Pricing policy

Purpose

System Pay Services (Malta) Limited, trading as BVNK (“BVNK”, “we” or “us”) is a private limited liability company incorporated in Malta, with company registration number C66961 and registered address at Ruby Workspaces Office 3, Pendergardens, Triq Sant’Andrija, San Giljan STJ9023, Malta.

BVNK is authorised by the Malta Financial Services Authority (“MFSA”) as a crypto-asset service provider (“CASP”) under the Markets in Crypto-Assets Act (Chapter 647 of the Laws of Malta), in accordance with Article 3(15) of Regulation (EU) 2023/1114 (“MiCA”).

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Our commitment to transparency

BVNK is committed to ensuring full transparency regarding our pricing, costs, and fees. We believe in providing clear, fair, and accessible information to all our active and prospective clients. This document outlines the fees associated with our crypto-asset services and forms part of BVNK’s services agreement (the “Client Agreement”). In the case of any conflict between the fees pre-agreed between you and BVNK and this disclosure, the specific agreement between you and BVNK will apply.

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Scope of services

This disclosure relates to the following crypto-asset services offered by BVNK:

• The custody and administration of your crypto-assets.
• The exchange of crypto-assets for fiat funds (like EUR) or other crypto-assets
• The transfer of crypto-assets on your behalf, including both the sending and receiving of crypto-assets.
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‍Note. Unless expressly stated otherwise, this Pricing, Costs & Fees Disclosure applies exclusively to our crypto-asset services regulated under MiCA. It does not cover fees related to our fiat (e-money) account or related payment services. For details on such fees please refer to your Client Agreement, visit our Help Centre or contact merchants@bvnk.com.

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Crypto-asset pricing and fees
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Wallet and internal transfer fees

BVNK provides wallet services for the custody of your crypto-assets at no cost.

Furthermore, transfers of crypto-assets from one BVNK wallet to another BVNK wallet (i.e. internal transfers) are also provided free of charge.

For other services, BVNK applies a combination of fixed, percentage-based, and tiered fees, as detailed below.
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Conversion services

When you buy, sell, or convert crypto-assets, the fees are included in the "Conversion All-in Exchange Rate". This rate is comprised of the following components:

• BVNK Rate: A stable, blended rate we source from global and regional exchanges, market makers, and OTC desks; and
• Commercial Fee: A pre-agreed percentage and/or fixed amount added to the BVNK Rate, as agreed with you.
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For the avoidance of doubt, unless expressly agreed otherwise, these fees are applicable to all of BVNK’s products that involve a conversion of crypto-assets.
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Crypto-asset payment services

For sending or receiving crypto-assets to or from an external wallet (outside the BVNK platform), we will charge a percentage and/or fixed fee. These fees may be tiered, meaning higher volumes can result in lower rates. All applicable fees for these services are pre-agreed with you.

For the avoidance of doubt, unless expressly agreed otherwise, these fees are applicable to all of BVNK’s products that involve the sending or receiving of crypto-assets (including Payment Link Refunds).
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Blockchain fees

For transactions on a blockchain network (i.e., sending crypto-assets off the BVNK platform), BVNK incurs and pays blockchain network fees (e.g., "miner fees" or "gas fees").

When you send crypto-assets from your BVNK wallet to an external wallet, we charge a fee based on our estimate of the prevailing network fees. This estimated fee is disclosed to you at the time of the transaction. Please note that the final fee BVNK pays may differ from the estimate due to factors like network congestion or our own transaction batching.

We disclose our prevailing weekly estimates for network fees on the BVNK Help Centre, accessible via the BVNK Website.

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Other potential fees

As applicable, and only where pre-agreed with you, BVNK may charge general fees for access to our services (including both crypto-asset and e-money), namely:

• Onboarding Fee: A one-time fee for account setup.
• Monthly Platform Fee: A platform fee charged monthly in arrears.
• Minimum Monthly Commitment (MMC) Fee: Applicable if your aggregate monthly transaction fees fall below a pre-agreed MMC Fee.

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Review and updates

BVNK will review and update this pricing and fees disclosure periodically to reflect market changes and client feedback. Any such changes will come into effect upon notification to you and approval by BVNK’s Board of Directors.
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Contact and support

For further information or any questions about our pricing, costs, and fees, please contact us via merchants@bvnk.com or contact your dedicated Account Manager.