1.Introduction
GATE KRİPTO VARLIK ALIM SATIM PLATFORMU A.Ş (“Gate Turkey” or the “Company”) is a crypto asset service provider established under the Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers (III-35/B.1) and regulated by the Capital Markets Board of Turkey (“CMB”). The Company enables clients to buy and sell, crypto assets through its exchange Platform (“Platform”). Gate Turkey is highly committed to the interests of its clients, as well as its responsibilities under the laws and regulations of Turkey applicable to crypto asset service providers. Accordingly, the Company has:
●established a committee tasked with responsibility for determining the initial and continued conditions and procedures for listing crypto assets on the Platform (“Listing Committee”);
●established a coin listing policy (“Policy”) to provide guidelines, criteria and procedures for the assessment, listing and de-listing of crypto assets and the ongoing risk management in relation to crypto assets listed on the Platform;
●established these coin listing standards (“Standards”) for the crypto assets listed on the Platform.
2.General Procedures
(1)Candidate Assets
From time to time, the Company may consider certain crypto assets for listing on the Platform either sua sponte (such crypto assets, “Non-Applicant Listed Assets”) or pursuant to a listing application and a listing agreement (such crypto assets, “Applicant-Listed Asset”).
(2)Crypto Asset Evaluation Framework
Each crypto asset considered for listing on the Platform shall be evaluated by the Listing Committee in accordance with the applicable law, including without limitation the rules and regulations on the CMB and the evaluation framework set out in these Standards which has been developed and maintained by the Company in conjunction with external counsel (the “Evaluation Framework”).
The Evaluation Framework summarizes the factors by which Gate Turkey performs the overall evaluation for each candidate asset. The evaluation is performed holistically and the Listing Committee should pay close attention to a multitude of factors (both quantitative and qualitative).
Except for the statutory circumstances under CMB regulations, it is essential that platforms list only those crypto-assets that can be held by custody institutions authorized by the CMB. Crypto-assets to be listed on platforms must comply with the following principles:
a)They must meet the requirements under the CMB regulations.
b)There must be no restrictions or prohibitions imposed by relevant authorities regarding the issuance and trading of the underlying asset of the crypto-asset, and the crypto-asset must not be of a nature that could be used to circumvent or significantly undermine legal regulations.
c)The crypto-asset must not be structured in a manner that grants extraordinary unilateral rights to the project owner.
d)The project owner must not be listed on national or international sanctions lists related to money laundering, terrorist financing, or under the provisions of Law No. 7262.
e)The crypto-asset must not be designed to enable transfer transactions by concealing wallet addresses.
f)The crypto-asset must be capable of being stored in cold wallets.
Except for certain crypto-assets identified by the CMB or specified under relevant regulations, the Company cannot list crypto-assets that are initially sold or distributed by themselves or by:
a)A natural person together with their spouse and children under custody, or companies in which they participate with unlimited liability or where they serve as the chairman, member of the board of directors, general manager, or deputy general manager;
b)Legal persons, excluding public legal entities, or partnerships in which any of the persons mentioned above directly or indirectly hold 10% or more of the capital or voting rights;
c)Persons determined by the Board to be acting in concert with the platform through employment, contractual relationships, or other reasons.
(3)Initial Listing
At the time of initial listing, the Listing Committee shall verify the fulfilment of the CA Standards (as defined below), whether it be for Non-Applicant Listed Assets (as defined below) or Applicant Listed Assets (as defined below).
