1. Know Your Client (KYC)
A. List of Documents for Corporate Entities:
• Certified True Copy of Business License/Registration and Certificate of Incorporation
• Certified True Copy of Memorandum and Articles of Association
• Ownership and Control Structure Chart indicating shareholdings signed and dated by Director
• Authorized Signatory List (Note: Each Authorized signatory has to provide identification document to confirm his Full Name, Date of Birth, Nationality and Address Proof issued within 3 months)
• Director List (Note: One of the director has to provide identification document to confirm his Full Name, Date of Birth, Nationality and Address)
• Ultimate Beneficiary Owners List (Note: For ultimate beneficial owners owning more than 25%, they need to provide identification document to confirm his Full Name, Date of Birth, Nationality and Address Proof Issued within 3 months)
• For offshore company, we need a copy of Certificate of Incumbency (issued within 6 months from the date of onboarding) and should include the following:
o Company’s registered office address
o List of Directors (Note: One of the directors need to provide identification documents to confirm his Full Name, Date of Birth, Nationality and Address Proof issued within 3 months)
o List of Shareholders (Note: For shareholders owning more than 25%, they need to provide identification documents to confirm his Full Name, Date of Birth, Nationality and Address Proof issued within 3 months)
o Identification of business address if it is different from registered office address
B. List of Documents for Individuals
• Certified True Copies of Passport/Identification card copy (front and back)
• Selfie with passport / identification card
• Proof of Address issued within 3 months (e.g. Utility Bill or Bank Statement)
2. Trading and Operation Matters
1. Minimum trade size is USD 100,000. There is no maximum trade size. Significantly larger trade sizes may be executed across multiple days due to lack of supply, liquidity, and price sensitivity.
2. OTC Desk primarily facilitates trade for: Bitcoin (BTC), Ethereum (ETH), stable-coins (e.g. Tether USDT, Gemini GUSD, PAX), and other high market-capitalization virtual assets.
3. Client inquiries are sent to the OTC desk via Our company registered email email@example.com
• We have a ‘MANUAL’ trading procedure for the OTC Desk, WITHOUT trading channels such as a website, dedicated application, application programming interface (API).
• Different types of orders: Client will either inquire to ‘BUY’ or ‘SELL’ virtual assets, while denoting the trade size.
4. Trading hours are available 24 hours, 7 days a week (excluding public holidays, where there may be an outage due to other counter-part OTC desks being closed).
5. Before any trading can commence, client will send the virtual assets to the designated OTC Desk wallet address; or transfer the fiat funds to our “Universe Connect” bank account. OTC Desk trading is hence ‘pre-funded’ with either Virtual Assets or Fiat Funds first.
6. Upon receiving your inquiry via email, OTC Desk traders will respond with a price quote which you need to:
• if both sides accept the price quote, then the price is ‘locked’ in for the transaction
• this may not be amended or cancelled once accepted and “locked”
• therein the Client can either ask for a re-quote, or ask OTC Desk to refund the virtual assets / funds at no extra cost
(c) Counter with a level of your own
• which we can either Accept, Reject, or Counter as well
If there is no response from the Client after a reasonable amount of time to the price quotation, we will communicate to both sides that the quotation is no longer valid or live.
5. An email confirmation will be sent with trade and settlement details.
6. Trade verification procedure: Confirm the trade and settlement details by replying to the email.
7. Fiat proceeds will be transferred (if selling) or virtual assets will be sent (if buying) – after payment settlement has been confirmed.
3. Settlement Timeline
Buy order settlement
• For T+0 delivery, trade cut off time is 15:00 HKT. Coins will be delivered on the same day by end of day (excluding Sunday and public holidays). Otherwise virtual assets will be delivered T+1.
• We will only deliver to one wallet address per transaction. Delivery to two or more addresses is subject to an additional fee, and must be requested in advance.
Sell order settlement
• Deposits take up to 2 working days for clearance, depending on bank and transfer method.
• We only accept bank transfer (HKD/USD).
• Bank advice slip will be sent to seller.
Exchange Rates: (subject to change depending on FX market, with reference to HSBC TT Rate)
7.87 HKD/USD (Buy orders)
7.81 HKD/USD (Sell orders)
4. Internal – Conflicts of Interest
Employees trading with the OTC Desk will be subject to Code of Conduct and the Policy of Personal Account Trading and trades will need to be approved by senior management.
All employees are required to identify all related virtual asset trading account(s) and report them to senior management each month. The term “related virtual asset trading account(s)” includes an account of their minor children and accounts in which the employees hold beneficial interests.
Any trade deemed as a potential Conflict of Interest will not be approved or executed.
5. Prohibited Trading Activities
Prohibited trading activities, include, but not limited to, churning, pump-and-dump schemes, ramping, wash trading and other market manipulation aimed at creating a false representation of price and/or quantity.
If the Client is engaged in prohibited trading activities, the Client’s trading account will be suspended and/or terminated.