Conflict of Interest Statement
Introduction
Dream Finance US LLC is committed to conducting its operations with integrity, fairness, and transparency. As a U.S.-regulated Virtual Asset Service Provider (VASP) and Money Services Business (MSB), we maintain strict standards to identify, prevent, and manage conflicts of interest that may arise in connection with our business activities.
This document summarizes the principles and practices that guide how Dream Finance manages conflicts of interest to safeguard our clients, partners, and stakeholders.
Definition of a Conflict of Interest
A conflict of interest occurs when personal, financial, or professional interests-whether of Dream Finance, its employees, or related parties-could compromise, or appear to compromise, our duty to act in the best interests of our clients.
Conflicts may be:
- Actual: The conflict exists now.
- Potential: Circumstances could develop into a conflict.
- Perceived: It appears, even without evidence, that impartiality may be affected.
Dream Finance seeks to identify and address all such situations promptly and effectively.
Core Principles
Dream Finance manages conflicts of interest based on the following principles:
Fair Treatment
Clients are treated fairly, consistently, and without preference.
Integrity and Independence
Employees must act with independent judgment and avoid personal interests that could impact decision-making.
Transparency
Where a conflict cannot be fully prevented, clear and fair disclosure is provided to affected clients.
Confidentiality
Client information – including virtual asset-related data – is protected and used only for legitimate purposes.
Proportionality
Controls are scaled to the nature, risk, and complexity of our business operations.
Types of Conflicts of Interest
Institutional Conflicts
Institutional conflicts may arise from the Company’s business structure, operational arrangements, or relationships with vendors and partners.
Mitigation measures include:
- Segregation of duties
- Information barriers (“Chinese walls”)
- Independent review processes
- Clear reporting lines
Personal Conflicts
Personal conflicts may arise when an employee’s private interests interfere with professional obligations. Examples include:
- Ownership interests in clients or partners
- Close personal relationships affecting objectivity
- Receiving gifts, benefits, or inducements
- Outside employments or advisory roles
Employees must disclose any such interests and may be restricted from related activities or decisions.
Identification and Assessment of Conflicts
Dream Finance implements procedures to proactively identify conflicts of interest, including:
- Annual and event-driven employee declarations
- Compliance review of new products and business changes
- Monitoring of third-party relationships
- Ongoing oversight by the Compliance Department
Conflicts are assessed based on their:
- Nature
- Source
- Impact on clients
- Potential to affect integrity, fairness, or judgment
Managing and Mitigating Conflicts
Where conflicts are identified, Dream Finance applies appropriate controls, such as:
Preventive Measures
- Segregation of responsibilities
- Access controls and information barriers
Market-standard treatment for related-party transactions - Defined escalation procedures
Mitigating Measures
- Reassignment of duties
- Enhanced compliance monitoring
- Requiring abstention from decision-making
- Restricting participation in certain activities
Material conflicts of interest are never accepted and must be prevented or effectively mitigated.
Disclosure to Clients
If a conflict cannot be fully eliminated, Dream Finance may disclose it to affected clients.
Disclosure will include:
- The nature of the conflict
- Potential implications
- Steps taken by the Company to mitigate it
Disclosure is used only when necessary and never as a replacement for robust internal controls.
Recordkeeping and Monitoring
Dream Finance maintains a Conflicts of Interest Register, documenting all identified conflicts and the steps taken to address them.
The Compliance Department:
- Monitors controls on an ongoing basis
- Conducts periodic reviews
- Provides reports to senior management
- Ensures training for employees
Continuous Improvement
Dream Finance reviews this policy regularly to ensure continued alignment with:
- Applicable U.S. regulatory requirements
- Expectations for registered MSBs/VASPs
- Industry best practices in ethical conduct and governance
We remain committed to protecting our clients’ interests and maintaining the highest standards of professionalism and integrity.