What Galaxy Digital Inc. told the SEC could break it.

Earnings and balance sheet are highly sensitive to digital-asset prices (largest holding is bitcoin); a +/-20% move in digital-asset prices would change the Treasury/Corporate portfolio by +/-$184.0 million (FY2025).

“Management's estimate of the effect of digital asset price risk on our Treasury and Corporate digital asset portfolio due to a +/- 20% change in the market prices of digital assets, with all other variables held constant, was +/- .0 million and .3 million as of December 31, 2025 and December 31, 2024, respectively.”

Subject to Bank Secrecy Act AML obligations (SAR/FinCEN reporting, KYC/customer due diligence) and a patchwork of state money-transmission/digital-asset licensing regimes, plus SEC Advisers Act and swap-dealer rules.

“As part of our obligations under the Bank Secrecy Act (“BSA”), we are required to develop, implement, and maintain a risk-based anti-money laundering program, provide an anti-money laundering-related training program, report suspicious activities and transactions to FinCEN, comply with certain reporting and recordkeeping requirements, and collect and maintain information about our customers.”

Certain operations are headquartered in Tel Aviv, Israel (~75 employees, some with military-reserve obligations), exposing those operations to Middle East conflict risk.

“Furthermore, certain Galaxy operations are headquartered in Israel, with primary offices located in Tel Aviv. Approximately 75 Galaxy employees are physically located in Israel, a number of whom have military reserve service obligations.”