Investment in cryptoassets is not regulated, may not be suitable for retail investors and the full amount invested may be forfeited.
It is important to read and understand the risks of this investment which are explained in detail in this location.
High-risk investment product
1. The value of investments and the return on investments may fluctuate significantly up and down and the entire amount invested may be lost.
2. Investments in early-stage projects involve a high level of risk, so it is necessary to properly understand their business model.
3. Cryptoassets within the scope of the CNMV Circular are not covered by customer protection mechanisms such as the Deposit Guarantee Fund or the Investor Guarantee Fund.
4. Cryptoasset prices are formed in the absence of mechanisms to ensure their correct formation, such as those present in regulated securities markets.
5. Many cryptoassets may lack the liquidity to unwind an investment without significant losses, as their circulation to both retail and professional investors may be very limited.
6. Distributed log technologies are still at an early stage of maturity, with many of these networks having been created only recently, so they may not be sufficiently tested and there may be significant flaws in their operation and security.
7. The transaction log in networks based on distributed log technologies operates through consensus protocols that may be susceptible to attacks that attempt to modify the transaction log and, in the event of a successful attack, there would be no alternative log to support such transactions and thus the balances corresponding to the public keys, and all cryptoassets could be lost.
8. The anonymity facilitates that cryptoassets make them a target for cybercriminals, as in the case of stealing credentials or private keys they can transfer the cryptoassets to addresses that make them difficult or impossible to retrieve.
9. Amber has engaged the external wallet provider Fireblocks as our crypto asset custodian to safeguard client’s digital assets. Fireblocks is responsible for generating private keys for Amber and its customers. When Amber’s customers create a new account, a unique Fireblocks vault would be automatically assigned to the user with a dedicated key generated by Fireblocks. In the vault, each crypto asset includes one deposit address which is displayed on the user's front-end interface as their deposit address. In addition, risk monitoring and security monitoring are in place to detect any suspicious transaction, working together with external threat intelligence providers. Amber has a service agreement with Fireblocks and we regularly review Fireblock's security posture and compliance status through reviewing their SOC2 Type II report to ensure their compliance of IT and security controls, and additionally review the process and security of their wallet management, including the key management life cycle. The service agreement Amber has with Fireblocks is governed by the laws of the State of New York. Investors may wish to note that Amber is also SOC2 certified (as audited by Deloitte).
10. Assets, the country in which it performs the custody and the applicable legal framework shall be identified.
11. Amber Technologies Limited is not established in an European Union country and the resolution of any conflict could be costly and fall outside the jurisdiction of the Spanish authorities.
12. Investors should note that their crypto assets are held by Amber in custodial wallets. This means that investors do not hold the private keys to those wallets and are consequently not the direct holder of the crypto assets in those wallets. Amber may also use shared blockchain addresses, controlled by the Company, to hold crypto assets of investors. Although Amber maintains segregated books for Investors and their accounts, Amber shall have no obligation to segregate such crypto assets through different blockchain addresses. This setup described above means that investors are likely to be treated as general unsecured creditors in the event of any bankruptcy proceedings.
13. Where the investor does not hold the cryptoassets, being in digital wallets ("wallets") of the service provider, and without access to the private keys of the wallets, this situation shall be indicated and the investor's rights to these cryptoassets shall be described.