Crypto Asset Listing Standards
(“CA Standards”)
| Factor | Description |
|---|---|
| Trading Volume & Market Pairs | Trading volume and liquidity help with establishing a market price for users to acquire and sell crypto assets. 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 crypto assets including its possible use cases. This may include a review of all intended and unintended use cases or features of the crypto asset. If the crypto asset represents rights to any other assets, the enforceability of such rights. It is not designed to provide unilateral extraordinary rights to the project owner. |
| Supply Limitations | Whether the supply of the crypto assets is limited, whether the crypto asset has a fixed or flexible supply. A limited supply may impact scarcity and value retention whereas an unlimited supply could raise concerns about inflation and long-term sustainability. |
| Transaction Speed and Costs | Confirmation times and associated costs will impact the efficiency of transactions and transaction costs. Assets with high transaction costs or slow processing speeds may pose usability challenges and impact market adoption. |
| Algorithmic Value Determination | Tokens with algorithmically determined values, such as stablecoins or dynamically adjusted assets, should be reviewed for reliability, transparency, and potential risks related to price stability mechanisms. |
| Forks | whether there is a potential for blockchain forks, including hard forks and soft forks and whether there are any associated security risks relating to such forks, such as replay attacks or network instability. |
| 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.We shall also review the background of its issuer including, but not limited to, relevant experience in the crypto assets 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. |
| Historical Price Movements | The price movements of the crypto asset in past periods |
| 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 crypto assets and helps the crypto assets ecosystem grow as a whole. |
| Project Longevity & Activity | Many projects come and go. For this reason, we prefer to list 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 crypto asset is prohibited by the CMB or any other appropriate authorities both inside or outside of Turkey in jurisdictions in which the Gate Turkey will provide regulated activities, or equivalent activities, in relation to such crypto asset. Review the regulatory treatment by the CMB and other appropriate authorities [including those outside of Turkey], in relation to the crypto asset, and in particular whether the issuance of the crypto asset 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. We shall also review the security and immutability of the underlying blockchain. |
| Market Capitalisation | Whether there is a concentration of holdings or control by a small number of individuals or entities. Whether the crypto asset may be susceptible to price manipulation for any reason and relevant mitigations methods that will be implemented by the Company. Company shall ensure that crypto asset terms and conditions reflect, to the extent possible, the operation of any existing underlying physical market and avoid adverse impacts to such market. |
| 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 Company’s compliance | Whether the listing of the crypto asset will impact the Company’s ongoing legal and regulatory compliances including but not limited to those relating to AML/CFT, sanctions, securities, intellectual property.Whether Company has sufficient assets available to satisfy any obligation with respect to any regulated activities conducted in relation to such crypto 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 a Gate Turkey provide any regulated activities in relation to the crypto asset and relevant steps to mitigate. |
Without limiting the foregoing, the Company shall verify the following:
For Non-Applicant Listed Assets
a)Asset Evaluation
b)Legal Analysis
c)AML/CTF/CPF Analysis
d)Decision-Making
e)Liquidity
For Applicant-Listed Assets
a)Initial Listing Application
To be eligible for consideration by the Company for listing on the Platform, an applicant (the “Applicant”) shall provide the information and documents required therein, including but not limited to the following:
●A memorandum or legal opinion prepared by competent legal counsel within Turkey that presents the factual and legal basis as to the characterization of the crypto asset under Turkish law upon trading of such crypto asset on the Platform;
●Copies of any private or public sale, subscription, offering, distribution or other materials relating to the crypto assets;
●Copies of any software or other technology that is used, in combination with other open source or commercially available technology, required to enable, administer or control the creation, destruction or transfer of the crypto asset;
●Copies of any regulatory inquiries, administrative or legal matters relating to the Applicant or the crypto asset; and
The Company may also request any information or documentation, public or non-public, deemed necessary for assessment of the crypto asset, including but not limited to, any materials provided by the Applicant to or received by the Applicant from any regulatory authorities. Failure to provide within the specified timeframe or if any information provided contains a material misrepresentation or omission may result in delist or denial of listing. The Company shall have absolute discretion to list, delist or deny listing of a crypto asset.
b)Asset Evaluation
The Applicant’s compliance with the initial listing criteria will be assessed.
c)Certification
Upon request of the Company, the Applicant shall provide a certificate signed by the CEO or CFO of the Applicant, or other governing body or authorized representative of the Applicant, certifying that all materials and information provided in connection with the listing application are true, correct, complete, updated and non-misleading in all respects.
d)AML/CTF/CPF Checks
The compliance department will conduct AML/CTF/CPF checks on the Applicant-Listed Asset and the team behind.
e)Withdrawal of Application
An Applicant may withdraw its application for initial listing at any time.
f)Decision-Making
The Listing Committee shall determine whether to approve the initial listing of any crypto assets on the Platform.
g)Liquidity
Each Applicant shall maintain a “hot wallet” on an address controlled by the Company with a minimum number of such Applicant’s crypto assets as the Company may require appropriately, as applicable under the CMB regulations.
