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Legal Disclosures
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MiCAR Policies Library:
Complaints Handling
Pay Perform OÜ is committed to handling all client complaints in a transparent, fair, and timely manner. This summary sets out how clients can submit a complaint, what to expect during the process, and how we resolve issues
A complaint is any verbal or written expression of dissatisfaction made by, or on behalf of, a client regarding our payment, e-money, or crypto-asset services or concerning conduct, rights, or obligations under applicable regulations.
How to submit a complaint
Complaints are accepted in any form and free of charge. You can reach us through any of the following channels:
Email: complaints@orbital.com
Website: via the 'Contact Us' page at www.getorbital.com
Phone: +44 (0)203 807 5060: available Monday to Friday,
9:00am – 5:00pm GMT (excluding bank and public holidays)
9:00am – 5:00pm GMT (excluding bank and public holidays)
Post: Hobujaama tn 4, 10151, Tallinn, Estonia
Please use the standard complaint form attached as a PDF for easy access on our website. Completing it is not mandatory, but it may help ensure your complaint is processed as quickly as possible.
Complaints may be submitted in any language we use to promote our services or communicate with clients, or in the official language of any country where we operate (provided it is an official EU language).
To help us handle your complaint promptly, please include your contact details, a description of the issue, relevant transaction information (e.g. payment ID, wallet address), the date of the irregularity, any harm or loss incurred, and what outcome you are seeking.
What happens after you submit
We aim to acknowledge receipt of your complaint within 1 working day. Our standard processing timeline is as follows:
Acknowledgement of receipt (with admissibility assessment): within 1 working day
Request for additional information (if needed): within 15 days of receipt
Final response: within 15 days of receipt, or the date a completed complaint is submitted
Extended deadline (one-time, where justified): up to 35 days from receipt. If we cannot resolve your complaint within 15 days, we will notify you in writing of the reason for the delay and the revised expected response date.
How we handle your complaint
All complaints are received by our Customer Support Team, logged in our internal system (JIRA), and assigned to the relevant department. A designated responsible person will act as your primary point of contact throughout the process.
We assess every complaint on its merits, impartially, thoroughly and consistently. We will not request information from you that we can already obtain from our own records. All correspondence will be conducted in plain, clear language.
Where we uphold a complaint, we will offer appropriate remedial action or redress and implement it promptly. Our decision will include a full statement of reasons and information on any available remedies.
Appeals and external recourse
If you are not satisfied with our decision, you have the right to appeal. The same timelines and procedures that apply to the original complaint apply to the appeal process.
You may also escalate your complaint to external bodies:
The Estonian Financial Supervision and Resolution Authority (EFSA)
A court of competent jurisdiction in Estonia (by default, Harju County Court), in accordance with Regulation (EU) No 1215/2012 and applicable Estonian law
Complaints Template
To submit a complaint, please download and complete the complaint template form below. Once completed, send the form together with any supporting documentation to our complaints handling team.
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Download Complaints Template
Conflict of Interest
This document describes how Pay Perform OÜ discloses to clients and prospective clients the general nature and sources of conflicts of interest, as well as the steps taken to mitigate them.
Pay Perform OÜ is committed to acting in the best interests of its clients at all times, treating them fairly, and conducting its business with honesty and integrity. Pay Perform OÜ identifies, prevents, manages, and discloses conflicts of interest through its Conflicts of Interest Policy.
Pay Perform OÜ acknowledges that, as a for-profit organisation, its commercial interest in maximising revenue can be inherently at odds with clients' interest in receiving services at the lowest cost. Such structural conflicts cannot be eliminated entirely; however, Pay Perform OÜ manages them through transparent pricing, fair and equal treatment of clients and the measures described below.
General nature & sources of conflicts of interest
Conflicts of interest may arise in the following contexts:
1.
Between Pay Perform OÜ and its clients
Pay Perform OÜ acts as principal when providing exchange services using its own proprietary capital, creating a potential tension between Pay Perform OÜ’s commercial interest in achieving a favourable rate and the client's interest in receiving the best price. Pay Perform OÜ may also earn revenue through spreads and margins on order execution, which could diverge from the client’s interest in minimising transaction costs.
Pay Perform OÜ acts as principal when providing exchange services using its own proprietary capital, creating a potential tension between Pay Perform OÜ’s commercial interest in achieving a favourable rate and the client's interest in receiving the best price. Pay Perform OÜ may also earn revenue through spreads and margins on order execution, which could diverge from the client’s interest in minimising transaction costs.
