Information and Risks identified in relation to crypto-assets
Last updated: 15 May 2026
Effective date: 1 June 2026
1. Informational nature of the event and Site content
MERGE Madrid, MERGE LatAm and the other events organised by Merge Digital SL ("MERGE") are professional gatherings of an informational, training and networking nature focused on digital assets, blockchain, Web3 and the convergence between traditional finance and new digital models.
The talks, panels, presentations, videos and other content published on https://www.mmerge.io or shown during the events do not in any case constitute financial, tax, legal or investment advice, nor a personalised recommendation to acquire, hold or sell any crypto-asset, security or other financial instrument. The opinions expressed by speakers are personal and do not commit MERGE.
Any investment decision must be taken in an informed manner, considering the investor's personal situation and, where applicable, with independent professional advice.
2. Applicable regulatory framework
2.1. Spain and European Union
- Regulation (EU) 2023/1114 on Markets in Crypto-Assets ("MiCA"), fully applicable from 30 December 2024, harmonising the regime applicable to crypto-assets not covered by traditional financial services legislation.
- Circular 1/2022, of 10 January, of the Spanish National Securities Market Commission ("CNMV"), on advertising of crypto-assets presented as an investment, the Annex II of which is reproduced in section 4.
- Regulation (EU) 2015/847 and Regulation (EU) 2023/1113 on information accompanying transfers of funds and of crypto-assets.
- National legislation on the prevention of money laundering and financing of terrorism applicable to crypto-asset service providers.
2.2. Brazil and Latin America
- Law 14.478/2022 (Legal Framework for Virtual Assets) in Brazil, regulating the provision of virtual asset services and granting powers to the Central Bank of Brazil.
- Resolutions and guidance of the Comissão de Valores Mobiliários ("CVM") of Brazil, in particular CVM Resolution 175/2022 and pronouncements on security tokens and public offerings of crypto-assets equivalent to securities.
- Local legislation of each Latin American jurisdiction in which MERGE holds events or has an audience.
3. General disclaimer
The content published on mmerge.io and presented at MERGE events:
- (a) Is purely informational and educational.
- (b) Does not constitute an offer, invitation to contract or personalised investment recommendation.
- (c) May refer to products, services or entities subject to regulation, without this implying endorsement, certification or supervision by MERGE.
- (d) May reflect opinions of third parties (speakers, sponsors, partners) that do not necessarily reflect the position of MERGE.
Before investing in crypto-assets, please carefully read the following warnings and, where appropriate, consult a professional advisor.
4. Annex II of CNMV Circular 1/2022 — Mandatory warnings
High-risk investment product
- The value of investments and the returns obtained may undergo significant variations both upwards and downwards, with the possible loss of the entire amount invested.
- Investments in early-stage projects involve a high level of risk, so it is necessary to properly understand their business model.
- Crypto-assets within the scope of this Circular are not covered by customer protection mechanisms such as the Deposit Guarantee Fund or the Investor Guarantee Fund.
- The prices of crypto-assets are formed in the absence of mechanisms ensuring their correct formation, such as those present in regulated securities markets.
- Many crypto-assets may lack the necessary liquidity to unwind an investment without suffering significant losses, since their circulation among investors, both retail and professional, may be very limited.
Technology-specific risks
- Distributed ledger technologies are still at an early stage of maturity, with many of these networks having been created recently, so they may not be sufficiently tested and there may be significant failures in their operation and security.
- The recording of transactions on networks based on distributed ledger technologies operates through consensus protocols that may be susceptible to attacks attempting to modify such records and, if such attacks succeed, there would be no alternative record supporting such transactions or the corresponding balances of the public keys, and the entire crypto-assets could be lost.
- The anonymity facilities that crypto-assets may provide make them a target for cybercriminals, since if credentials or private keys are stolen they can transfer the crypto-assets to addresses that hinder or prevent their recovery.
- The custody of crypto-assets entails a very significant responsibility, since they may be entirely lost in the event of theft or loss of the private keys. The investor must ensure that they know the entity holding custody of the advertised crypto-assets, the country in which custody is carried out and the applicable legal framework.
Legal risks
- The acceptance of crypto-assets as a means of exchange is still very limited and there is no legal obligation to accept them.
- When the service provider is not located in a country of the European Union, the resolution of any dispute could be costly and fall outside the jurisdiction of the Spanish authorities.
- The investor must ensure that they know the regime of availability and access to crypto-assets and, if held in digital wallets of the service provider without access to the private keys, the investor's rights over such crypto-assets.
5. Additional warnings under MiCA
- The authorisation of an issuer or service provider on crypto-assets under MiCA does not imply any judgement on the suitability of the product or guarantee its profitability. The authorisation refers to compliance with organisational, conduct and solvency requirements.
- Crypto-asset white papers published under MiCA contain essential information on the project and its risks. The investor must read them in full and understand that the content of the white paper is not equivalent to a prospectus approved by a supervisory authority.
- Stablecoins (including asset-referenced tokens and e-money tokens) are subject to a specific regime of reserves and redemption rights under MiCA. Unauthorised or non-compliant stablecoins may not offer these guarantees.
6. Specific warnings for users in Brazil and Latin America
- Investment in crypto-assets in Brazil and the rest of Latin America is subject to evolving regulatory regimes. The presence or promotion of a crypto-asset at MERGE LatAm does not imply authorisation or registration with the Comissão de Valores Mobiliários (CVM) or with the Central Bank of Brazil, nor with the national regulators of other Latin American countries.
- Certain crypto-assets may be qualified as securities (valores mobiliários) under Brazilian law, in which case their public offering requires prior authorisation from the CVM.
- The taxation of crypto-asset operations varies by jurisdiction and is generally being updated. The investor is responsible for compliance with their local tax obligations.
7. Non-exhaustive
This list of risks is not exhaustive. There are other risks not expressly enumerated, including macroeconomic risks, counterparty risks, operational risks, reputational risks and others. The investor must be properly informed and, where appropriate, seek professional advice before making any investment decision.
8. Contact
If you need clarification on the scope of this page or have any observations on the contents published or presented at MERGE:
Merge Digital SL
Calle Gaztambide 57, Local 5, 28015 Madrid (Spain)
Email: [email protected]