Virtual Asset Standards

Gate Technology FZE (“Gate UAE”, “we”, “our” or “us”) is licensed as a virtual asset (“VA”) exchange by Dubai Virtual Assets Regulatory Authority (“VARA”). Gate UAE enables clients to buy, sell and exchange VA through its exchange platform (“Platform”). We are highly committed to protecting the interests of our clients, as well as assuming our responsibilities under the laws and regulations of the United Arab Emirates (“UAE”), so that we can provide our clients with a convenient and reliable platform for the spot trading of virtual assets. As such, Gate UAE adopts these Virtual Asset Standards (“VA Standards”) to select suitable virtual assets for listing.

These VA Standards not only apply to all new applications for listing on the Platform but also to the continued listing of existing VA available for trading on the Platform to ensure fair and orderly trading.

Our VA Standards are set forth as follows:

1.Gate UAE will at least take the following factors into account while evaluating whether to list any VA or remain them listed:

Factor	Description
Trading Volume, Liquidity and Market Pairs	Trading volume is the amount of trading activity in relation to a VA and liquidity refers to the ease with which tokens can be swapped to other tokens. Trading volume and liquidity help with establishing a market price for users to acquire and sell VA. We also pay close attention to the market pairs on other supported exchanges and platforms and the sources of the volume.
Design, Features, Rights and Use Cases	The design and features of the VA including its possible use cases. This may include a review of all intended and unintended use cases or features of the VA. If the VA represents rights to any other assets, the enforceability of such rights
Community Interest & Engagement	A project’s usefulness is largely a function of adoption and its ability to foster meaningful interactions with its community and user base.
Traction/Progress	This can take the form of user growth, partnerships, institutional/consumer adoption, and roadmap progress.
Team	The personnel, investors, and advisors are integral to the success of any given project, especially if there are transferable skills/experience/networks that can be leveraged. The conduct of the team (e.g., transparency and professionalism) will also factor into our assessment. Gate UAE shall also review the background of its Issuer including, but not limited to, relevant experience in the VA sector and whether it has been subject to any investigations or claims in relation to fraud or deceit.
Product/Market	Fit A project with a minimum viable product that addresses a specific pain point, problem, or use case is more likely to gain traction in the long run.
Impact & Practicality	Ease of implementation and size of the addressable market
Uniqueness & Innovation	Creating a project with unique and interesting characteristics/technology expands the use cases for VAand helps the VAs ecosystem grow as a whole.
Project Longevity & Activity	Many projects come and go. For this reason, Gate UAE also considers listing projects that have stood the test of time.
Legal	Whether there are any pending or potential regulatory, criminal or enforcement action relating to the issuance, distribution or use of the asset such as tokens that facilitate the obfuscation or concealment of the identity of a customer or counterparty or used to circumvent laws and regulations. Whether the virtual asset is prohibited by VARA or any other appropriate authorities [both inside or outside the UAE] in jurisdictions in which the Gate UAE will provide VA activities, or equivalent activities, in relation to such VA. Review the regulatory treatment by VARA and other appropriate authorities [including those outside of the Emirate], in relation to the VA, and in particular whether the issuance of the VA has received any regulatory approvals.
Security & Immutability	Whether there are any security concerns with the asset, such as hacks or exploitation of source course within the public domain. Gate UAE also reviews the security and immutability of the underlying blockchain.
Market Capitalisation	Market capitalisation (commonly known as “market cap”) is the total value of a VA in the market. Market cap is calculated as follows: Market cap = number of coins in circulation x current market price Whether there is a concentration of holdings or control by a small number of individuals or entities. Whether the VA may be susceptible to price manipulation for any reason and relevant mitigations methods that will be implemented by Gate UAE. Gate UAE will ensure that VA 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].
Fully Diluted Market Value	Fully diluted market value (commonly known as “FDV”) is the value of a virtual asset’s market cap if all tokens in its total supply have been issued. FDV is calculated as follows: FDV = Maximum supply of a token x current market price The gap between the market cap and the FDV ought to be relatively small. Normally, a high FDV might indicate that a token could be subject to inflationary tokenomics and huge selling pressure and there could be a higher chance that the value per token will decrease as more tokens get unlocked. However, it must be noted that FDV itself is not conclusive and shall be considered together with multiple factors.
AML/CTF/CPF	Whether the project team is identified and the country the project team is located in as well as sanction, PEP and adverse media screening being carried out on all known individuals such as the project team, controllers and owners.
Impact on Gate UAE’s compliance	Whether the listing of the virtual asset will impact Gate UAE’s ongoing legal and regulatory compliances including but not limited to those relating to AML/CFT, sanctions, securities, intellectual property. Whether Gate UAE has sufficient assets available to satisfy any obligation with respect to any VA activities conducted in relation to such virtual asset.
Project Roadmap	The future development [e.g. “roadmap”] as communicated by the issuer and/or relevant developers
Conflict of Interest	Whether potential or actual conflicts of interest may arise should Gate UAE provide any VA activities in relation to the VA and relevant steps to mitigate.

