Token Admission and Review Policy

Whalefin Markets Limited

Token Admission and Review Policy

Whalefin Markets Limited (“Whalefin”) has established and maintains a comprehensive framework for the admission of virtual assets onto its platform for trading. A summary of our Token Admission and Review Policy is provided here for your reference.

Our Token Admission and Review Committee (the “TARC”) is responsible for maintaining the Token Admission and Review Policy and approving any relevant changes to the policy. The TARC is also responsible for admitting virtual assets on Whalefin’s platform and monitoring admitted virtual assets on a continuous basis.

It should be noted that the considerations and factors outlined in this summary are not exhaustive and do not solely determine the admission of a virtual asset to Whalefin’s platform.

Token Admission and Evaluation Criteria

Whalefin adopts a risk-based approach when evaluating each virtual asset for admission for trading. Please refer to the below for a non-exhaustive list of factors to be considered:

• the background of the management or development team of a virtual asset or any of its known key members (if any);
• the regulatory status of a virtual asset in Hong Kong and whether its regulatory status would also affect the regulatory obligations of the Company;
• the supply, demand, maturity and liquidity of a virtual asset, including its track record, where the virtual asset (except for a security token) should be issued for at least 12 months;
• the technical aspects of a virtual asset;
• the development of a virtual asset;
• the market and governance risks of a virtual asset;
• the legal risks associated with the virtual asset and its issuer (where applicable);
• whether the utility offered, the novel use cases facilitated, technical structural or cryptoeconomic innovation, or the administrative control exhibited by the virtual asset clearly appears to be fraudulent or illegal, or whether the continued viability of the virtual asset depends on attracting continuous inflow into the virtual asset;
• the enforceability of any rights extrinsic to the virtual asset (for example, rights to any underlying assets) and the potential impact of the virtual asset’s trading activity on the underlying markets; and the money laundering and terrorist financing risks associated with the virtual asset.

Ongoing Monitoring

Whalefin will continuously monitor, assess and review each admitted virtual asset to ensure that such virtual asset remains eligible and suitable to be admitted. If Whalefin identifies any major issue with respect to an admitted virtual asset on its platform, Whalefin may issue notifications to its users. Whalefin may also consider suspending or discontinuing the listing of a virtual asset under such circumstances.

Issuers, senior management, and employees are prohibited from dealing with admitted virtual assets if they possess confidential information with respect to the admitted virtual assets until it is made public.

Suspension or Discontinuation of Admission

If Whalefin decides to suspend or delist an admitted virtual asset on its platform, it will provide prior notices to its clients regarding the planned suspension, discontinuation or cancellation. Whalefin will take reasonable and practicable steps to provide opportunities for its clients to manage any risks they may have in relation to the affected virtual assets.

Clients shall withdraw virtual assets from Whalefin’s platform pursuant to the procedures and deadlines prescribed under the notices from Whalefin. If a client experiences any difficulties during the process, it shall contact Whalefin promptly.