Listing Process on Blocktrade

Preliminary

Blocktrade will, as a general rule, review and respond to all applications.
If successful, the details of the integration timeline will be shared with you.

Listing Process on Blocktrade

General

Until the process is finished, the applicant is not to disclose neither the application itself, nor the current stage in the process. Blocktrade reserves the right to disqualify such applications and terminate the process, especially if such an announcement is conducted in a misleading fashion.

You will be asked to sign an NDA.

Applications are processed on “first in, first out” principle. Blocktrade does not guarantee a fixed date until when a decision is taken. You can contact your account manager in urgent cases, however, this will not speed up the review process. Unsolicited re-applications will not be reviewed.

Be careful with phishing attempts and/or impersonation fraud. Do not pre-transfer any funds until you have received a confirmation through official channels. All external announcements regarding listing decision are to be approved by Blocktrade.

If selected for listing, you will be asked to sign a listing contract. The signature thereof is a precondition for the listing itself. Blocktrade reserves the right to delist a coin/token for any reason. In such case, a sufficient period of time will be allowed for withdrawals of the delisted coin/token.

Any questions about the listing process can be addressed to [email protected]

Listing Application

Please submit the initial form of listing via this form:

https://forms.office.com/r/NAzgNx4u7K 

Token issuer information and due diligence

The applicant must supply information and evidence documenting the below.

3.1. Minimum requirements

The applicant must satisfy the following minimum requirements:

  • Public team with no criminal record, known company address, registration in the respective company register (must have a LEI (legal entity identifier)). Incorporated in at least an A-country or equivalent,
    • Deviations from the above-mentioned requirements are possible, but need
      a separate approval (DAO token etc), contact
      [email protected].
    • Sharing individual LinkedIn profiles (or equivalent)
    • Agreement to share new updates, concerns etc
      (some form of written agreement)
  • An extensive business plan, including financial statements and assessment of capital adequacy (solvency and liquidity projections) for further development, if necessary
  • A working prototype, i.e. Minimum Viable Product at least in public beta
  • Long-term intention to stay with the current token standard, i.e. no token swaps to native mainnet,
  • Public token smart contract (verifiable token burns, lockups, fixed total supply, allocation to team etc.)
  • Demonstrated adequate KYC/AML processes during initial coin offering. Must supply terms of the initial coin offering.

3.2. Due diligence on stakeholders

Token project representatives must initiate an onboarding process dedicated to token issuers and pass KYC procedure as a part of fit and proper examination.

Investigation on the project’s stakeholders must be conducted:

  • Do they have properly assigned roles?
  • Do they have the necessary experience and engineering capabilities?
  • Can they conduct proper community management?
  • What is the experience, stability and track record of the project’s leadership? What is the duration of key personnel’s involvement? Were there notable changes in the leadership? Is there a risk of reliance on a single person or entity for leadership?
  • Does the project’s team have sufficient size, adequate structural organisation and development experience?
  • What is the degree of centralization of the engineering team?
  • What is the identity of other stakeholders in the project? Is there support from traditional financial institutions, venture capital firms or notable industry specialists?
  • What is the size and activity of the project’s community? Who is interested in buying such digital asset? In which jurisdictions does the public reside?
  • What is the nature of community management, the responsiveness of the team and their methods of issue resolution?

3.3. Due diligence on business and economics

  • Does the project have a solid and sustainable business aspect?
  • What are the key functions, benefits and utility resulting from holding or spending the project’s assets within or outside the network?
  • Is the size of the addressable market sufficiently large to enable scalability and network effects?
  • What are the key business risks, state of the competition and advantages of the project compared to both direct competitors and traditional market infrastructure?
  • What is the structure and transparency of the mechanisms for raising, rewarding and allocating funds for future development?
  • Are there resources for the project’s funding to realise its long-term goals?
  • Does the project feature appropriate incentives to ensure alignment of stakeholder interests while minimizing potential conflicts of interest?
  • Can the project’s team or other contributors hold substantial material interest in the project?