2.
Between clients
Where Pay Perform OÜ processes multiple client orders, the sequencing and routing of orders could, in theory, affect the prices or liquidity available to individual clients. Pay Perform OÜ applies a transparent, rule-based order-priority system (time and price) to ensure no client is systematically favoured over another.
Where Pay Perform OÜ processes multiple client orders, the sequencing and routing of orders could, in theory, affect the prices or liquidity available to individual clients. Pay Perform OÜ applies a transparent, rule-based order-priority system (time and price) to ensure no client is systematically favoured over another.
3.
Between Pay Perform OÜ and the Orbital Group
Pay Perform OÜ is part of the Orbital Group, which includes entities providing related financial services. Conflicts may arise from shared technological infrastructure (including the Fireblocks custody environment, IT systems, and cybersecurity tools), common ownership, overlapping governance or shared personnel, and intra-group service or outsourcing arrangements. Such conflicts, if unmanaged, could result in decisions made in the interests of one entity at the expense of another or of clients.
Pay Perform OÜ is part of the Orbital Group, which includes entities providing related financial services. Conflicts may arise from shared technological infrastructure (including the Fireblocks custody environment, IT systems, and cybersecurity tools), common ownership, overlapping governance or shared personnel, and intra-group service or outsourcing arrangements. Such conflicts, if unmanaged, could result in decisions made in the interests of one entity at the expense of another or of clients.
4.
Dual role holders
Where individuals simultaneously hold roles within more than one Orbital Group entity (cross-entity roles) or across different regulated activities such as crypto-asset, payment, and e-money services (cross-sector roles), there is a risk that their independence or decision-making in one role may be influenced by their responsibilities in another. This applies in particular to areas such as safeguarding of client assets, risk management, and pricing.
Where individuals simultaneously hold roles within more than one Orbital Group entity (cross-entity roles) or across different regulated activities such as crypto-asset, payment, and e-money services (cross-sector roles), there is a risk that their independence or decision-making in one role may be influenced by their responsibilities in another. This applies in particular to areas such as safeguarding of client assets, risk management, and pricing.
5.
Personnel with personal interests
Conflicts may arise where a member of Pay Perform OÜ’s personnel has personal, financial or professional interests that could affect their objectivity. This includes situations where a person has shareholdings or financial interests in clients, suppliers, or competitors; close personal or family relationships with individuals at counterparties or clients; prior or current professional relationships (e.g. consultancy or board roles) with relevant entities; or engages in outside employment without prior consent.
Conflicts may arise where a member of Pay Perform OÜ’s personnel has personal, financial or professional interests that could affect their objectivity. This includes situations where a person has shareholdings or financial interests in clients, suppliers, or competitors; close personal or family relationships with individuals at counterparties or clients; prior or current professional relationships (e.g. consultancy or board roles) with relevant entities; or engages in outside employment without prior consent.
6.
Inducements from Third Parties
Pay Perform OÜ may interact with liquidity providers, stablecoin issuers and other service partners. Any rebates, incentives, or non-monetary benefits from these parties could, if not properly managed, create an incentive for Pay Perform OÜ to act in ways that are not in the clients' best interests.
Pay Perform OÜ may interact with liquidity providers, stablecoin issuers and other service partners. Any rebates, incentives, or non-monetary benefits from these parties could, if not properly managed, create an incentive for Pay Perform OÜ to act in ways that are not in the clients' best interests.
7.
Integrated Platform Services
Pay Perform OÜ provides crypto-asset custody, order execution, exchange and e-money or payment services within a single platform. The integration of these services could lead to conflicts among regulated activities, for example, when decisions about asset deployment or liquidity affect clients across different services.
Pay Perform OÜ provides crypto-asset custody, order execution, exchange and e-money or payment services within a single platform. The integration of these services could lead to conflicts among regulated activities, for example, when decisions about asset deployment or liquidity affect clients across different services.
Steps taken to mitigate conflicts of interest
1.
Pricing Transparency
All exchange rates, margins and fees are determined under a fair, Board-approved pricing methodology consistent with Pay Perform OÜ’s Commercial Policy. Clients are always shown an all-inclusive rate before confirming a transaction. Pay Perform OÜ does not execute transactions in a manner designed to generate proprietary benefit at a client's expense, and where it acts as principal in execution, it discloses this to clients in advance.
