ADDED). SPV operates within the federal commercial framework and the regulatory perimeter of Abu Dhabi Global Market (ADGM) as applicable to its activities.

SPV operates as a private holding and advisory entity engaging exclusively with professional, institutional and qualified counterparties.

02

Regulatory Position

Stratos Private Vault LLC is not currently licensed by:

the Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM);

the Central Bank of the United Arab Emirates (CBUAE), in its capacity as federal prudential and monetary authority;

the Securities and Commodities Authority (SCA); or

the Abu Dhabi Department of Economic Development (ADDED), in relation to commercial licensing.

SPV does not perform — and does not hold itself out as performing — any of the regulated virtual asset activities defined under FSRA's Rulebook and ADGM's Financial Services and Markets Regulations (FSMR), including but not limited to: Advisory Services, Broker-Dealer Services, Custody Services, Exchange Services, Lending and Borrowing Services, VA Management and Investment Services, and VA Transfer and Settlement Services.

Where any such activity is appropriate to a counterparty's strategy, SPV refers that counterparty to a third-party service provider licensed by the relevant authority in the relevant jurisdiction. Any such activity is contracted directly between the counterparty and that licensed provider; SPV is not a party to the underlying regulated transaction.

This page does not constitute, and should not be interpreted as, a representation that Stratos Private Vault LLC is approved, endorsed or supervised by any regulator. The FSRA/ADGM Register is the authoritative source for the licensed status of any entity in Abu Dhabi Global Market and can be consulted at adgm.com/fsra/registers-and-lists.

03

KYC, AML, CTF & Sanctions

Stratos Private Vault operates a written compliance framework reflecting applicable UAE federal anti-money-laundering and counter-terrorism-financing requirements, the standards of the Financial Action Task Force (FATF), and the Targeted Financial Sanctions regime administered by the UAE Executive Office for Control and Non-Proliferation.

3.1 — Counterparty Due Diligence

Before engagement, each counterparty is subject to a documented due-diligence process appropriate to its risk profile, including:

Identity Verification

Verified identification of the counterparty, beneficial owners and authorised signatories.

Source of Wealth

Documentary evidence of source of wealth and, where relevant, source of funds.

PEP Screening

Politically exposed person screening, including against UAE federal lists and recognised international lists.

Sanctions Screening

Screening against the UAE Local Terrorist List, the UN Consolidated Sanctions List, and other applicable lists.

Adverse-Media Review

Systematic review of negative news and adverse media concerning the counterparty and its principals.

Ongoing Monitoring

Continuous transaction monitoring and periodic refresh of counterparty due diligence records.

3.2 — Enhanced Due Diligence

Enhanced due diligence is applied where indicators of higher risk exist, including non-resident counterparties, complex ownership structures, and exposure to higher-risk jurisdictions as identified by FATF or the UAE authorities.

3.3 — Sanctioned Jurisdictions

Stratos Private Vault does not engage with counterparties resident in, organised under the laws of, or controlled from, jurisdictions subject to comprehensive United Nations or UAE financial sanctions. This list is subject to change at any time.

3.4 — Suspicious-Activity Reporting

Where required by law, SPV reports suspicious transactions or activities to the competent UAE financial intelligence authorities. Counterparties acknowledge that such reporting obligations override confidentiality undertakings.

04

Suitability & Partner Classification

Engagement is restricted to counterparties who qualify as professional, institutional or otherwise sophisticated investors under the laws of their jurisdiction of residence. Before any engagement progresses beyond initial enquiry, the counterparty must:

i

confirm in writing its classification as a professional, institutional or qualified investor under the applicable regime;

ii

complete a suitability questionnaire describing its investment objectives, time horizon, capacity to absorb loss and risk tolerance;

iii

acknowledge that all information shared by SPV is general information and does not amount to personal investment advice; and

iv

acknowledge that engaging any regulated third-party service provider is the counterparty's own decision, made on the basis of independent legal and tax advice.

05

Risk Disclosure

Counterparties acknowledge and accept the following non-exhaustive risks:

Capital Risk

The value of investments and exposures can fluctuate materially. Counterparties may receive back less than the amount originally allocated.

No Performance Guarantee

No information published by SPV — including any historical figure or scenario — should be read as a forecast or guarantee of future results. Past performance is not indicative of future results.

Liquidity Risk

Certain exposures may be illiquid or subject to lock-up periods. Realisation may not be possible at short notice and may incur material costs.

Virtual Asset Risk

Where virtual assets are involved, additional risks apply, including operational, custodial, cybersecurity, technology, market manipulation, network and protocol risk. Such assets are highly volatile and may fall to zero.

Counterparty Risk

Third-party service providers are independently licensed and contracted, and carry their own credit, operational and regulatory risk.

Regulatory Risk

The legal and regulatory framework applicable to virtual assets is evolving; future changes may affect the availability or terms of services accessed through licensed providers.

Tax Risk

The tax treatment of any arrangement depends on the counterparty's individual circumstances and the jurisdictions involved, and may change. Independent tax advice is essential.

Counterparties must form their own independent judgement, taking advice from independent legal, tax and investment advisers in the relevant jurisdictions before entering into any arrangement.

06

Conflicts of Interest

SPV operates a written conflicts-of-interest policy. Where SPV maintains a material relationship with a third-party provider to whom a counterparty may be introduced, the existence of that relationship is disclosed in writing to the counterparty.

SPV does not receive undisclosed commissions or rebates that would compromise the independence of an introduction.

07

Marketing & Solicitation

Stratos Private Vault does not engage in mass marketing or general solicitation of investment business. The information presented on this website is general in nature, applies to no specific person and is not, and must not be construed as, an offer to sell or a solicitation to buy any security, financial instrument or virtual asset.

No information on this site is directed at, or intended for, retail investors. Where applicable, all communications with UAE-resident counterparties relating to virtual asset activities are conducted by or in conjunction with VASPs licensed by FSRA/ADGM.

08

Cross-Border Restrictions

This website may not be accessed from, and the services described may not be offered in, jurisdictions in which such access or offering would be unlawful or would subject Stratos Private Vault LLC to any registration or licensing requirement.

Without limitation, no part of this site is intended for distribution to, or use by, any person resident or located in a jurisdiction where such distribution or use would be contrary to law. Persons accessing this site are responsible for compliance with all applicable laws.

09

Tax

Nothing on this site constitutes tax advice. The tax treatment of an investment, holding structure or service depends on the individual circumstances of the counterparty and the jurisdictions involved and is subject to change.

Counterparties must obtain independent tax advice from a qualified adviser in the relevant jurisdiction. References to UAE tax treatment are descriptive of the federal framework and do not constitute advice on its application to any specific person.

10

Complaints

Complaints should be sent in writing to compliance@stratosprivatevault.com. Complaints are acknowledged in writing and investigated by a person not involved in the matter complained of.

Where a complaint concerns a third-party provider, SPV will assist the counterparty in escalating it to the relevant provider and, where appropriate, to the relevant regulator.

11

Updates & Regulatory References

This compliance statement is reviewed periodically and updated as circumstances change. The version number and last-updated date appear at the top of this page.

For the regulatory framework applicable to virtual assets in the Emirate of Abu Dhabi, refer to:

This compliance statement provides a general description of the framework operated by Stratos Private Vault LLC. It is not a substitute for the documented internal policies that govern the firm and is not legal advice. Counterparties should rely on the specific terms of their written engagement with the firm and on independent legal advice.

By Invitation Only

Request access to Stratos Private Vault

Admission is limited and reviewed individually. Submit an enquiry and our team will respond confidentially.

Begin a Confidential Enquiry