3.4. Legal and regulatory

  • What is the project entity type? Incorporation deed, business register excerpt must be provided
  • What is the area of activity?
  • What are the UBO(s) and controlling persons of the token issuer?
  • What is the description of the executive team?
  • Is the token a “privacy coin” or anonymity enhanced cryptocurrency?
  • Does the network allow ‘tumbling’, ‘mixing’, or similar obfuscation of tokens?
  • Legal opinion required, stating whether the digital assets are characterised as a commodity, utility token, currency, or stablecoin, or else
  • Audits required for stablecoins:
    • publicly available financial audit reports required for stablecoins, demonstrating adequate collateralization if the assets are pegged to an external value,
    • peer-reviewed code audits for algorithmic stablecoins
  • Is the proposed asset deemed a security? – regulatory analysis under Estonian (and soon, Italian) law must be provided
  • What are the restrictions associated with the digital asset? Is it prohibited under some jurisdictions? Is it excluding some categories of persons?
  • What is the list the exchanges, if any, that support the token?
  • What is the list of wallets and any other material services that support the token?
  • How can the token be purchased, earned, exchanged, or otherwise obtained?
  • What is/are the primary utility purpose(s) of the token?
  • What is the current state of the token development? What are the plans for further development?
  • What is the token issuer’s ongoing role, if any, in the development, promotion, or function of the network?
  • Is the token issuer’s involved in supporting the market for, or price of, the token (e.g., limiting the token supply, buybacks, burning, controlling the creation and issuance of additional tokens, or similar)?
  • Is the token issuer able to earn or derive revenue from the network?
  • Does the token issuer own any intellectual property (e.g., patents, trademarks, service marks, tradenames, copyrights, trade secrets, domain names, mask works, or applications related thereto) related to the token or network?
  • Do unaffiliated third parties assist with the development of the network or perform essential tasks or responsibilities (e.g., GitHub pull requests, merge, and contributor information)?
  • What are the number of:
    1. daily active users;
    2. DApps or projects built on a chain;
    3. transaction volume;
    4. any other quantitative data that supports the use of the network and token
  • How are token holders entitled to receive payments, additional tokens, interest, or other consideration by virtue of holding such tokens?
  • If tokens be earned by staking, description of the staking process required.
  • Information about any user, growth, and/or social metrics required
  • What are the governance rights, if any, and what are the token holders entitled to?
  • Are token holders able to suggest and/or implement changes to the network without the token issuer’s consent? Examples and description required.
    (For Blocktrade to assess)
  • Are there potential or existing conflicts of interest that could induce a risk of:
    • Not complying with legal or regulatory obligations
    • Not fulfilling duty of care
    • Not observing professional judgement and objectivity
    • Engaging in unethical behavior and/or
    • Obtaining improper advantage or treatment or cause the appearance of impropriety and reputational damage.

3.5. Compliance – Anti-money laundering

  • Does the project allow Blocktrade to be in compliance with the relevant AML obligations it is subject to and to fulfill the relevant reporting obligations towards financial regulatory authorities?
  • Is the digital asset implemented on TRM (or transaction monitoring third-party tool of Blocktrade) and subject to screening?
  • Annual attestation of AML/CTF compliance program from a third-party will be required ahead of listing and on a yearly basis
  • Is the project/company regulated in any jurisdiction? please state the jurisdiction(s), names of regulatory entities, and licensing information
  • Has any of the project’s stakeholders / executive team members ever been the subject of a law enforcement action or regulatory investigation?
  • Have or is any of the project’s stakeholders / executive team members currently facing any formal lawsuits?
  • Do the project’s stakeholders / executive team members have relationships with regulated financial institutions?
  • Is custody available or are there plans to be offered by any custodian?
  • Do the project’s stakeholders actively participate in trading and market making?
  • Is the price or value of the digital asset dependent or influenced by another token or project?
  • If the digital asset is ERC-20, is it planned to migrate to a different chain in the future?
  • Is the transparency of the network deemed sufficient? Is there an option allowing for unrestricted visibility by the way of blockchain monitoring and forensics tools?
  • Are the network and assets used for the purpose of illegal activities, dark web activity or for the circumvention of any regulations?
  • Are there tools facilitating the blacklisting of addresses on the network?