(4)Continued Listing
A crypto asset which has been approved for initial listing on the Platform shall continue to meet the applicable requirements, in particular the CA Standards. The Company shall regularly assess the crypto asset.
Suspension, termination or delisting of a crypto asset from the Platform can happen after careful consideration of Gate Turkey. Gate Turkey may delist a listed crypto asset or have suspension of trading for a listed crypto asset in accordance with the Standards.
In the event of delisting for a certain asset, all its trading pairs are removed. The assets withdrawals from the Platform will remain open for a specified period of time after the delisting. This way, customers can withdraw their existing funds even though trading is no longer available on the platform.
During the continued listing, the Company shall follow the principles determined by the Central Securities Depository regarding the reporting of listed and delisted crypto assets to the Central Securities Depository from time to time.
Generally, the Company shall maintain all records relevant to its CA Standards assessments for ten [10] years.
Considerations for Suspension, Termination and/or Delist
Gate Turkey may consider a variety of factors in determining whether to suspend, terminate or delist any crypto asset on the Platform, including but not limited to the following:
•the crypto asset ceases to meet the CA Standards;
•Any considerations taken into account in connection with the initial listing of the crypto asset, and any changes thereto;
•Technological challenges including failure of the crypto asset 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 these Standards or any agreements between the Applicant and the Company in relation to the crypto asset listing;
•User complaints or feedback;
•False, misleading or otherwise deceptive communications;
•Additional or new AML/CTF/CPF risk;
•Adverse changes to the Applicant, including bankruptcy or any merger, acquisition or sale of the Company’s assets or equity;
•Material changes to the Applicant, including ownership, structure or leadership;
•The Applicant’s loss of control or ownership, or failure to support the crypto asset;
•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 crypto 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 the CMB or competent authority;
•Changes in applicable law;
•Any actual or potential risks considered by Gate Turkey within the scope of the applicable legalisation to crypto asset service providers.
Additional Information
For any Applicant-Listed Asset, the Company may, at its sole discretion and at any time, request any additional information or documentation, public or non-public including but not limited to, any materials provided by the Applicant to or received by the Applicant from any regulatory authorities for the Company’s assessment. Failure to provide the additional information within a reasonable period of time, or if any communications with the Company contains a material misrepresentation or omission, may result in delisting.
For any Non-Applicant Listed Asset, the Company may from time to time assess any additional information deemed necessary for assessment and may decide to delist any such crypto asset in its sole discretion.
Technology Upgrades
Each Applicant shall be required to notify the Company in the event of any distribution, “Hard Fork” or similar technological changes at least one (1) month prior to such event occurring. The Company is not obligated to support any such event and may suspend, terminate or delist such crypto asset following such events. If the Company decides to support such an event, the Applicant shall reimburse the Company for all related costs and expenses.
Technical and Security Requirements
Each Applicant shall be required to implement security standards aligned with best industry standards to prevent any hack, data or security breaches, “majority attacks,” “replay attacks,” “Sybil attacks” or any compromise of the integrity or security of its crypto asset, the Company’s technology or any personal data.
Each Applicant shall be required to adhere to all Company security and technical policies and requirements, provide on-going technical support, as well as any other form of support that the Company may request in connection with the trading of such crypto asset on the Platform.
News and Announcements
Each Applicant shall be required to notify the Company, prior to the distribution of certain material information or announcements that may have a material impact on the trading of the Applicant’s crypto asset on the Platform, at least three (3) business days prior to public announcement of such information. Examples of material announcements include regulatory inquiries, adverse legal actions or other similar enforcement activities, product launches, partnership arrangements, changes to the Applicant’s management or ownership, or any material sale of the Applicant’s assets or equity.
