Secondary Trading Policy
Venue model, eligibility, order handling, price discovery & matching, settlement, transfer restrictions, surveillance, halts, disclosures, and governance for tokenized instruments.
Contents (short)
- Venue model: MTF/ATS, bulletin board, P2P/OTC — which ones you operate.
- Eligibility & onboarding: KYC/AML/sanctions, investor categories, whitelist, legends/lock-ups.
- Order handling: order types, TIF, priority, partials, cancel/replace.
- Price discovery: continuous vs auctions, indicative prices, negotiated crossing.
- Settlement & custody: DvP T+0/T+1, reconciliation, failed-settlement policy.
- Controls: price bands, halts, volatility auctions, disclosure halts, tech/custody incidents.
- Surveillance: spoofing/layering/wash/ramping detection and escalation.
- Disclosures & corporate actions: fair access, record/ex-dates, entitlements.
- Governance & review: ownership, annual review, change log.
- Appendices: trading calendar, order specs, halt triggers, settlement flows, definitions.
Download & next steps
Download the skeleton and tailor venue model, order set, bands/halts, and settlement rails to your license, liquidity profile, and tech stack. We can align it to MiCA/MiFID, Reg ATS, or your local regime.