All exchange rates, margins and fees are determined under a fair, Board-approved pricing methodology consistent with Pay Perform OÜ’s Commercial Policy. Clients are always shown an all-inclusive rate before confirming a transaction. Pay Perform OÜ does not execute transactions in a manner designed to generate proprietary benefit at a client's expense, and where it acts as principal in execution, it discloses this to clients in advance.
2.
No Inducements
Pay Perform OÜ does not accept any remuneration, rebates, discounts or non-monetary benefits from liquidity providers or other third parties in return for routing client orders. Any approved third-party benefits are disclosed, registered in the Conflicts of Interest Register, and reviewed at least annually.
Pay Perform OÜ does not accept any remuneration, rebates, discounts or non-monetary benefits from liquidity providers or other third parties in return for routing client orders. Any approved third-party benefits are disclosed, registered in the Conflicts of Interest Register, and reviewed at least annually.
3.
Order Handling Rules
Client orders are executed sequentially as they are received, applying time and price priority. Personnel involved in pricing, liquidity management, or counterparty selection do not have variable remuneration directly linked to the profitability of client transactions.
Client orders are executed sequentially as they are received, applying time and price priority. Personnel involved in pricing, liquidity management, or counterparty selection do not have variable remuneration directly linked to the profitability of client transactions.
4.
Group-Level Segregation
Each Orbital Group entity operates as a legally and operationally distinct regulated entity with independent management, governance, and decision-making. Client assets are never commingled between entities. Each entity maintains a separate Fireblocks workspace with its own governance, signing policies, and access controls. All intra-group service arrangements are formalised in written agreements reviewed at least annually.
Each Orbital Group entity operates as a legally and operationally distinct regulated entity with independent management, governance, and decision-making. Client assets are never commingled between entities. Each entity maintains a separate Fireblocks workspace with its own governance, signing policies, and access controls. All intra-group service arrangements are formalised in written agreements reviewed at least annually.
5.
Dual Role Controls
All individuals holding dual roles across Orbital Group entities or regulated activities are recorded in the Conflicts of Interest Register. Segregation of duties, delegation, and committee structures are applied so that no person with dual roles can unilaterally take decisions that could benefit one entity or business line over another. Higher-risk dual-role functions (compliance, risk, finance) require independent sign-off or dual-control mechanisms.
All individuals holding dual roles across Orbital Group entities or regulated activities are recorded in the Conflicts of Interest Register. Segregation of duties, delegation, and committee structures are applied so that no person with dual roles can unilaterally take decisions that could benefit one entity or business line over another. Higher-risk dual-role functions (compliance, risk, finance) require independent sign-off or dual-control mechanisms.
6.
Declaration of Personal Interests
All personnel with access to client, transaction, or pricing information complete an Annual Declaration of Personal Interests. New joiners complete this declaration upon onboarding. Any holding, investment, or beneficial ownership in entities in the crypto-asset, payments, or financial services sector requires pre-approval from the Head of Legal and Compliance. Personnel must disclose personal or family relationships with clients, suppliers, or counterparties, and are recused from related decision-making where appropriate.
All personnel with access to client, transaction, or pricing information complete an Annual Declaration of Personal Interests. New joiners complete this declaration upon onboarding. Any holding, investment, or beneficial ownership in entities in the crypto-asset, payments, or financial services sector requires pre-approval from the Head of Legal and Compliance. Personnel must disclose personal or family relationships with clients, suppliers, or counterparties, and are recused from related decision-making where appropriate.
7.
Information Barriers & Segregation of Functions
Pay Perform OÜ operates a three-lines-of-defence model. Information barriers, separate reporting lines, and functional segregation are applied to prevent conflicts from materialising. Where the same individual oversees multiple areas, independent sign-off and committee approval mechanisms are in place.
Pay Perform OÜ operates a three-lines-of-defence model. Information barriers, separate reporting lines, and functional segregation are applied to prevent conflicts from materialising. Where the same individual oversees multiple areas, independent sign-off and committee approval mechanisms are in place.
8.
Conflicts of Interest Register
Pay Perform OÜ maintains a Conflicts of Interest Register, updated on an ongoing basis, recording all actual, potential, and perceived conflicts, the mitigation measures applied, and any related disclosures. The Register is reviewed at least annually by the Head of Legal and Compliance and reported to the Management Board.
Pay Perform OÜ maintains a Conflicts of Interest Register, updated on an ongoing basis, recording all actual, potential, and perceived conflicts, the mitigation measures applied, and any related disclosures. The Register is reviewed at least annually by the Head of Legal and Compliance and reported to the Management Board.
9.
Oversight & Governance
The Head of Legal and Compliance is responsible for overseeing the identification, management, and disclosure of conflicts. Reports are submitted to the Management Board at least annually and on an ad hoc basis when material conflicts arise. The Supervisory Board reviews and approves the annual report and any amendments to the Conflicts of Interest Policy. All personnel undergo training on the identification, disclosure, and management of conflicts of interest at least annually.
The Head of Legal and Compliance is responsible for overseeing the identification, management, and disclosure of conflicts. Reports are submitted to the Management Board at least annually and on an ad hoc basis when material conflicts arise. The Supervisory Board reviews and approves the annual report and any amendments to the Conflicts of Interest Policy. All personnel undergo training on the identification, disclosure, and management of conflicts of interest at least annually.
10.
Platform Segregation
Where crypto-asset custody, order execution, exchange, and e-money or payment services are provided on the same platform, Pay Perform OÜ maintains clear functional segregation, entity-specific balance sheets, and audit trails demonstrating that client funds safeguarded under payment and e-money regulations are never used for MiCAR-regulated activities, and vice versa.
Where crypto-asset custody, order execution, exchange, and e-money or payment services are provided on the same platform, Pay Perform OÜ maintains clear functional segregation, entity-specific balance sheets, and audit trails demonstrating that client funds safeguarded under payment and e-money regulations are never used for MiCAR-regulated activities, and vice versa.
Residual Disclosure
Where the measures described above are not sufficient to prevent a conflict of interest from harming a client’s interests with reasonable certainty, Pay Perform OÜ will make a specific disclosure to the affected client before proceeding with the relevant service or transaction. Such disclosure will describe the specific conflict, the risks it presents, and why Pay Perform OÜ has concluded that it can proceed. Clients may then make an informed decision as to whether to proceed.
Custody Services
This document describes how Pay Perform OÜ safeguards crypto-assets held on behalf of clients, the controls in place to minimise the risk of loss from fraud, cyber threats, or negligence and clients’ rights regarding their assets.
This Policy applies to all crypto-assets safeguarded by Pay Perform OÜ on behalf of clients, including e-money tokens.
How your assets are held
Pay Perform OÜ provides custody and administration of crypto-assets as a standalone service or in connection with other services, such as order execution, exchange, and transfer services. Pay Perform OÜ acts as custodian, your crypto-assets are held securely on your behalf, and ownership remains with you at all times.
Client assets are held in Omnibus DLT Addresses (pooled wallets) that are legally and operationally segregated from Pay Perform OÜ's own holdings. Individual client entitlements are recorded separately in Pay Perform OÜ's internal ledger in real time and reconciled regularly. A pooled omnibus structure reduces the number of internet-exposed wallets, strengthening centralised security controls and making it easier to detect and prevent unauthorised access.
Pay Perform OÜ may also create Personal DLT Addresses for individual clients where required, for example, in connection with crypto-asset transfer services or for longer-term safekeeping.
Your assets are never used, pledged, lent, or otherwise disposed of by Pay Perform OÜ for its own account or purposes.
Register of positions
Pay Perform OÜ maintains a Register of Positions for each client, recording all crypto-assets held in custody and every change to those holdings, including deposits, withdrawals, and any other event affecting the nature or quantity of assets held. All changes are recorded as soon as practicable after they occur.
You can view your statement of position at any time by logging in to the Client Portal. In addition, Pay Perform OÜ will provide you with a formal statement of position at least once every three months, and at any time upon your request, in electronic format. The statement identifies the crypto-assets held, their balance and value, and any transfers made during the relevant period.
Returning your assets
You may request the return of your crypto-assets at any time. Withdrawal requests are subject to compliance screening in accordance with Pay Perform OÜ's AML/CTF procedures. Instructions can be submitted through any of the following channels:
Client Portal: Pay Perform OÜ's secured web application
API: secure programmatic access following integration with Pay Perform OÜ
OTC desk: instructions via encrypted messaging platforms (Slack, Teams, Zoom) as agreed in advance
You may also escalate your complaint to external bodies:
Private key management & cold storage
Pay Perform OÜ applies Multi-Party Computation (MPC) technology for private key management, powered by Fireblocks infrastructure. Under MPC, private keys are never stored in a single location or held by any one individual. Instead, each key is split into three shards: two held by separate senior members of Pay Perform OÜl’s personnel (each based in a different location) and one held within the secure Fireblocks MPC infrastructure. Transactions are signed cryptographically without the full private key ever being reconstructed.
