Tradlle’s Exchange allows Participants to execute Virtual Currency purchase and sale transactions in real-time with both other Virtual Currencies and fiat 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, across various pairs of both virtual-to-virtual and fiat-to-virtual legs.
In order to provide a fair and orderly marketplace and prevent against potential market misconduct, Tradlle 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.
Tradlle may amend these Principles at any time and any such changes will take effect when posted on the Tradlle website, or when a Participant logs on to the Exchange.
An individual or entity is eligible to become a Participant only if such individual or entity agrees to the Tradlle Terms of Service (and any other applicable agreement).
Upon completion of onboarding requirements, Participants will receive Trading Privileges, which are non-assignable, non-transferable and may not be sold or leased.
Tradlle 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 Tradlle User Agreement. Some important reasons are:
Tradlle charges fees based on a Maker/Taker pricing model. A maker order adds liquidity to the market. A taker order removes liquidity from the market. Maker orders, when executed, carry a lower transaction fee intended to reward those who bring liquidity to the Exchange.
Tradlle may, from time to time, establish programs that offer professional market makers financial incentives for meeting trading volume, liquidity or other thresholds, as established by Tradlle.
Each Participant, to the extent applicable, shall:
All orders are accepted and executed in Tradlle’s discretion.
Limit Orders may be placed with one or more of the following instructions:
A Market Order is a buy or sell order to be executed immediately at the current market price. Market Orders do not carry a limit price and will trade with anything on the order book. Market Orders default to Immediate or Cancel but they can also be sent as Fill or Kill.
Market Orders will not rest on the order book. If a Market Order can only be partially filled given the existing depth of the market, then the remaining quantity will be automatically cancelled.
During periods of high volume, fast market conditions, illiquidity, or volatility in the marketplace, the actual price that a Market Order is executed at may be different from the best price indicated at the time of your Order, in some cases significantly so.
A valid Market Order will be immediately posted to the Exchange. Participants may not cancel a Market Order.
Market Orders may be placed with the following instructions: Immediate or Cancel or Fill or Kill.
A Stop Order is an Order that will rest off of the order book and wait for the market to move into its stop price. This must be an Order outside of the current market price. For a sell Order, the stop price must be below the current last sale.
A Stop Order is not posted to the Exchange and is not visible to other Participants, but any resulting Order is posted and visible.
A Stop Order can be placed as either a Stop Market Order, which posts a Market Order when the stop price is triggered, or a Stop Limit Order, which posts a Limit Order when the stop price is triggered. Buy Stop and Buy Stop Limit Orders are not accepted at this time.
Stop Limit Orders may be placed with one of the following instructions: Good Til Cancelled, or Good Till Date.
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 Tradlle website.
Order handling rules have been carefully constructed in order to offer a fair and equitable marketplace. Generally speaking, orders that are routed to the order book are prioritized first by price and then by time. Buy Orders at the highest price are prioritized first over the the oldest Order placed in the order book. Similarly, sell Orders at the lowest price are prioritized first over the oldest Order placed in the order book. Market Orders take priority over Limit Orders, which will not be ranked on the order book until they are triggered.
Binding Obligation. Any Order placed by a Participant and accepted by Tradlle is a firm Order and represents a binding obligation by the Participant to buy or sell the specified quantity of Virtual Currency.
All Transactions are final and will not be reversed except in Tradlle’s sole discretion. Tradlle may reverse a Transaction, for example, in the following circumstances:
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 Tradlle 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.
Orders that are not yet Transactions may be cancelled by Tradlle in the following circumstances:
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. Tradlle 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.
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.
No Participant shall engage in fraud or deception in connection with the use of the Exchange.
No Participant shall use the Exchange in connection with illicit activity, including money laundering, financial crimes, the financing of terror or any other illegal activity.
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.
No Participant shall enter or solicit a bid, offer, or Order through the Exchange when in possession of material nonpublic information about another Bid.
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.
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 two (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.
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.
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.
With limited exceptions, Tradlle’s goal is to make markets available to Participants for monitoring and transacting 24 hours a day.
Tradlle does not guarantee uninterrupted Exchange access, that any Order will be posted, that any Order cancellation will take place or that any Order will be filled. Tradlle 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.
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, Tradlle will often publish regular maintenance. Upon resumption of operations, Tradlle will work to ensure the Exchange undergoes an orderly auction restart process.
Tradlle may temporarily halt operations in the event that the Exchange requires unanticipated maintenance. In the event of any such required maintenance, some or all Exchange functionality 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 Exchange functionality may become unavailable or unreliable, requiring Tradlle to halt operation of the Exchange. Notice of such a disruption may be posted on Tradlle’s website. During the course of any such unexpected disruption, Tradlle will take work to timely restore Exchange functionality.
For each Transaction, Tradlle will provide a Participant that is a party to the Transaction an electronic record of the material terms of such Transaction at the time of execution, which will serve as a confirmation of the Transaction (“the Confirmation“). Access to this Confirmation will be provided by tools that allow Participants to review their transaction history.
Tradlle operates an over-the-counter trading desk that facilitates purchase and sale transactions in Virtual Currency on a proprietary basis and for institutional and high net-worth individuals. For more information about Tradlle’s OTC trading desk and other product offerings, Participants may visit the Tradlle website.
When used in these Principles, the below terms shall have the following meaning: