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Why TOKO?
We build solutions to solve organisational inefficiencies
Real estate
Structure and tokenise real estate portfolios
Funds
Efficient and liquid funds through tokenisation
Art & media
Create unique digital representations
IP, rights & entitlements
Digitally represent rights and entitlements
Debt & project financing
Structure multi-jurisdictional financing through tokenisation
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Public disclosures
TOKO Virtual Asset Standards
Ensuring regulatory compliance is of utmost importance to our virtual asset platform. We take our responsibility to our customers seriously and have implemented robust processes and procedures to ensure compliance with all relevant factors related to virtual assets as defined by the VA Standards set out by the UAE regulatory authorities.
One of the key considerations we take into account is market capitalization, which provides an indication of the value and popularity of virtual assets. We also consider liquidity and whether metrics have trended downwards over time, which can provide insight into the stability of the market.
We take into account the design, features, and use cases of virtual assets, whether intended by the Issuer or relevant developers, and whether there are features that may materially affect compliance with applicable laws, regulations, rules, or directives, including but not limited to those relating to AML/CFT, sanctions, securities, and intellectual property.
In addition, we consider regulatory treatment by VARA and other appropriate authorities, including whether the issuance of the virtual asset has received any regulatory approvals. We also ensure that we comply with any prohibitions or conflicts of interest that may arise in jurisdictions in which we provide virtual asset activities.
We ensure the security and immutability of the underlying DLT protocol, and consider the future development of virtual assets as communicated by the Issuer and/or relevant developers. Additionally, we take into account whether virtual assets may be susceptible to price manipulation for any reason and implement relevant mitigations.
We consider potential or actual conflicts of interest that may arise should we provide any virtual asset activities in relation to the virtual asset and relevant mitigations. We also evaluate the background of the Issuer, including relevant experience in the virtual asset sector and whether it has been subject to any investigations or claims in relation to fraud or deceit.
Furthermore, we ensure that any represented rights to other assets are enforceable and that sufficient assets are available to satisfy any obligations related to virtual asset activities. We also ensure that our virtual asset terms and conditions reflect, to the extent possible, the operation of any existing underlying physical market and avoid adverse impacts to such market, if applicable. We regularly review our virtual asset terms and conditions to ensure they conform to standards and practices in that physical market, if applicable.
By adhering to these regulations and standards, we provide a secure and transparent virtual asset trading experience for our customers. We understand the importance of regulatory compliance and are committed to maintaining ongoing compliance by regularly reviewing and improving our processes and procedures. Our customers can trust that their virtual asset activities are conducted in a safe and compliant environment.
For additional information, please refer to VA Standards rules, Part VIII of VARA Market Conduct Rulebook.
Conflict of Interests
TOKO FZE is committed to maintain and operate effective organisational and administrative arrangements to identify, monitor and manage any potential or actual conflicts of interest. Should such circumstances arise, TOKO will adhere to its internal Conflicts of Interest Policy (to be reviewed on a regular basis) and tackle such conflicts in compliance with the applicable laws. TOKO FZE will also notify the relevant authorities if necessary.
Please refer to TOKO FZE Conflict of Interest Policy [download]
Whistleblowing
TOKO FZE is committed to developing an integrated framework for whistleblower protection, and ensure that no whistleblower, for reason of having made the disclosure:
- be subject to civil or contractual liability;
- have any contractual, civil, or other remedy or right enforced against them by another person; or
- be dismissed from their current employment, or otherwise subject to action by their employer (or its related parties) that is reasonably likely to cause them detriment.
Please refer to TOKO FZE Whistleblowing Policy [download]
TOKO Broker-Dealer licensed activity
TOKO is applying for Broker-Dealer Services license as a regulated activity under the Virtual Assets Regulatory Authority (VARA) in Dubai, UAE. Dubai’s Virtual Asset Regulatory Authority (VARA) has issued its Virtual Assets and Related Activities Regulations 2023. The Regulations set out a comprehensive Virtual Asset (VA) Framework built on principles of economic sustainability and cross-border financial security: Virtual Assets and Related Activities Regulations 2023.