Trading Activities
Gate Turkey monitors real time trading in all crypto assets on the Platform for price and volume activity. Gate Turkey may require the Applicant to explain any unusual market activity. The Applicant shall be required to provide full and prompt disclosure to the Company as required. The Company has a zero-tolerance policy for “pump and dump” schemes. Any such activities shall result in the crypto asset being delisted immediately.
Suspension and Delisting
Gate Turkey reserves the right to temporarily halt, suspend, terminate or delist any crypto asset on the Platform at any time in its sole discretion without waiting after notification to the clients. Potential reason of suspension or delisting may be due any of to the following reasons:
•Failure to comply with the CA Standards;
•Compliance issues with these Standards, regulatory standards and/or updates in the compliance framework of the Company;
•The crypto asset concerned is restricted by an applicable regulator;
•The crypto asset itself may be in violation of the Terms of Use and/or User Agreement of the Company;
•Actual or potentially suspicious trading activities;
•Unreliable crypto asset issuer who ignores good listing practice and not acting in good faith;
•Material changes in the team, product, or business model of the crypto asset issuer;
•Complaints by users and traders of the specific crypto asset;
•Restructuring, liquidation and or sale of the issuer issuing the crypto Aaset;
•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 crypto asset without explanation or announcement;
•The crypto asset is suspected to be involved in money laundering, deceiving, pyramid schemes or any other illegal acts; or
•Any actual or potential risks considered by Gate Turkey within the scope of the applicable legalisation to crypto asset service providers
Delisting Procedure
If the Company decides to delist any crypto asset within the framework of an assessment report they prepare, it will notify all users (i.e. with or without holdings) of the relevant arrangements and the expected timeline. Generally, the Company will provide at least seven (7) days advance notice prior to the delisting except for exceptional circumstances. It may provide a period of time within which all delisted crypto assets must be removed from user accounts, after which access, control and transfer of such delisted crypto asset may be disabled. The Company may allow crypto-assets that have been delisted to be traded on peer-to-peer digital marketplaces. The return of the relevant crypto assets either in kind or in cash, shall be enabled.
In the event that a crypto-asset is delisted by a global crypto-asset platform, the Company may also delist the relevant crypto-asset without waiting for seven (7) days, provided that investors are notified at least one day in advance. In cases of extraordinary circumstances arising in global markets, the one-day notification period may also be waived.
Crypto-assets may be delisted without waiting for the seven-day period, and all purchase, sale, and transfer transactions related to such crypto-assets may be suspended in the following cases:
a) If it is subsequently determined by the platform that the crypto-asset does not comply with the principles set forth in the first paragraph of Article 21 of the Communiqué on the Operating Procedures and Principles and Capital Adequacy of Crypto Asset Service Providers (III-35/B.2), or if such a request is made by public authorities or judicial bodies.
b) If there is a reasonable suspicion regarding the reliability of the relevant crypto-asset or the systems of the associated distributed ledger network.
Decision-Making
The Listing Committee shall prepare an assessment report on whether a crypto asset may be listed or should be delisted within the framework of the listing Standards, and crypto assets shall be listed or delisted based on the outcome of such assessment reports. The Listing Committee shall determine whether to continue listing or delist any crypto assets on the Platform.
Confidentiality
All Applicants must keep conversations with the Company and any potential listing of crypto assets on the Platform strictly confidential. Failure to do so could resulting in the Company’s delaying or refusing to list the Applicant’s crypto asset on the Platform.
Media and Public Announcements
Any press release or announcement relating to any crypto asset trading on the Platform must not encourage the trading of such crypto asset for speculative or investment purposes. Any press release, marketing material or announcement to any crypto asset trading on the Platform must be undertaken in accordance with applicable laws including any guidelines issued by the CMB and shall be suspended and removed from the Platform upon receiving notice from the CMB or from any public authorities or judicial bodies pursuant to the notice.
Waivers
Any provision of these Standards may be waived by the Listing Committee.
3.Review
These Standards will be reviewed periodically (at least on an annual basis) and on an ad hoc basis by the Listing Committee for the final review and approval of the board of directors.
You can review our listing criteria and contact us via listing@gate.com.tr for the listing of your crypto-asset project.
