Investor Protection, Transparency and Rigor in the Provision of Financial Services
The entry into force of the European regulatory framework applicable to markets in financial instruments — namely Directive 2014/65/EU (MiFID II) and its associated regulation — has significantly strengthened investor protection, market transparency, and the quality of services provided by financial institutions.
Bison Bank fully adopts these standards, implementing robust policies and practices that ensure strict compliance with legal obligations and the provision of responsible, transparent investment services tailored to each client’s profile.
Bison Bank maintains records and recordings of communications related to investment services, ensuring traceability, documentary evidence, and quality in the execution of operations — across telephone, email, website, or in-person interactions.
In accordance with the European regulatory framework, clients are classified for regulatory protection purposes as follows:
- Retail Client – highest level of protection and detailed information requirements;
- Professional Client – intended for clients with advanced experience and knowledge of financial markets;
- Eligible Counterparty – category applicable to financial institutions and public entities, with a lower level of regulatory protection.
This classification determines the type of information provided and the applicable level of protection.
To ensure that each product or service is appropriate for the client, the Bank collects information on:
- Financial knowledge and experience
- Financial situation and ability to bear losses
- Investment objectives and risk tolerance
- Sustainability preferences
This assessment enables the Bank to provide recommendations and services aligned with each investor’s profile and needs.
Before subscribing to certain investment products, the client is provided with a Key Information Document (“KID”), which includes:
- Key product characteristics
- Risk profile
- Associated costs
- Potential performance scenarios
This information enables investors to make informed decisions.
Clients have access to full information regarding the costs and charges associated with investment services and should carefully review them before proceeding. It is also recommended to consult the guidelines and cost comparison tools made available by the Portuguese Securities Market Commission (CMVM).
The Bison Bank Financial Intermediation Fee Schedule is available at:
https://bisonbank.com/legal/price-list/
Bison Bank is committed to achieving the best possible result when executing or transmitting client orders, taking into account factors such as:
- Price
- Costs
- Speed
- Likelihood of execution and settlement
- Market conditions
For further information on Bison Bank’s Order Execution Policy, please refer this document.
In the course of its activities, Bison Bank, S.A. ensures that it is equipped with the appropriate material, technical, and human resources, allocating qualified personnel in sufficient numbers to its various functions, and maintaining information systems that ensure services are provided securely, efficiently, and in compliance with legal requirements.
Bison Bank, S.A. complies with all applicable legal requirements and has procedures in place to ensure the clear segregation between its own assets and those of its clients. The Bank is annually audited by an independent external entity regarding the measures adopted for the safeguarding of assets, and the corresponding compliance report is submitted to the CMVM in accordance with regulatory requirements.
For further information on Bison Bank’s Asset Safeguarding Policy, please refer this document.
Bison Bank, as a crypto-asset service provider authorized under Regulation (EU) 2023/1114 (“MiCAR”), provides custody and administration of crypto-assets on behalf of clients, ensuring high standards of security, protection, and transparency.
Crypto-asset custody services are supported by a robust governance framework, including operational, technological, and cybersecurity risk management policies, as well as business continuity and disaster recovery plans. For detailed information on this matter, please consult our Policy on the custody, management, and segregation of crypto-assets here.
This service is provided in compliance with the applicable European regulatory framework, namely MiCAR, ensuring a high level of investor protection and market integrity. In addition to the full version of the Policy on the custody, management, and segregation of crypto-assets, a summary of how Bison Bank protects your crypto-assets is presented below:
Governance
- The Bank only provides crypto-asset custody and administration services upon the signing of an agreement with the client.
- Please be advised that crypto-assets are not covered by the Deposit Guarantee Fund or the Investor Compensation Scheme.
- Clients’ crypto-assets are recorded in individualized accounts.
- The client may request statements of their crypto-asset positions via the application (online banking).
Security of Crypto-Assets
- Access to crypto-assets is protected by multi-factor authentication, encryption, and advanced custody technology (MPC).
- Private keys are stored in a fragmented, secure, and redundant manner.
- All movements are subject to rigorous controls (four-eyes principle).
Exercise of Rights and Staking
- The Bank assists clients in exercising the rights associated with crypto-assets, where applicable.
- Events such as forks, airdrops, or changes to the blockchain network are communicated to clients whenever possible.
- The Bank provides staking services subject to client consent, retaining a portion of the rewards as remuneration.
Return of Crypto-Assets
- The client may, at any time, request the return of their crypto-assets.
- The transfer is completed within 1 business day following the receipt of the required documents and the completion of all mandatory Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) procedures.
- The return is only made to wallets duly proven to be held in the client’s name.
Risk Management and Liability
- The Bank implements measures to mitigate risks such as cyberattacks, technological failures, outsourcing, and operational errors.
- The Bank shall not be held liable for losses caused by client negligence, blockchain network failures, or external attacks.
Segregation of Assets
- Clients’ crypto-assets are legally segregated from the Bank’s assets.
- They are held in omnibus accounts (“jumbo accounts”) with detailed record-keeping per client.
- In the event of the Bank’s insolvency, clients’ assets do not form part of the insolvency estate.
Outsourcing
- The Bank may rely on third-party providers for custody, requiring high standards of security and certification.
- Continuous monitoring and due diligence are performed to ensure the quality of the outsourced services.
Bison Bank, as a crypto-asset service provider authorized under Regulation (EU) 2023/1114 (“MiCAR”), provides crypto-asset transfer services on behalf of clients, ensuring high standards of security, transparency, and execution.
For detailed information on this matter, please consult our Crypto-Assets Transfer Services Policy here. In addition to the full version of the Policy, a summary of how Bison Bank protects your crypto-assets is presented below:
Execution of Transfers
- Transfers are executed in accordance with client instructions, diligently and within the shortest possible timeframe, following the validation of applicable requirements.
- The Bank ensures that orders are handled with accuracy, respecting the parameters defined by the client.
Verification and Security
- The Bank implements rigorous verification and authentication controls for instructions, including strong authentication mechanisms and transaction monitoring, with the aim of preventing fraud, error, or unauthorized access.
Irreversibility and Specificities
- Crypto-asset transfers may become irreversible once validated on the DLT network.
- Bison Bank informs clients in advance about these characteristics, including execution timeframes, costs, and conditions associated with the operation.
Record-keeping and Transparency
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The Bank maintains complete and auditable records of all transfers, ensuring traceability and the availability of clear information before and after the execution of each operation, including costs, status, and relevant details.
Liability
- Bison Bank acts diligently, fairly, and professionally, being liable under the applicable legal terms for the execution of transfers.
- The correct specification of the operation data, namely the destination address, is the responsibility of the client.
Compliance and Risk Management
- The service is supported by a robust control and risk management framework, including cybersecurity measures and regulatory compliance, namely Anti-Money Laundering requirements and the “Travel Rule”.
Management of Operational Failures and Cybersecurity Risks
Bison Bank implements measures and procedures designed to prevent, detect, respond to, and recover from operational failures and cybersecurity incidents that may affect the provision of its crypto-asset services.
These procedures include:
- Continuous monitoring of relevant systems and services;
- Detection and handling of operational and security incidents;
- Containment and recovery measures to minimize impacts on clients;
- Business continuity and service recovery plans;
- Periodic assessment of operational and cybersecurity risks;
- Reporting of material incidents to competent authorities and to clients, where applicable.
Bison Bank regularly reviews these measures to ensure their adequacy in light of evolving technological risks and cybersecurity threats.