2.Gate may consider a variety of factors in determining whether to suspend, terminate or delist any VA on the Platform, including but not limited to the following:

Any considerations taken into account in connection with the initial listing of the VA, and any changes thereto;
Technological challenges including failure of the VA to function as intended or designed;
Security breaches or compromises by third parties;
Discovery of bugs, defects or errors;
Poor market interest, lack of liquidity or low activity;
Breach of any rules of the coin listing policy or any agreements between the listing applicant and Gate UAE in relation to the coin listing;
User complaints or feedback;
False, misleading or otherwise deceptive communications;
Additional or new AML/CTF/CPF risk arising from the asset itself or the team behind it. Adverse changes to the listing applicant, including bankruptcy or any merger, acquisition or sale of its assets or equity;
Material changes to the listing applicant, including ownership, structure or leadership;
The listing applicant’s loss of control or ownership, or failure to support the VA;
Unusual or suspicious trading activity, including any “pump and dump” schemes;
Large fluctuations in pricing and/or trading volume;
Hard forks or double spend attacks;
Use or association of virtual asset for illegal or otherwise objectionable activities;• Legal, regulatory or administrative inquiries, enforcement actions, or lawsuits;
Intellectual property challenges;
Adverse media reports;
Adverse reputational impact;
Any notices, announcements and/or postings made by VARA or competent authority;
Changes in applicable law; and
Any actual or potential risks considered by Gate UAE.

3.Gate UAE will notify VARA as soon as possible after becoming aware that a virtual asset no longer meets its VA Standards and shall implement any steps directed by VARA to minimise any adverse impact on clients arising as a result.

4.Gate UAE reserves the right to temporarily halt, suspend, terminate or delist any VA on the Platform at any time in its sole discretion without prior notification. Potential reason of suspension or delisting may be due any of to the following reasons:

Failure to comply with the VA Standards;
Compliance issues with these VA Standards, regulatory standards and/or updates in the compliance framework of Gate UAE;
The VA concerned is restricted by an applicable regulator;
Actual or potentially suspicious trading activities;
Unreliable virtual asset issuer who ignores good listing practice and not acting in good faith;
Material changes in the team, product, or business model of the VA issuer;
Complaints by users and traders of the specific VA;
Restructuring, liquidation and or sale of the issuer issuing the VA;
The project, team, consultant, or founder of the issuer company has significant legal and negative issues;
The asset project development is not carried out in accordance with the timeline of the roadmap planned in its whitepaper;
Delays in progress of the development of the VA without explanation or announcement;
The VA is suspected to be involved in money laundering, deceiving, pyramid schemes or any other illegal acts; and/or
Any actual or potential risks considered by Gate UAE.

5.Please note that security tokens, digital commodity contracts, Anonymity-Enhanced Cryptocurrencies (as defined under the VARA Regulations) and/or any other VA, which display in-built anonymisation features that make tracing transactions and/or identifying the asset holder difficult, will not be listed on the Platform. Also, any VA that might enable anonymous transaction is also prohibited and will not be listed on the Platform. Before launching any new products (including coins and tokens), Gate UAE will ensure that such products fulfil these VA Standards, and wherever deemed necessary, have them authorised by VARA.

6.As a part of Gate UAE’s Coin Listing Policy, VA Standards will be reviewed periodically and on ad hoc basis. Gate UAE will maintain all records relevant to its VA Standards assessments for 8 years and provide such records for VARA’s inspection upon request.