LAST UPDATED: APRIL 27, 2026

Compliance Standards

1. Purpose

These Compliance Standards describe the principles and controls that govern TradeOn’s OTC settlement infrastructure and related services for regulated institutions and professional market participants.

2. Regulatory Posture

TradeOn operates through and alongside licensed payment partners and financial institutions in relevant jurisdictions (including Singapore and Hong Kong). Our framework is designed to support:
Regulatory compliance and supervision
Auditability and evidence-based oversight
Risk management and governance for institutional clients
Specific licenses and regulatory statuses of partners may be provided upon request or in separate documentation.

3. Core Principles

Our compliance framework is built on:
Evidence-first transactions: Every transaction generates a verifiable evidence chain, including timestamps, reconciliation files, and supporting records.
Governance by design: Access, approvals, and workflows are structured to support institutional governance and oversight.
Risk-based controls: KYC, KYB, and KYT measures are applied proportionately to risk.
Audit readiness: Records are maintained to support internal and external audits, regulatory reviews, and legal validation.

4. KYC, KYB, and KYT

We apply:
KYC/KYB: Identification and verification of entities, ownership, and authorized signatories; collection of corporate registration documents and other required information.
KYT: Screening and monitoring of transactions and wallets, including sanctions, adverse media, and other risk indicators.
Ongoing monitoring: Periodic reviews and event-driven updates to reflect changes in risk, ownership, or regulatory requirements.
Clients must cooperate with information requests and notify us of relevant changes.

5. Wallet Governance and Controls

Wallets and settlement endpoints are subject to:
Whitelisting and approval workflows
Role-based access controls and segregation of duties
Logging of instructions, approvals, and changes
Periodic reviews and reconciliations
Clients are responsible for their internal governance over access to our platform and for instructions submitted through their accounts.

6. Evidence Chains and Recordkeeping

For each transaction or workflow, we maintain records that may include:
Timestamps and event logs
Instruction details and approvals
Reconciliation files and settlement confirmations
Screening results and risk assessments
Records are retained in line with legal, regulatory, and contractual requirements.

7. Screening, Sanctions, and Prohibited Activities

We screen counterparties, transactions, and wallets against applicable sanctions and other risk lists. We may:
Request additional information
Delay, decline, or block transactions
Restrict or terminate access
Use of the Services for prohibited or unlawful activities is strictly forbidden.

8. Data Protection and Confidentiality

We implement technical and organizational measures to protect data and maintain confidentiality, subject to legal and regulatory disclosure obligations. Our data protection practices are further described in our Privacy Policy.

9. Incident Management

We maintain processes for:
Identifying and assessing incidents and potential breaches
Containing and remediating issues
Notifying affected clients and, where required, regulators
Clients must promptly notify us of any suspected compromise of credentials or unauthorized use of the Services.

10. Audits and Oversight

Subject to applicable agreements and confidentiality obligations, we may:
Support client audits and due diligence
Provide relevant policies, reports, or attestations
Cooperate with regulatory and supervisory reviews
Any on-site or extended audit activities are subject to prior agreement on scope, timing, and cost.

11. Updates to These Standards

We may update these Compliance Standards to reflect changes in law, regulation, risk environment, or our services. The “Last updated” date indicates the latest revision. Updated versions may be shared via our website or directly with institutional clients.

12. Contact for Compliance Matters

For compliance, legal, or regulatory questions, contact: compliance@tradeon.cc