 

3.6. Digital asset information

The applicant must supply accurate coin/token information, including,
but not limited to:

  • Smart contract code (must be verified by a blockchain explorer, if applicable)
  • Code audit (if applicable) – should we state a few auditors we accept?
    not limited to though.
    • Open source or closed source
    • Eth blockchain (erc20) or other
  • Public Whitepaper
  • Well-developed token economics
    • Total token supply, if applicable
    • Ready supply
    • Who holds the majority of the tokens + vesting periods?
    • Pre mined?
  • Any existing legal opinions on the nature of the coin/token from any jurisdiction
  • ICO/TGE information
    • Soft cap/hard cap
  • Trading information
    • Liquidity information
    • Market cap
  • Development stage:
    • Still funding of in a more advanced stage?
    • Anything released (app, website, platform etc)
  • Real world application
    • USP´s (unique selling points)
    • Does it solve a real world problem or have some sort of other application
      (if applicable)
  • Active community
    • Social media presence
    • Developer support
  • Funding method
    • ICO or IDO
    • Specific details

Prohibited and restricted areas of activities

Prohibited:

  • “Non-standard” or “non transparent” activities – carried out through special-purpose or assimilated legal entities (special purpose vehicles) (structures) or in jurisdictions that impede transparency;
  • Bidding fee auctions, penny auctions, or any type of all-pay auction in which all participants must pay a non-refundable fee to place each small incremental bid;
  • Shell banks (banks based in countries where they have no physical presence involving decision-making and management and which are typically not connected to wider regulated financial groups);
  • Shell companies (a company with no physical presence involving effective decision-making, operations or assets other than cash or equivalents of cash);
  • Bearer share corporations and companies connected to nominee or similar arrangements for the purpose of hiding or mask the true beneficial ownership
  • Adult services – this includes physically and non-physically adult services, regardless of whether it is legal in the specific country involved;
  • Any involvement in the sale or marketing of binary options;
  • Any involvement in the sale or intermediation for weapons of war, automatic weapons, ammunitions or defence equipment.

Restricted:

  • Any business involved with the sale of medication or drugs. These businesses must possess the appropriate licenses in the jurisdictions where they are established, or sell products into.
  • Charities, social service organisations and other non-profit or political organisations. These businesses must:
    • be registered, or local equivalent, in the country of incorporation,
    • not be located in high-risk countries, not sponsor or support any act of violence or hate.
  • Any business involved in gambling. These businesses must:
    • Any business involved in gambling. These businesses must:
      be incorporated in EEA (additional countries may only be accepted with explicit approval from Blocktrade’s Compliance department),
    • only perform the following activities: online gambling, betting, poker, sport, horse racing, skill games, casino, lottery, arcade;
    • have a relevant license (as required) where they are established or provide services to, including by means of a website in a country-specific language;
    • be registered on the local countries gambling commission;
    • be established more than five years;
  • Any business involved in import/export and cross-border logistics companies including maritime and land based shipping.
    These businesses:
    • must exercise supply chain due diligence to ensure that recipients and counterparties to a transaction are not sending or receiving commodities that may trigger sanctions.
    • may not have activities involving prohibited countries,
    • may not deal with prohibited goods or counterparties.

Contact

For inquiries: [email protected].

Disclaimer:

No review or approval of plans, specifications or other information or documentation by applicant Companies shall constitute a representation or warranty by Blocktrade that such plans, specifications or other information or documentation satisfy any applicable laws or other requirements or will provide for a safe and/or prudent operation, and no such review or approval shall make Blocktrade.com otherwise liable with respect thereto. Company shall be solely responsible for determining whether its plans, specifications, construction and maintenance meet its needs, satisfy applicable laws and other requirements and will provide for a safe and prudent operation.

Applicant Company shall furnish Blocktrade with all financial and other information and data as Blocktrade reasonably believes appropriate and necessary in order to perform pre-listing assessment, and shall provide Blocktrade access to the principals, managers, officers, directors, employees and professionals (including counsel, accountants and consultants) of applicant Company. Applicant Company acknowledges that, as between applicant Company and Blocktrade, Blocktrade: (1) shall be entitled to rely without investigation upon all information that is available from public sources or supplied to it by applicant Company or any advisor of applicant Company; (2) shall not be responsible for, and need not verify, the accuracy, completeness or sufficiency of the information described in the foregoing clause (1); and (3) shall be entitled to assume that all projections made available to Blocktrade will have been prepared in good faith. Applicant Company acknowledges to promptly notify Blocktrade in writing if it learns of any material inaccuracy or misstatement in, or material omission from, any information previously delivered to Blocktrade.