A. General Description of Advisory Firm 1. Galaxy Digital Capital Management LP Galaxy Digital Capital Management LP, “GDCM”) is a Cayman Islands exempted limited partnership formed on November 30, 2017. Our principal office and place of business is at 300 Vesey Street, 13th FL, New York, New York. GDCM commenced operations in March 2018 as an exempt reporting adviser; and registered, effective July 2019, as an investment adviser with the United States Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Galaxy Vision Hill Asset Management LLC (“GVHAM”), a Delaware limited liability company formed on February 1, 2018, is a relying adviser of GDCM. For purposes of this Brochure, “Adviser”, “we”, and “us” refer to both GDCM and its relying adviser unless otherwise indicated. 2. Ownership of the Adviser GDCM and its general partner, Galaxy Digital Capital Management GP LLC (the “Adviser General Partner”), a Cayman Islands exempted limited liability company, and GVHAM are controlled by Galaxy Digital LP (“GD LP”), a Cayman Islands exempted limited partnership. GD LP is an operating company and its sole limited partner is Galaxy Digital Holdings LP (“GDH LP”), a Cayman Islands exempted limited partnership. GDH LP’s general partner is Galaxy Digital Holdings GP LLC, a Cayman Islands exempted limited liability company. GDH LP has two classes of units representing limited partnership interests: Class A Units and Class B Units. Class A Units of GDH LP are held by Galaxy Digital Holdings Ltd. (“GDH Ltd.”), a Cayman Islands corporation, and its wholly owned subsidiary, GDH Intermediate LLC, organized in Delaware. GDH Ltd. is a publicly traded company whose shares are listed on the Toronto Stock Exchange (TSX) under the symbol “GLXY.” Class B Units of GDH LP are held by three groups of shareholders: (i) Galaxy Group Investments LLC (“GGI”), a Delaware limited liability company, owned 100% by Michael Novogratz and his family members; (ii) employee founders of GDH LP; and (iii) former First Coin Capital Corp. shareholders. In May 2021 GDH LP announced that, subject to shareholder approval, GDH Ltd. expects to effect a reorganization and domestication whereby GDH Ltd. shares will be converted into and exchanged for stock in its successor entity, Galaxy Digital Inc., a Delaware corporation (“GD Inc.”). In January 2022, GDH Ltd. and GD Inc. publicly filed a registration statement to the SEC for the public offering of shares of GD Inc. in the United States. As indicated on Form ADV Part 1A, the principal owner of the Adviser and GDCM’s General Partner, through the organizational structure described above, is Mr. Novogratz (the “Principal Owner”). The Principal Owner is not generally involved in the day-to-day operations of the Adviser. 3. Affiliates of the Adviser The Principal Owner, GD LP, GDH LP and GDH Ltd., through affiliates and subsidiaries (collectively, “Galaxy Digital”), have interests in certain other entities described in this Brochure (including in Item 10.C), and are seeking to build a full service, institutional-quality merchant banking business in the Digital Assets1 (as defined below) space. Currently, Galaxy Digital intends to capitalize on market opportunities made possible by the ongoing evolution of the cryptocurrency space through three primary business lines: Global Markets, Asset Management and Digital Infrastructure Solutions. Galaxy Digital may add or discontinue business lines at any time, and expects its business to continually evolve given the rapidly developing cryptocurrency space. Certain senior officers of the Adviser also are senior officers of Galaxy Digital. As discussed below, the Adviser has assumed management of the Galaxy Principal Investments Portfolio (as defined below), which has previously been managed separately from the Adviser by the Galaxy Digital principal investments team. The Adviser’s facilities and personnel are provided by an affiliate, Galaxy Digital Services LLC, a limited liability company organized in Delaware and wholly owned by GD LP. B. Description of Advisory Services This Brochure generally includes information about us and our relationships with our clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information applies to specific clients or affiliates only. We are an investment management firm that provides advisory services on a discretionary basis to privately offered pooled investment vehicles (including funds of funds (i.e., funds that seek to achieve their investment objective(s) by investing substantially all of their assets in private funds managed by third party investment managers and/or our affiliates)), which are intended for investment by certain investors (“investors”) that are accredited investors under Rule 501 of Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), and Managed Accounts (as defined below). Investors in certain of these vehicles that we manage are also required to be qualified purchasers under Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment Company Act”) or “knowledgeable employees,” as defined under Rule

