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BLOCKCHAIN AND CRYPTO ADVISORY · VATP APPLICATION SUPPORT
VATP Policy Review and Drafting
Hands-on assistance in drafting and reviewing the full range of policies and documents required by the SFC for VATP applicants.
OVERVIEW
Policies and procedures for your SFC application
At KTC, we recognise the challenges Virtual Asset Trading Platform (VATP) applicants face during the application process with the SFC. Our team provides independent, expert external assessment services and comprehensive support in drafting the full suite of policies and External Assessment Reports required for your VATP license application.
KTC offers hands-on assistance in drafting and reviewing the full range of policies and documents required by the SFC for VATP applicants, including the policies set out below.
WHAT WE REVIEW
Policies we draft and review
Our review covers the areas the SFC expects licensed platform operators to address, including:
01
AML Policies
Comprehensive frameworks to ensure compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) and SFC guidelines, including client due diligence, transaction monitoring, and suspicious transaction reporting.
02
Know-Your-Client
Client onboarding, identity verification and suitability procedures for platform users.
03
Custody of Client Assets
Safe custody of client virtual assets and client money, including wallet arrangements and private key management.
04
Token Admission and Review
Criteria and due diligence for admitting virtual assets for trading, and their ongoing review.
05
Conflicts of Interest
Identifying, avoiding and managing conflicts, including policies on employee dealings in virtual assets.
06
Market Surveillance
Preventing and detecting market manipulative and abusive trading activities.
07
Risk Management
Frameworks for identifying, measuring, monitoring and controlling the risks of operating the platform.
08
Cybersecurity
Security of the trading platform and custody infrastructure, including incident escalation procedures.