For assets not actively transacted, Pay Perform OÜ may additionally implement a cold storage layer using air-gapped environments, systems completely isolated from the internet. Cold storage is applied selectively based on asset type, volume, and client requirements.
No single member of personnel can access full private keys. Backup copies are stored in encrypted, offline environments and may only be reassembled through strict authorisation procedures, with all actions logged and monitored. A Full Key Recovery Package is provided under Pay Perform OÜ's contract with Fireblocks.
Protection in the event of insolvency
Client crypto-assets are not part of Pay Perform OÜ’s bankruptcy estate and are protected from claims by Pay Perform OÜ’s creditors. Client entitlements are recorded off-balance-sheet in real time via an internal ledger and are subject to regular reconciliation and audit.
Both Pay Perform OÜ’s contractual arrangements with Fireblocks and the Master Services Agreement with each client confirm that Pay Perform OÜ holds assets solely as a custodian, without any proprietary claim, and that clients retain legal ownership and full rights of recovery at all times, including in the event of insolvency.
Security systems & risk controls
Pay Perform OÜ employs a layered security and operational integrity framework designed to minimise the risk of loss due to fraud, cyber threats, or negligence. Key controls include:
MPC infrastructure: eliminates any single point of failure in cryptographic control; no individual or system component has unilateral access to full cryptographic keys
Role-Based Access Control (RBAC): enforces the principle of least privilege; segregation of duties is embedded in system workflows and reviewed regularly through access recertification and audit logging
Multi-level transaction approvals: all asset transfers require multi-level authorisation tied to documented client instructions and pre-defined transaction thresholds
Continuous monitoring: 24/7 monitoring of internal systems and endpoints with real-time anomaly detection; assets may be programmatically frozen and access revoked instantly in the event of suspicious activity
Multi-factor authentication: MFA, password policies, and automated response playbooks protect against compromised credentials
Penetration testing & vulnerability management: regular internal and external scans, with issues prioritised and remediated based on risk severity
Comprehensive audit logging: all access attempts and transactions are captured and reviewed for compliance verification
Disaster recovery: key shard backups are stored in geographically separated environments; business continuity procedures ensure custody operations can continue safely following any system failure
Cyber insurance: Pay Perform OÜ maintains PI and Cyber insurance coverage of £2,000,000, renewed annually
Pay Perform OÜ’s systems and controls are certified to SOC 2 and ISO/IEC 27001 standards, independently audited on a periodic basis, and overseen by the Chief Product and Technology Officer and the Compliance team.
Third-party custody technology (Fireblocks)
Pay Perform OÜ delegates technical aspects of its custody infrastructure to Fireblocks, which acts strictly as a non-discretionary technology provider. Fireblocks provides key-shard infrastructure, MPC management, and secure transaction policy enforcement. It does not have access to client assets and cannot initiate or authorise transfers independently.
All operational responsibility, key management, approval logic, and transaction policies remain fully controlled and administered by Pay Perform OÜ. There are no sub-delegations beyond Fireblocks. Should Pay Perform OÜ ever engage a third-party provider with discretionary control over client assets, that provider would be required to hold appropriate MiCAR authorisation, segregate client assets at wallet level, and contractually commit not to commingle, pledge or use client assets for any purpose.
Liability for loss of client assets
Pay Perform OÜ is liable to clients for the loss of any crypto-assets or the means of access to crypto-assets, where such loss results from an incident attributable to Pay Perform OÜ. Pay Perform OÜ’s liability is capped at the market value of the crypto-asset at the time the loss occurred, except where the loss is caused by intentional misconduct or gross negligence.
Pay Perform OÜ is not liable for:
Events occurring independently of Pay Perform OÜ's operations, including problems inherent in the operation of the distributed ledger that Pay Perform OÜ does not control
Loss caused by incidents attributable to the client, including viruses, cyber attacks directed at the client, or compromised client credentials arising from social engineering or impersonation
Unforeseeable loss, indirect loss, loss of profit, business interruption, or loss of business opportunity.
