1. Scope of the policy

• This policy covers trading in deliverable assets in the over-the-counter (OTC) market when the delivery of an asset via blockchain is implied.
• The policy does not cover on-exchange proprietary trading without any incoming/outgoing transfers.

2. Coin acceptance
Before adding a coin or token to the list of assets available for trading, the following concerns are assessed:

1. Liquidity

• An asset should be listed on major European or US exchanges (such as Coinbase, Kraken, Gemini, Binance, Bitfinex, Bybit. OKX, etc.).
• High liquidity stablecoins, namely average daily volume is above the threshold
• The threshold is $ 10 M;
• The statistics is based on the data from coingecko.com;
• Only volume from Coinbase, Kraken, Gemini, Binance, Bitfinex, Bybit, OKX is taken into account.

3. Privacy

• No privacy coins are accepted.
• No coins with optional anonymity are accepted.

4. Legal & tax

• No security tokens are accepted.
• No other tokens that might be considered a financial instrument are accepted.
• No tokens that might be subject to VAT in Switzerland are accepted.

5. Reputation

• Team members of the coin/token issuer (if applicable) should have a sound reputation.
• Coin\token is not subject to scam / wash trading / pump & dump schemes that might be initiated by the team members of the coin/token issuer.
• Coin\token is recognised by the digital asset industry as a true and valuable asset and, thus, has listing on reputable crypto exchanges.

6. Initial and ongoing monitoring

• Any new coin is subject to the assessment specified above.
• The list of accepted assets is subject to the annual review.
• Ongoing monitoring is carried out to screen mass media for cases of the scam/wash trading/pump & dump schemes that involve a coin/token from the list of accepted assets.

7. Responsible person
The AML officer is responsible for:

• having this policy up-to-date;
• making necessary changes to the list of accepted assets;
• annual review;
• ongoing monitoring.