3c-5 of the Investment Company Act so as to comply with the exemption under Section 3(c)(7) of the Investment Company Act. Certain investors in pooled investment vehicles and Managed Account clients are also required to be qualified clients under Rule 205-3 of the Advisers Act. We do not limit our investment advice to only certain types of investments. The Adviser and its affiliates also provide management services to accounts that do not invest in securities, including accounts that only invest in Bitcoin (BTC) or Ether (ETH), as described in further detail below in Item 10.C. Such services are not provided by the Adviser in its capacity as a registered investment adviser and are not subject to the Advisers Act. In addition, the Adviser provides management services to other accounts, including the Crypto Index Fund (as defined below) that, due to their investment strategy, do not constitute “securities portfolios” and are therefore not included in the calculation of the Adviser’s regulatory assets under management. Additionally, the Adviser and its affiliates may in the future provide advisory services on a non-discretionary basis to certain clients. Our “clients” include private investment funds (collectively referred to herein as the “Funds,” and each, individually, a “Fund”) and Managed Accounts which pursue the investment strategies described below in 1 “Digital Assets” means cryptographically derived digital assets, referred to as cryptoassets, cryptocurrencies, and/or blockchain tokens, virtual currencies or digital currencies, such as Bitcoin (BTC), Ether (ETH), or Solana (SOL), as well as other assets available on public, private or permissioned blockchains and/or ledger systems, including decentralized application tokens and protocol tokens, and other digital assets that are based on a cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and/or (iii) used as a medium of exchange, store of value, and/or represent ownership in some asset, interest or object, whether real or intangible. Item 8. Our clients also include special purpose vehicles which the Funds invest in, or alongside, with Fund investors and third-party investors. The Adviser and the Fund General Partners (as defined below), in their sole discretion, also provide co-investment opportunities to other funds, private investors, groups or individuals, including Fund investors (or their affiliates). In addition, subject to the compliance policies of the Adviser and GD LP, the General Partners’ or the Adviser’s affiliates, principals, officers, and employees make investments that are also appropriate for the Funds and, at certain times, simultaneously seek to purchase or sell, including in their individual capacities, the same or similar investments for the Funds. Finally, in addition to the assets maintained on behalf of clients, the Adviser has assumed the management of a portfolio of principal investments held and beneficially owned by the Galaxy Related Parties (as defined below) (the “Galaxy Principal Investments Portfolio”). In addition, in 2023 the Adviser was appointed by FTX Trading Ltd. and its affiliated debtors and debtors in possession (collectively, “FTX”) to manage certain assets of the FTX bankruptcy estate. Under the investment management agreement with FTX (as approved by the bankruptcy court), the Adviser is authorized to sell, transfer and stake certain Digital Assets and other instruments held by the FTX bankruptcy estate and to enter into certain hedging arrangements with respect to such assets. Please see Item 6 for details on potential conflicts of interest arising in the context of co- investments and managing different accounts side-by-side. We provide our investment advisory services to the Funds in part through special purpose entities established to be the general partner or managing member of such Funds (the “Fund General Partners”). The Fund General Partners operate under our supervision and control and are subject to our compliance program. C. Availability of Customized Services for Individual Clients Our advisory services are provided to the Funds, pursuant to the terms of the Funds’ relevant offering documents and based on the specific investment objectives and strategies as disclosed in the offering documents. The advisory services each Fund receives are tailored to its individual needs, specified investment objectives and strategies as set forth in each Fund’s offering documents. The Funds may impose restrictions on investing in certain types of Digital Assets and other instruments in accordance with achieving their investment objectives and strategies. Otherwise, there are no material restrictions on the types of investments and/or strategies we may employ for our clients. We also offer investment advice to a limited number of clients that are separately managed accounts (“Managed Accounts”). The investment objectives and guidelines of such Managed Accounts are determined in conjunction with the applicable client. D. Wrap Fee Programs We do not currently participate in any Wrap Fee Programs. E. Assets Under Management As of December 31, 2023, we manage approximately $3,649,532,477 in regulatory assets under management on a fully discretionary basis. We do not manage any clients’ assets on a nondiscretionary basis as of such date.