Please note that this is just the summary of the principles applying to Pay Perform OÜ’s liability in relation to your assets custodied by Pay Perform OÜ. Please refer to your Master Services Agreement for legally binding liability clauses.
Clients are responsible for safeguarding their own credentials, managing their designated users, maintaining security over their communication channels and devices, and promptly notifying Pay Perform OÜ of any suspected security breach. Failure to comply with these obligations may limit or exclude Pay Perform OÜ's liability.
Fees Disclosures
This document summarizes Pay Perform OÜ’s Commercial Policy and sets out how Pay Perform OÜ determines prices and fees for its crypto-asset exchange services. It covers our pricing methodology, how costs and fees are disclosed to clients, how we differentiate pricing by client type and the availability of our exchange services.
Pay Perform OÜ's default service is execution of orders on behalf of clients using third-party liquidity providers. On an exceptional basis, Pay Perform OÜ may act as a principal, using its own proprietary capital, to provide exchange services as defined under MiCAR. While the Commercial Policy is established primarily pursuant to Article 77 of MiCAR in respect of exchange services, the principles defined in the policy also apply, to the extent relevant, to the execution of orders.
How we determine prices
When acting as principal, Pay Perform OÜ determines the exchange price based on the last available benchmark or market rate at the time of the transaction, marked up with the margin pre-agreed with the client in their Pricing Schedule. The margin is Pay Perform OÜ's fee for the exchange service.
When executing orders on behalf of clients, Pay Perform OÜ sources executable quotes from integrated liquidity providers (currently B2C2; others may be added at Pay Perform OÜ's discretion). Pay Perform OÜ performs periodic checks against external market data to ensure pricing remains aligned with broader market conditions.
For manual instructions, the guaranteed exchange rate is valid for 15 to 60 minutes (depending on product type) and comprises the base rate, the applicable margin, and any network/gas fees. For pre-agreed auto-conversions via API, the rate is constituted from the live market or liquidity provider rate at the time of the transaction, plus the applicable margin.
E-Money Tokens (EMTs) are priced using the same liquidity provider infrastructure as other supported crypto-assets. While EMTs reference a fiat currency and typically exhibit lower volatility, the executable rate is determined by the relevant liquidity provider, as with other crypto-assets.
Fees, costs & pre-trade disclosure
All fees, including Pay Perform OÜ's margin and any applicable network/gas fees, are included in the rate shown to the client before they confirm a transaction.
Network/gas fees are not Pay Perform OÜ fees; they are third-party costs charged by the relevant blockchain network. Pay Perform OÜ estimates these fees at the time of transaction and displays the estimate alongside the following disclaimer prior to any client confirmation:
“The network fee shown is an estimate calculated at Pay Perform OÜ’s discretion using multiple estimators and tools. Due to fluctuating network demand and transaction complexity, the actual fee may differ. Once charged, the fee will not be adjusted, even if the final network cost is higher or lower. In some cases, Pay Perform OÜ may apply strategies to reduce fees using its own capital.”
Where Pay Perform OÜ acts as principal, the client is explicitly informed prior to execution that: (a) Pay Perform OÜ is acting as principal; (b) the price is a firm price set by Pay Perform OÜ; and (c) best execution principles do not apply. In the absence of such explicit notification, the service is deemed to constitute execution of orders.
Post-trade, transaction information (including volumes and prices) is made available to clients via the Client Portal or other agreed channels, as close to real-time as is technically possible and in any case within 5 minutes of execution.
Pricing by client type
Pay Perform OÜ’s pricing is non-discriminatory. All clients in the same category are treated equally and assessed against the same objective criteria. Pricing tiers are set and reviewed by the Management Board, taking into account the cost of delivering the service, risks assumed, market demand, and competitor rates.
The key factors that determine a client's pricing tier include:
Risk profile: assessed based on jurisdiction, industry, business model, transaction patterns, sanctions exposure, PEP exposure, and AML/CTF classification. Higher-risk classifications may result in higher compliance costs reflected in pricing.
Products and services required: some services involve higher operational costs, such as bespoke API integrations, Travel Rule compliance tooling, or OTC desk arrangements.
Transaction volume: clients with higher volumes may benefit from economies of scale, which can offset servicing costs and allow for more competitive pricing.
Client profitability: assessed using projected or actual transaction volume, revenue generated, and cost-to-serve analysis. Pricing for new clients is based on projected activity; for existing clients, it may be reviewed periodically.
