We have been asked to outline some of the Due diligence we perform on projects who wish to publish on TrustedIn Trading. In line with our transparent concept, here is our outline of due diligence performed on projects publishing on TrustedIn Trading.
Any project who wishes to list on the TrustedIn Trading must complete a due diligence process in which the Trusted Team and their partners look to identify specific aspects of information surrounding the project and its founders, directors and board members.
The primary aim is to identify and ensure that we understand and know who the ultimate beneficiaries are within a project and no bad actors are associated with the project or have hidden vested interests.
So what exactly do we look at?
Due Diligence Documentation: We ensure that all documentation surrounding the company is matching to what has been published and that the directors within the company are the individuals which are listed.
Additionally, we look at the capital within the company, the shareholdings, and the distribution of the shares and consequently who maintains control. If a separate entity maintains a controlling interest in the company, we demand full information on this entity and will follow the line until we understand who is behind and controlling this entity as well.
Furthermore: We investigate name changes to the company and any previous directors whom have been involved with the company or project.
Directors/ Shareholders: All directors and significant shareholders go through a full know your customer process to ensure they are who they say they are as well as including a host of checks against them, including judgement checks, securities barring orders, bad actor checks etc
We check to ensure there is good activity surrounding the entity and its directors. What is good activity? Good Activity shows that a company is in good public standing, an operational entity as such. This can be a little bit abstract within the crypto space particularly with a lot of the raises coming through newly formed company’s. As such, we look for connection with company’s which may be incubating the project during the time frame of the raise and utilize their actions and standing within the diligence process.
Litigation's: We look for ongoing and previous litigation's associated with an entity. To be exact, the check are focused on civil, criminal and bankruptcy/ winding up proceedings. This is done in the local jurisdiction in which the entity is set up and, if the project is being incubated by another company, we look in these jurisdictions too.
The press can be a tremendous source of information though the accuracy of news stories can be called into question in many instances.
Local press and international press is checked in both English and the native language if needed.
Any bad press, comments, posts, articles will be a cause of a red flag and as such will need to be explained adequately to us.
US Federal lists check: in the scope of our investigation, we have consulted the Office of Foreign Assets Control (OFAC) of the US Department of the Treasury.
Denied Persons List: a list of individuals and entities that have been denied export privileges.
Unverified List: a list of parties where the Bureau of Industry and Security of the US Department of Commerce has been unable to verify the end-user in prior transactions.
Debarred List: a list compiled by the State Department of parties who are barred by §127.7 of the International Traffic in Arms Regulations (ITAR) from participating directly or indirectly in the export of defense articles, including technical data or in the furnishing of defense services for which a license or approval is required by the ITAR.
Entity List: a list of parties whose presence in a transaction can trigger a license requirement under the Export Administration Regulations.
The subjects are not barred from securities markets and are not mentioned as bad actors on international markets.
Asset Association: If in the course of our investigations, we notice that specific asset such as technology assets are not associated with the entity which is publishing their project, we will identify this to the directors and request that the assets in question are associated with the relevant entities.
As you can see from above, we perform a higher level of due diligence on published projects than any other listing platform within the crypto space and at no cost to the project , if they agree to utilize our systems and maintain compliance. After all, many people are bootstrapping their projects, we should be helping them, not preying on them as is happening now.
Current Projects which have passed Due Diligence are available on the Digital Offerings Page