The Exchange allows Participants to execute Virtual Currency purchase and sale Transactions in real-time with other Virtual Currencies. The Exchange will be available to both retail and institutional customers, and will offer real-time price discovery and trade execution in Virtual Currencies.

In order to provide a fair and orderly marketplace and prevent against potential market misconduct, FMFW has developed the following principles and standards which must be followed by all Participants (“Principles”). All Participants who are approved to use the Exchange agree and understand to abide by these Principles, which have been designed to prevent deceptive or manipulative conduct.

FMFW may amend these Principles at any time and any such changes will take effect when posted on the Site, or when a Participant logs on to the Exchange.


When used in these Principles, the below terms shall have the following meaning:

“Applicable Law” means any rule, regulation, legislation, statute or other directive from a governmental or self-regulatory authority applicable to Participant or FMFW.

“Order” means either a bid or an offer for a Virtual Currency accepted by FMFW and made by a Participant with Trading Privileges and the intent that such Order results in a valid Transaction.

“Participant” means an individual or entity that is granted Trading Privileges to access and use the Exchange.

“ Exchange” means FMFW’s electronic trade execution system that is used for trading Virtual Currency on the terms set forth in this Trading Code of Conduct.

“Site” means

“Spoofing” means the practice of entering bids, offers or Orders with an intent to cancel prior to any such Order being filled.

Trading Privileges” means any right granted to a Participant to transmit Orders and execute Transactions on or through the Exchange.

“Transaction” means the successful execution of two valid Orders on the Exchange.

“Virtual Currency” means a cryptocurrency, digital currency, digital asset, crypto-asset or other such similar term describing, for example, Bitcoin Cash or Ether, but does not include a derivative of a virtual currency, or a security.

1. Access to the Exchange

1.1 Eligibility. An individual or entity is eligible to become a Participant only if such individual or entity agrees to the User Agreement (and any other applicable agreement).

1.2 Trading Privileges. Upon completion of onboarding requirements, Participants will receive Trading Privileges, which are non-assignable, non-transferable and may not be sold or leased.

1.3 FMFW may deny a Participant’s Trading Privileges or revoke, suspend or otherwise condition a Participant’s Trading Privileges at any time and for any reason as set forth in the User Agreement. Some important reasons are:

if FMFW believes such Participant has not or may not adhere to these Principles, Applicable Law or the User Agreement;

if servicing such Participant could bring FMFW or the Exchange into material disrepute; or

if servicing such Participant could interfere with FMFW’s provision of high quality services to other Participants.

2. Obligations of Users

2.1 Each Participant, to the extent applicable, shall:

use the Exchange in a responsible manner and not for any improper purpose;

use the Exchange only to exercise Trading Privileges in a manner consistent with these Principles;

observe high standards of integrity, market conduct, fair dealing, and similar equitable principles of trade in conducting any activity on or through the Exchange and in all aspects of its business connected with or concerning the Exchange; and

keep all credentials related to the Exchange confidential and secure.

3. Order Handling

3.1 Orders. All Orders are accepted and executed in FMFW’s discretion. FMFW will limit a Participant’s ability to place Orders consistent with the Participant’s deposits on the Exchange.

FMFW will reduce a Participant’s ability to place Orders according to the value of the Participant’s open Orders plus estimated fees.

A Participant may place an Order as either a limit order, a market order, or a stop order.

A Participant may request to cancel a stop Order or an unexecuted limit Order at any time before it is executed, which may or may not be honored by FMFW. No fees are charged for canceled orders.

FMFW may cancel an Order on the request of a Participant for reasons including the Participant’s inability to cancel such Order due to technological difficulties.

3.2 Order Sizes. All Orders are subject to minimum and maximum sizes according to the corresponding Virtual Currency. Participants may find a list of such minimum and maximum Order sizes on the Site.

3.3 Binding Obligation. Any Order placed by a Participant and accepted by FMFW is a firm Order and represents a binding obligation by the Participant to buy or sell the specified quantity of Virtual Currency.

3.4 No Cancellation or Modification of Transactions. All Transactions are final and will not be reversed except in FMFW’s sole discretion. FMFW may reverse a Transaction, for example, in the following circumstances:

FMFW is compelled to do so by any Applicable Law; or

Due to a serious technical error, Transactions do not occur as specified in these Principles, - in which case FMFW would make reasonable efforts to restore Participants to the position they would have been in had the technical error not occurred.

