Virtual Asset Standards

WB Fintech Development FZE (the “Company”) will, through the Company’s governance framework, ensure that it maintains effective and appropriate measures, procedures and internal controls to identify, assess, monitor the compliance of Virtual Assets (hereinafter - “VA”) present on the platform with VA standards introduced by Virtual Assets Regulatory Authority (hereinafter - “VARA”).

As a regulated entity, the Company will ensure that the methodology, policies, procedures and controls applied to identifying and managing any risks associated with VA will be commensurate with the requirements under the relevant regulations, laws and guidance, and will take all reasonable steps including, but not limited to, conducting relevant due diligence to ensure all VAs meet its VA Standards before, and at all times during, the Company provides any VA Activities to such VAs. 

These VA Standards are subject to disclosure on the Company’s website.

The Company implements a risk-based classification framework, categorizing virtual assets into different tiers based on market volatility, liquidity, regulatory treatment, and susceptibility to manipulation. Each category is subject to specific governance, monitoring, and risk mitigation measures.

Issuers are required to provide detailed and accurate information regarding the virtual asset, including tokenomics, underlying technology, governance structure, and associated risks. The Company ensures that this information is available to users through the platform and is updated regularly.

To ensure compliance with applied regulations, as well as meeting the VA Standards, the following considerations will be undertaken concerning the relevant VAs:

  1. Market capitalization, fully diluted value and liquidity, and whether such metrics have trended downwards over time. These shall cover without limitation: application of clear, reasonable and unambiguous calculations of market capitalization, fully diluted value, and liquidity of the VA in the relevant market; adequate identification of any factors, concerns and issues that could impact the mentioned metrics; regular assessment of any significant changes and/or updates in the introduced metrics and/or approaches to their calculations, with further disclose, if any.
  2. Design, features and use cases, whether or not intended by the Issuer or relevant developers. These shall cover without limitation: analysis and assessment of technical design, features and usability of the intended VA; evaluation of any potential risks arising from the design, use cases,  and purported or unintended misuse of the VA by any of the stakeholders.
  3. Risks of material adverse effect of any VA’s features on the Company’s compliance with applicable laws, Regulations, Rules or Directives, including but not limited to those relating to AML/CFT, sanctions, securities, and intellectual property. These shall cover without limitation: continuous and regular review of actual legal, and regulatory requirements and implementation of solid compliance processes aiming to promptly address any upcoming changes and/or potential issues arising from the updated regulatory and/or legal requirements; performance of advanced compliance processes and strategies to ensure strict AML/CFT controls in place, as well as observance of sanctions, securities, and intellectual property laws.
  4. Regulatory treatment, in particular, whether the issuance of the VA has received relevant regulatory approvals. These shall cover without limitation: assessment and recording of the applied regulatory treatment with respect to the relevant VA; regular monitoring of any updates and changes in the regulatory status of the relevant VA, and if required - introducing appropriate measures to address the upcoming changes in fully compliant manner; ensure obtaining and holding valid of all the necessary regulatory approvals, if required.
  5. Prohibition of VA in any jurisdiction. This includes: identification, regular monitoring and recording of whether relevant VA is prohibited by VARA, other regulators in any other jurisdictions; implementation of policies, which clearly prohibit the listing, trading or any other related activities regarding the prohibited VA in all jurisdictions concerned.
  6. Security and immutability of the underlying DLT protocol. This shall be analyzed as a part of the technical assessment of the VA in the course of obligatory due diligence, in conjunction with all the measures designed to address any potential issues to the protocol integrity, if any.
  7. VA Roadmap. It shall be clear, adequate, up-to-date, and unambiguously communicated by the VA developers.
  8. Susceptibility to price manipulation. This shall cover without limitation: assessment and evaluation of the risks of price manipulation, its reasons and relevant mitigations available; implementation and regular review of the implemented measures, their updates, if necessary.
  9. Existence of conflict of interests. This shall cover without limitation: assessment and evaluation of the risks of potential conflicts of interests; identification of any actual conflicts of interests and their disclosure, if any; implementation of clear and effective processes to timely and adequately identify and address any potential conflicts of interests for the avoidance of unfair business and market practices.
  10. Issuer’s background, experience, good standing. This shall cover without limitation: due diligence analysis of the issuer’s team, their experience, qualifications, and proven skills, check of investigations, litigation, claims history, and criminal liability records, in particular, with regard to fraudulent and/or deceit accusations, check on negative media references.
  11. Enforceability of the VA-associated rights. In case if VA represents rights to any other assets, the enforceability of such rights shall be checked, assessed and disclosed.
  12. Availability of sufficient assets. This is subject to periodic verification, and sufficient measures to timely identification and address of any potential issues shall be developed and implemented.
  13. Adequacy, relevance and review of the VA terms and conditions. This is subject to periodic review, monitoring and, if required, updating of the relevant terms to sustain compliance with actual physical market standards, practices, and operations as well as with all applicable regulations.

The Company will perform the relevant assessments to ensure VA’s compliance with VA Standards on an ongoing basis. The Company will maintain all records relevant to such assessments for eight [8] years and provide such records for VARA’s inspection upon request.

The Company will promptly notify VARA upon becoming aware that a VA no longer meets VA Standards and shall take such steps as VARA may direct to minimize any adverse impact on clients arising as a result. Moreover, the Company will assist VARA and implement all relevant measures in case if VARA:

  • set conditions under which VA Activities in relation to a VA may be suspended, including where a VA no longer meets its VA Standards;
  • require the suspension of a VA Activity in respect of any VA upon reasonable grounds it deems appropriate.

The detailed procedures of applying the above-mentioned standards are subject to the Company’s Listing Policy, which specifies without limitation detailed rules, conditions, and terms of issuance of particular VA on the platform, as well as conditions for their suspension, including where a VA no longer meets its VA Standards or other grounds for delisting, are arisen; necessary operational procedures and controls in the event such conditions are met.