Currently TOKO FZE does not have any live Virtual Asset offered in the market regulated by VARA. Once live, TOKO FZE will list below characteristics for each Virtual Asset listed on its OTC Broker-Dealer Primary Market Platform:
- name and symbol;
- date of issuance;
- market capitalisation and fully diluted value;
- circulating supply, including as a percentage of maximum total supply [if • applicable];
- whether the Virtual Asset has been subject to an independent smart contract • audit and the date of the most recent audit; and
- largest reduction in price from high to low stated as both an absolute amount • and a percentage change, including when it occurred.
- a description of how TOKO determines the prices of the Virtual Assets it quotes to clients;
- a description of the TOKO’s routing practices, including if twenty percent [20%] or more of client orders are routed to any liquidity source and if so, the identity of such source[s];
- a statement confirming that TOKO does not holds or maintains funds or Virtual Assets or provides clearing services for other VASPs providing Broker-Dealer Services;
- a statement as to TOKO’s arrangements for the protection of clients’ ownership of assets held by TOKO;
- a statement confirming that TOKO does not refer or introduce clients to other Entities such as other VASPs;
- a statement confirming TOKO does not have accounts, funds or Virtual Assets maintained by a third party, with exception of VARA Regulated Custodian partners for the conduct of TOKO business activities as per TOKO Business Plan.
TOKO leverages partners Regulated Virtual Assets Custodian licensed under the VARA Regime to support platform operations and safekeeping of Virtual Assets.
TOKO Exchange licensed activity
TOKO is applying for Virtual Assets Exchange Services license as a regulated activity under the Virtual Assets Regulatory Authority (VARA) in Dubai, UAE. Dubai’s Virtual Asset Regulatory Authority (VARA) has issued its Virtual Assets and Related Activities Regulations 2023. The Regulations set out a comprehensive Virtual Asset (VA) Framework built on principles of economic sustainability and cross-border financial security: Virtual Assets and Related Activities Regulations 2023.
Currently TOKO FZE does not have any live Virtual Asset offered in the market regulated by VARA. Once live, TOKO FZE will list below characteristics for each Virtual Asset listed on its Exchange Secondary Market Platform:
- name and symbol;
- date of issuance;
- market capitalisation and fully diluted value;
- circulating supply, including as a percentage of maximum total supply [if • applicable];
- whether the Virtual Asset has been subject to an independent smart contract • audit and the date of the most recent audit; and
- largest reduction in price from high to low stated as both an absolute amount • and a percentage change, including when it occurred.
- a description of how TOKO determines the prices of the Virtual Assets it quotes to clients.
- details of how Virtual Assets traded over TOKO trading venue are deposited and protected and how clients’ ownership in respect of those Virtual Assets are thereby respected.
TOKO leverages partners Regulated Virtual Assets Custodian licensed under the VARA Regime to support platform operations and safekeeping of Virtual Assets.
Please refer to Non-definitive illustration web page of TOKO Secondary Market listed Virtual Asset page to be further updated in accordance to VARA regulation upon TOKO go live date: [download]
TOKO Corporate information disclosures
- TOKO FZE is incorporated in Dubai under Professional License number L-2465
- TOKO FZE has received Virtual Assets MVP Provisional Approval from VARA – Please refer to DLA Piper and TOKO Press Release. When applicable, TOKO will list out all Virtual Asset Activities that are licensed by VARA to carry out in the Emirate [including any restrictions stated by VARA as a condition of their Licence] and the validity period of such Licences. TOKO is currently in application process for FMP Licenses with VARA.
- TOKO FZE Responsible Individuals – Contact:
- Scott Thiel: scott.thiel@toko.network
- Tim Popplewell: tim.popplewell@toko.network
Other disclosures
- TOKO FZE does make third-party referrals or introductions where monetary or non-monetary benefits are received.
- TOKO FZE partners with a VARA regulated entity, HEX Trust, to provide VA Custody Services.
- TOKO FZE partners with Zand Bank, a fully licensed bank regulated by the Central Bank of the UAE, for our corporate banking needs.
- TOKO FZE’s Board Members and Senior Managers have no past convictions or prosecutions in UAE courts nor other jurisdictions.
How to contact us
If you have any questions about this Public Disclosure information, please contact us by sending an email to contactus@toko.network.