nealthy - digital asset management

Virtual Asset Standard and Listing Policy

Version: 1.1
Last revised: 24. October 2023

1. Introduction

1.1 Purpose

As the market for Virtual Assets grows and matures globally, nealthy FZCO (hereinafter referred to as “the Company”) strives to bring the global Virtual Asset market to its customers. Our commitment is to maintain the highest standards in providing virtual assets services to our customers. As such, In the ever-evolving world of Virtual Assets, the importance of diligent management and compliance with regulatory norms cannot be overstated. The Company has established its Virtual Asset Standards, crafted in accordance with VARA's regulations. This thorough framework serves as a guiding principle for assessing and dealing with VAs, ensuring they align with both regulatory mandates and the highest industry standards.

1.2 Scope

This is applicable to all virtual asset activities and operations conducted by nealthy.

2.VA Standards

In accordance with the Virtual Assets Standards, nealthy has established comprehensive standards for all virtual assets offered on its platform. These standards, referred to as the VA Standards, form the basis for assessing and managing virtual assets. nealthy is committed to taking all reasonable steps to ensure that VAs listed on its platform meet these standards, including conducting thorough due diligence, as outlined below.

  1. Market Analysis: Evaluating the market capitalization, fully diluted value, liquidity, and historical trends of these metrics.
  2. Design and Utility: Assessing the design, features, and practical applications of Virtual Assets, regardless of the original intentions of the Issuer or developers.
  3. Compliance Impact: Determining whether certain features could significantly influence nealthy’s ability to comply with existing laws, regulations, rules, or directives. This includes areas such as AML/CFT, sanctions, securities, and intellectual property rights.
  4. Regulatory Status: Reviewing the regulatory treatment by VARA and other relevant authorities, including those outside the Emirate, and whether the Virtual Asset has received any regulatory approvals.
  5. Prohibitions: Checking whether any Virtual Asset is banned by VARA or other authorities, both within and outside the UAE, in jurisdictions where we offer Virtual Asset activities.
  6. Technology Integrity: Analyzing the security and immutability of the Digital Ledger Technology (DLT) protocol underpinning the Virtual Asset.
  7. Development Trajectory: Considering the future development plans or 'roadmap' as communicated by the Issuer and/or developers.
  8. Market Manipulation Risks: Identifying susceptibility to price manipulation and nealthy will outline its mitigation strategies accordingly.
  9. Conflict of Interest: Assessing potential or actual conflicts of interest in providing VA activities related to the Virtual Asset and the corresponding mitigations.
  10. Issuer Background: Investigating the history of the Issuer, including their experience in the Virtual Asset sector and any past investigations or allegations of fraud or deceit.
  11. Asset Rights: If the Virtual Asset represents rights to other assets, evaluating the enforceability of these rights.
  12. Asset Availability: Ensuring sufficient assets are available to meet obligations related to VA activities.
  13. Market Correlation: Ensuring that the terms and conditions of Virtual Assets, where applicable, reflect the operation of any underlying physical market and do not adversely impact it.
  14. Periodic Review: Periodically review the terms and conditions of Virtual Assets to ensure they remain appropriately correlated with any physical market, adhering to standards and practices of that market.

3. Virtual Asset Listings

The above VA Standards are designed to offer a detailed structure for assessing and handling Virtual Assets, ensuring they align with both regulatory mandates and the highest industry standards. As such, nealthy has crafted a unique Virtual Asset Listing Policy, drawing from these standards, and adheres to it rigorously before proceeding with Asset Listing.

At a high-level, we take the following into account when listing assets:

  • Idea Generation by Product Development Team: Our product team is dedicated to identifying potential Virtual Assets (VAs) for our listings. This involves a thorough process of gathering essential information and documents, as well as conducting a preliminary evaluation of each asset (as outlined in the VA Standards, above).
  • Legal and Compliance Analysis: Our legal and compliance teams meticulously examine each VA application against our listing standards, as well as relevant regulatory and legal frameworks.
  • Management-Level Evaluation: Post-review, VAs that meet our criteria are escalated to our senior management team for a final round of evaluation and decision-making.
  • Approval and Listing: Following internal approval, and ensuring adherence to all necessary regulatory requirements, the VA is officially listed on our platform.
  • Continuous Oversight: Once listed, we actively monitor each VA to guarantee ongoing compliance with regulatory, legal, and internal standards.
  • Delisting: nealthy has established specific criteria for the potential suspension of Virtual Asset (VA) Activities. This includes situations where a Virtual Asset fails to comply with established VA Standards.
  • Record Retention: We maintain all records relevant to VA Standards and Listing assessments for eight [8] years.