Order Execution Policy

Effective Date: April 2026

1. Overview

This Order Execution Policy explains how Geloro Pay Ltd executes client transactions involving the conversion of fiat currency and crypto-assets.

The Company is a registered Money Services Business (MSB) in Canada and operates in compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and FINTRAC requirements.

The Company provides crypto-asset conversion services only, specifically:

Fiat currency → crypto-assets
Crypto-assets → fiat currency

The Company does not provide trading, brokerage, investment advice, or portfolio management services.

2. Service Model

Geloro Pay Ltd operates a direct over-the-counter (OTC) execution model for fiat-to-crypto and crypto-to-fiat conversion transactions.

This means:

The Company acts as the principal counterparty to each transaction
Transactions are executed individually (not via an order book or trading platform)
Pricing is provided as a firm quote before execution

The Company does not operate a public exchange or matching system.

3. Non-Custodial Structure

The Company operates on a non-custodial basis, meaning:

The Company does not provide or manage customer wallets
The Company does not store or control private keys
Clients must use their own external wallets for crypto transactions

This structure ensures clients retain full control of their digital assets at all times, reducing custody-related risk.

4. How Orders Are Executed

When a client initiates a transaction:

The client requests a quote
A real-time price is displayed (including fees and spread)
The client confirms the transaction
The order is executed immediately after confirmation

Execution may involve:

Internal liquidity (Company inventory)
External liquidity providers and regulated counterparties

All execution is based on prevailing market conditions at the time of confirmation.

5. Pricing and Best Execution

The Company aims to provide fair and competitive pricing based on:

Market liquidity
Transaction size
Execution speed
Network and settlement conditions

Clients receive:

Transparent, upfront pricing
No hidden fees
Clear breakdown of spreads and costs

Once a transaction is confirmed, the price is fixed.

6. Settlement Process

Settlement depends on transaction type:

Crypto transfers: processed on blockchain networks after confirmation
Fiat transfers: processed through regulated banking partners

Typical settlement times vary depending on network and banking conditions.

7. Risk Disclosure

Clients acknowledge that crypto-asset transactions involve risks, including:

Market volatility
Blockchain network delays
Liquidity fluctuations
Potential loss of access to wallets if private keys are compromised

The Company does not guarantee:

Investment returns
Asset price stability
Continuous availability of services

Clients are solely responsible for their transaction decisions.

8. Execution Limitations

The Company may, where necessary:

Refuse or delay a transaction
Request additional verification (KYC/AML checks)
Cancel transactions in cases of extreme market conditions or compliance requirements

These measures are required to comply with legal and regulatory obligations.

9. Conflicts of Interest

As the Company acts as principal in transactions, it may have inherent commercial interests.

To manage this, the Company ensures:

Transparent and consistent pricing
Uniform treatment of clients
Internal compliance oversight
No preferential treatment between clients

10. Compliance and Regulation

The Company operates under strict regulatory obligations, including:

FINTRAC MSB registration requirements
Canadian AML/CTF legislation (PCMLTFA)
Sanctions screening and monitoring
Ongoing transaction monitoring

Suspicious activity may be reported to relevant authorities as required by law.

11. Contact

For questions regarding this policy:

📧 support@octapex.com

🌐 https://octapex.com

📍 1055 West Georgia Street, Suite 2100, Vancouver, BC V6E 3P3, Canada