3.4.1 Cancellation of Orders by Participants. The Participant understands that when they place a request to cancel an order, such cancellation request may not be executed. The Order will be canceled only if the request to cancel is received by FMFW before it is executed. Mere submission of a cancellation request prior to confirmation of a Transaction does not ensure that an Order will not be executed.

3.4.2 Cancellation of Orders by FMFW. Orders that are not yet Transactions may be cancelled by FMFW in the following circumstances:

Orders placed by Participants who, in FMFW’s sole discretion, have engaged in abusive use of the Exchange;

Orders which under the circumstances and in FMFW’s sole discretion involve an obvious error with respect to price, quantity, or other parameters of these Principles;

If required by Applicable Law, including but not limited to circumstances where FMFW is required to suspend or terminate a Participant’s Trading Privileges; or

If required for technical reasons, in FMFW’s sole discretion.

3.5 Clearly Erroneous Transactions. Participant is responsible for verifying the Transaction details prior to finalizing any buy, sell, exchange, or other action taken in connection with use of the Exchange. FMFW may consider a Transaction to be clearly erroneous or inconsistent with current market conditions and take certain action to remedy the situation, including but not limited to canceling the Transaction in its entirety.

4. Market Conduct Practices

4.1 Market Manipulation. No Participant shall engage in any conduct, either with the intent to manipulate, or that which results in the manipulation of the Virtual Currency markets.

4.2 Fraud. No Participant shall engage in fraud or deception in connection with the use of the Exchange.

4.3 Illicit Transactions. No Participant shall use the Exchange in connection with illicit activities, including money laundering, financial crimes, the financing of terror or any other illegal activity.

4.4 No Misuse of Information. No Participant shall use information gained from the Exchange for purposes or services which Exchange were not designed to provide Participants. No Participant shall resell information provided by the Exchange or use any robots, spiders, scraping or other technology to access, query, or use the Exchange to obtain any such information.

4.5 Front Running. No Participant shall enter or solicit a bid, offer, or Order through the Exchange when in possession of material nonpublic information about another bid.

4.6 Wash Trading. No Participant shall engage in any conduct that results in a Transaction with no economic or legitimate purpose. This includes the practice of engaging in wash trading, or otherwise entering Orders for different accounts with common beneficial ownership with the intent to evade or negate market risk or price competition.

4.7 Coordination. No Participant shall coordinate actions with other Participants that are designed to disrupt or otherwise create the false appearance of legitimate market activity. Coordination includes directing another market Participant, to enter into, or alter, a Transaction with specific details, either in a threatening, intimidating, collusive or otherwise improper manner. Coordination also refers to the practice of pre-arranged trading, where 2 or more Participants use the Exchange after previous discussions with an intent to profit from or merely disrupt the competitive nature of the Exchange.

4.8 Spoofing / General Misconduct. No Participant shall engage in activity that is designed to disrupt or otherwise manipulate the Virtual Currency or other financial markets, which includes engaging in the practice of Spoofing.

4.9 Self-Trading. No Participant shall take, directly or indirectly, the opposite side of the Order for its own account, an account in which it has a direct or indirect financial interest, or an account over which it has discretionary trading authority.

5. System Availability

5.1 Availability. With limited exceptions, FMFW’s goal is to make markets available to Participants for monitoring and transacting 24 hours a day.

5.2 No Guarantee of Uninterrupted Access. FMFW does not guarantee uninterrupted access to the Exchange, that any Order will be posted, that any Order cancellation will take place, or that any Order will be filled. FMFW may suspend access without prior notice during scheduled or unscheduled system repairs or upgrades and to modify the Exchange at any time without prior notice.

5.3 Regular Scheduled Maintenance. The Exchange undergoes regular maintenance. During such times, some or all of the Exchange’s functionality may be unavailable to Participants. In order to minimize disruption to the Exchange, its Participants and the Virtual Currency marketplace as a whole, FMFW will often publish notices for regular scheduled maintenance. Upon resumption of operations, FMFW will work to ensure the Exchange undergoes an orderly auction restart process.

5.4 Unscheduled System Maintenance or System Disruptions. FMFW may temporarily halt operations in the event that FMFW requires unanticipated maintenance. In the event of any such required maintenance, some or all functionality of the Exchange may be unavailable to Participants. The Exchange may experience disruptions in service, including but not limited to unexpected computer or Virtual Currency network functionality or speed, partner or vendor outages, or cybersecurity incidents. In any such case, some or all the Exchange’s functionality may become unavailable or unreliable, requiring FMFW to halt operation of the Exchange. Notice of such a disruption may be posted on the Site. During the course of any such unexpected disruption, FMFW will take work to timely restore the Exchange’s functionality.

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