The applicable pricing is agreed in writing in a Pricing Schedule, which forms part of the Master Services Agreement. Any changes to the Pricing Schedule require mutual agreement.
Service availability & limits
Pay Perform OÜ provides exchange services 24/7 under normal market conditions with no cut-off time. There are currently no firm minimum or maximum transaction limits, beyond a minimum of €1 (or equivalent). Pay Perform OÜ reserves the right to establish or communicate limits at any time.
Exchange services may be suspended or restricted in circumstances including:
All liquidity providers halt trading, or a market rate cannot be obtained
Exceptional market volatility or regulatory intervention under MiCAR
Orders that exceed usual volumes, involve temporarily illiquid assets, or would breach internal risk limits
Platform downtime, technical failures, or errors outside Pay Perform OÜ's control
Compliance, security, or legal/regulatory requirements
Pay Perform OÜ may also, at any time and without prior notice, suspend or restrict exchange services for certain or all crypto-assets for internal risk management reasons.
Order Execution
This summary sets out how Pay Perform OÜ executes orders for crypto-assets on behalf of its clients. It explains Pay Perform OÜ’s best execution obligations, the factors it considers when executing orders, the liquidity providers it uses and how clients can place and manage their orders.
Pay Perform OÜ’s default service is the execution of orders for crypto-assets on behalf of clients using third-party liquidity providers. On rare occasions, Pay Perform OÜ may execute against its own proprietary capital (exchange service), in which case the Commercial Policy applies. This summary relates specifically to order execution services. Fiat-to-fiat payments and FX conversion are outside the scope of this document.
Supported crypto-assets
Pay Perform OÜ currently provides order execution services for the following crypto-assets: USDT (Tether), USDC (USD Coin), ETH (Ether), BTC (Bitcoin), BCH (Bitcoin Cash) and LTC (Litecoin). The full list of supported assets and their MiCAR classifications are available upon request.
Important: USDT is classified as an e-money token under MiCAR but has not yet sought EU authorisation from its issuer (Tether Holdings Limited). It is therefore not MiCAR-compliant. Clients should be aware of the additional risks associated with non-MiCAR-compliant assets — see Pay Perform OÜ's Risk Disclosure for further detail.
Exchange services may be suspended or restricted in circumstances including:
Best execution obligation
Pay Perform OÜ is required under Article 78 of MiCAR to take all sufficient steps to obtain the best possible result for clients when executing their orders, taking into account a combination of execution factors. Pay Perform OÜ has an overriding duty to act honestly, fairly and professionally in accordance with the best interests of its clients at all times.
In determining the best possible result, Pay Perform OÜ considers total consideration: being the price of the crypto-asset and all costs directly related to execution, including spreads, mark-ups, and any third-party fees. In most cases, price and speed of execution carry the highest relative importance, given the volatility inherent in crypto-asset markets.
The Execution Factors Pay Perform OÜ considers include:
Price: from liquidity provider quotes or, where applicable, internal pricing
Costs: spreads, mark-ups, and liquidity provider fees
Speed: time taken to execute and settle the transaction
Likelihood of execution: supported by Pay Perform OÜ's liquidity provider network and, where relevant, internal liquidity
Order size: potential market impact of the transaction
Nature of the crypto-asset: its inherent volatility and available liquidity
Operational resilience: reliability of the execution infrastructure
The relative weight given to each factor may vary depending on the type of client, the asset being traded, the size of the order and prevailing market conditions.
Execution counterparties & liquidity providers
Pay Perform OÜ sources liquidity from third-party trading platforms and OTC liquidity providers. Counterparties are selected based on liquidity depth, pricing quality, operational resilience, settlement reliability, and financial standing.
The primary programmatically integrated liquidity provider for crypto-asset trades against major currencies is B2C2. B2C2 is not a MiCAR-licensed liquidity provider; accordingly, Pay Perform OÜ records the details of each executed order as if it had executed the order itself, in accordance with MiCAR record-keeping requirements.
For trades against exotic currencies, Pay Perform OÜ selects from multiple OTC liquidity providers based on available liquidity, price, speed, and other relevant factors. For larger orders handled by the OTC desk, Pay Perform OÜ may also access exchanges such as Kraken or Binance where they offer a better price, though these are not programmatically integrated.
