Important Notice

Dream Finance UAB (Lithuania) has temporarily suspended the provision of all crypto-asset related services, including onboarding of new clients, execution of transactions, and conclusion of new agreements.

During this period, the company does not offer, market, or provide any services described on this website. Any product descriptions or references are provided for informational and historical purposes only and shall not be interpreted as an offer, solicitation, or availability of services.
This website is maintained solely to provide mandatory legal information, regulatory disclosures, and contact details for former clients, counterparties, and competent authorities.

For inquiries related to existing contractual obligations, outstanding matters, or regulatory questions, please contact us at: [email protected].

 

Conflict of Interest Statement

Dream Finance UAB is committed to acting honestly, fairly, and professionally in the best interests of our clients. We maintain robust internal standards to identify, prevent, and manage conflicts of interest that may arise during the course of our business activities.

This page summarises the key principles of our Conflicts of Interest Policy.

1. What Is a Conflict of Interest?

A conflict of interest occurs when the personal, professional, or financial interests of Dream Finance UAB, its employees, or related parties may diverge from the interests of our clients or impair the objectivity and independence of decision-making.

Conflicts may be:

  • Actual – a direct and existing conflict;
  • Potential – a situation that could develop into a conflict;
  • Perceived – circumstances that may appear to compromise impartiality, even if no real conflict exists.

Our objective is to ensure such situations are recognised early, assessed properly, and managed effectively to maintain trust and integrity.

2. General Principles We Follow

Dream Finance UAB applies the following fundamental principles in managing conflicts of interest:

Fair treatment

We always act in the best interests of our clients and ensure our actions do not unfairly advantage one client over another.

Integrity and independence of judgement

Our employees and management must make decisions independently and avoid situations that could impair objectivity.

Transparency

Where unavoidable conflicts arise, we provide transparent disclosures to clients, explaining the nature of the conflict and the measures used to address it.

Confidentiality

Sensitive information obtained during business activities – including crypto-asset-related and commercial information – is handled strictly in accordance with confidentiality and applicable regulations.

Proportionality

Measures to prevent or manage conflicts are applied in a manner proportionate to the nature, scale, and risks of our business.

3. Types of Conflicts of Interest

A. Institutional Conflicts of Interest

Institutional conflicts may arise from the Company’s organisational structure, business lines, or interactions with external stakeholders. Examples include:

  • Different business units whose objectives may diverge;
  • Situations where multiple functions overlap or could influence one another;
  • Relationships with vendors, partners, or group-related entities.

To mitigate such risks, we implement clear separation of responsibilities, information barriers (“Chinese walls”), and robust governance arrangements.

B. Personal Conflicts of Interest

Personal conflicts may arise when an individual’s private interests diverge from their professional duties. Examples include:

  • Financial interests in external companies or clients;
  • Close personal or professional relationships that may impact independent judgement;
  • Gifts, benefits, or inducements that could influence decisions;
  • External employment or business activity that could affect impartiality.

Employees and management are required to disclose such interests and refrain from participating in decisions where their independence may be compromised.

4. How We Identify and Assess Conflicts

Dream Finance UAB maintains internal procedures to identify and assess potential or actual conflicts of interest. These include:

  • Regular declarations of interest by employees and management;
  • Review of new products, business lines, and organisational changes;
  • Ongoing monitoring by the local Compliance Officer in Lithuania in accordance with applicable regulations

Identified conflicts are evaluated based on:

  • Their nature and sources;
  • The persons or units involved;
  • The potential impact on clients and the Company (material vs non-material).

5. How We Manage Conflicts of Interest

Where conflicts are identified, the Company applies measures such as:

Preventive measures

  • Segregation of duties and responsibilities;
  • Separation of structural units and sensitive functions;
  • Ensuring related-party transactions occur on market terms;
  • Restrictions on access to sensitive information.

Mitigating measures

If a conflict cannot be fully prevented, we take additional steps such as:

  • Reassigning responsibilities;
  • Enhanced monitoring of decisions or transactions;
  • Withholding certain persons from participating in decision-making (e.g., abstaining from votes).

Material conflicts of interest are never accepted and must always be prevented or effectively mitigated.

6. Disclosure to Clients

In the limited cases where a conflict cannot be fully avoided, we may provide clear and fair disclosure to affected clients.

Such disclosure includes:

  • The nature and source of the conflict;
  • Associated risks;
  • The measures taken to manage or mitigate the conflict.

Disclosure is used only as a last resort – never as a substitute for proper internal controls.

7. Record Keeping and Monitoring

Dream Finance UAB maintains a Conflicts of Interest Register, where identified conflicts and relevant mitigation measures are documented.
The Lithuanian Compliance Officer regularly monitors the effectiveness of applied measures and provides periodic reports to senior management and, if required, to the Bank of Lithuania.

We also conduct ongoing employee training to ensure awareness and adherence to our standards.

8. Commitment to Continuous Improvement

Our Conflicts of Interest Policy is reviewed regularly to ensure continued alignment with:

  • Regulation (EU) 2023/1114 (MiCA);
  • The Law on the Prevention of Money Laundering and Terrorist Financing of the Republic of Lithuania (No. VIII-275);
  • Applicable guidance, regulatory updates, and supervisory expectations from the Bank of Lithuania and ESMA;
  • Best practices in transparency, governance, and client protection.

Dream Finance UAB is committed to maintaining strong internal controls to protect the interests of all clients and stakeholders.