Pay Perform OÜ does not accept any remuneration, rebates, discounts, or non-monetary benefits for routing orders to any specific liquidity provider or trading platform.
How to place an order
Clients can place orders through two channels:
Client Portal — using the 'Convert' function, clients select the currency or crypto-asset they wish to sell or buy, and the relevant amount. An all-inclusive guaranteed rate (including Pay Perform OÜ's margin and estimated network/gas fees) is automatically presented before the client confirms. Orders are final upon clicking 'Confirm' and are shown as pending in the Client Portal until fully executed.
OTC Desk — clients may place orders off-platform via agreed secure communication channels (Slack, Teams, Zoom). The OTC team sources quotes from one or more providers and selects the best result based on the execution factors above.
Clients should be aware of the following risks specific to OTC execution (i.e. outside a formal trading venue):
Slippage: a difference may arise between the expected price at the time of order submission and the price at which the trade is actually executed
Partial execution: an order may not be fully filled if the price moves away from the order execution price
Order confirmations, including the execution timestamp, executed price, quantity, asset, execution venue, and total fees, are available within the Client Portal. Orders may be cancelled via the Client Portal before execution is complete. Once accepted, orders cannot be edited, a new order must be placed.
How orders are executed
Upon receiving a client order, Pay Perform OÜ typically executes on a matched principal basis with an external liquidity provider. In some circumstances — for example, where Pay Perform OÜ already holds the relevant crypto-asset on its books, where execution via a counterparty is unavailable or would result in unacceptable delay, or where internal execution offers faster settlement — Pay Perform OÜ may execute against its own proprietary capital. In such cases, Pay Perform OÜ's Commercial Policy applies and the client will be explicitly notified.
For standard executions via a liquidity provider, Pay Perform OÜ: (a) purchases the relevant assets from the client; (b) simultaneously initiates a matching sell order with the liquidity provider; (c) credits the resulting assets to the client's balance on the Client Portal; and (d) settles balances at least daily, transferring funds to a safeguarding account in accordance with Pay Perform OÜ's Client Funds and Crypto-Assets Safeguarding Procedure.
Until the regular settlement cycle takes place, the balance shown on the Client Portal represents the client's claim against Pay Perform OÜ for the assets obtained as a result of the trade. All orders are executed sequentially in the order they are received, and clients are promptly notified of any material difficulty affecting the execution of their order.
Monitoring & review
Pay Perform OÜ conducts ongoing monitoring and regular risk assessments of all liquidity providers and execution arrangements to verify they continue to deliver the best possible result for clients. This includes assessment of operational, credit, settlement and market risks associated with each counterparty.
The Operations team may periodically conduct execution analysis, benchmarking Pay Perform OÜ’s execution data against independently sourced data from comparable providers, reviewing metrics such as margins, slippage, order book depth, execution latency, and failed order rates. At least annually, Pay Perform OÜ performs an objective assessment of whether its best execution obligation has been met.
Where deficiencies are identified, Pay Perform OÜ implements corrective actions, which may include replacing liquidity providers or revising execution parameters. Results are reported to the Management Board at least annually.
Demonstrating Best Execution
Clients may request a formal explanation of how Pay Perform OÜ applied this Policy in relation to one or more specific transactions. Such requests should be directed to the Customer Support Team, making clear that a best execution demonstration is required. Upon reasonable request, Pay Perform OÜ will also provide information about the entities to which orders are transmitted for execution.
Pay Perform OÜ maintains detailed records of all executed orders, including pricing data, venue selection, and audit trails, in accordance with its Data and Record-Keeping Policy. These records support prompt and precise responses to queries from clients or competent authorities.
Resources & Support
Resources & Support
NB! Information provided on this website is intended to inform eligible corporate customers about Orbital’s services and does not constitute financial or investment advice. The availability of particular Orbital’s services is subject to jurisdictional and regulatory limitations. Orbital does not recommend buying or selling any particular digital assets and makes no representation on the suitability or reliability of any such asset. Cryptocurrencies are highly volatile and carry significant risks, including potential total loss. Stablecoins carry risks related to issuer solvency, reserve adequacy, and evolving regulatory frameworks.
Orbital is the trading name representing the Pay Perform group of traditional financial and digital asset service providers. Regulatory status of Orbital’s services differs per jurisdiction, and you may not be protected by government or regulatory protection schemes. Please see Legal Disclosures for more information or reach out to us at: hello@getorbital.com
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