Digital Asset Committee
The review of digital assets, including decisions on their listing or delisting, will be conducted by a Digital Asset Committee comprised of senior management across business, technology, operations, legal, compliance, and product functions.
The principles outlined in Hata’s internal Listing & Delisting of Digital Asset Policy form the basis of Hata’s framework governing the listing, ongoing monitoring, and delisting of digital assets, coins or tokens by Hata, in accordance with applicable securities laws, RMO Guidelines, and relevant international standards including IOSCO governance standards.
The objective of the Policy is to ensure that Hata protects its business and users by listing legitimate digital assets and establishing transparent procedures for the company’s operations.
Any future decisions concerning the listing or delisting of digital assets by Hata are guided by this framework and Hata’s internal governance standards.
Digital Asset Listing Assessment Process
Before any digital asset is listed on the Hata’s Digital Asset Exchange and/or made available via its Digital Broker, Hata will conduct an internal assessment of the digital asset.
Hata’s review generally includes both legal/compliance considerations and technical/market considerations. The depth of the review is proportionate to the risk profile of the digital asset, including whether it is assessed as presenting higher levels of risk.
Hata may consider publicly available information and reputable third-party sources (such as project disclosures, analytics providers, blockchain explorer data, and incident reporting sources) on a best-effort basis as part of its review.
Preliminary Assessment
As part of the review, Hata considers a range of preliminary legal and compliance factors, which may include:
- Whether the digital asset appears to represent certain rights, benefits, or utility
- Availability of publicly accessible information, such as a whitepaper or equivalent disclosure document
- Best-endeavour identification and sanctions screening of project founders, key contributors, and relevant affiliates against applicable watchlists and adverse media sources
- Whether the digital asset is reasonably assessed to be consistent with applicable legal and regulatory frameworks in Malaysia
- Whether the digital asset falls within categories that Hata does not support (for example, privacy tokens are prohibited)
- Trading history and market development (where available)
These factors help inform Hata’s assessment, which is conducted on a risk-based and case-by-case basis.
Internal Assessment Methodology
Hata applies a structured internal assessment methodology to evaluate digital assets across governance, market, technical, and security considerations. This methodology is designed to support consistent and risk-based decision-making.
High-Risk Digital Assets
Certain digital assets may be assessed as presenting higher levels of risk due to their heightened susceptibility to volatility, speculative trading, governance weaknesses, conflicts of interest, or information asymmetry.
This may include:-
a. Meme Tokens
Digital assets primarily driven by social sentiment, community engagement, or speculative interest, and which may lack intrinsic utility, formal governance structures, or sustainable value propositions (e.g. Dogecoin-type tokens).
b. Exchange Tokens
Digital assets issued by or affiliated with a digital asset exchange or its related parties, which may give rise to conflicts of interest, insider trading risks, or market manipulation concerns (e.g. fee discounts, preferential access, or buy-back mechanisms).
c. Nascent Utility Tokens (NUTs)
Digital assets associated with early-stage projects or infrastructure where:
- the intended utility is still under development or unproven;
- trading history may be limited; and
- information asymmetry exists, making the token more akin to venture-style investment risk.
Nascent Utility Tokens may include both IEO and Non-IEO tokens, which shall be subject to differentiated investor access and guardrails.
Higher-Risk Digital Assets may be made available subject to enhanced assessment, ongoing monitoring, and additional investor protection measures proportionate to their risk profile.
Guardrails for Digital Assets
6.1 All Tokens
Hata seeks to align with internationally recognised governance standards and provide users with relevant disclosures regarding listed digital assets, which may include:
- Hata’s role, capacity and any trading conflicts in relation to the digital asset;
- Whether the digital asset is issued by, affiliated with, or economically linked to Hata or its related parties; and
- Any market-making arrangements and measures to prevent front-running or preferential treatment.
All tokens listed on Hata are subject to market surveillance.
6.2 High Risk Digital Assets
High Risk Digital Assets are subject to ongoing monitoring, including surveillance for wash trading, pump-and-dump activity, insider trading indicators, and abnormal price or volume movements.
Depending on the risk profile of the asset, Hata may apply additional safeguards, which can include:
- Enhanced risk disclosures to users
- User risk acknowledgements prior to trading
- Periodic review of the digital asset
- Investor profiling and, where appropriate, investment limits
- Access restrictions based on investor classification
Sophisticated Investors
Certain high risk digital assets may be offered only to Sophisticated Investors in accordance with the categories defined by the Securities Commission Malaysia.
Where applicable, users may be required to provide reasonable information or documentation to verify their eligibility before being granted access to such digital assets. Hata applies internal processes to verify eligibility in line with regulatory expectations.
Disclosure Obligations
For each listed digital asset, Hata shall make available to users:
- Risk associated with the digital asset;
- Trading history (volume and price);
- Operational history, including incidents of manipulation or security failures;
- Token ownership concentration and insider lock-ups;
- Protocols for transfers;
- Hata’s treatment of client assets, including rights relating to forks and airdrops;
- Trading information, both pre-trade and post-trade, on a real-time basis;
- Comprehensive description of the Digital Asset;
- Information relating to the issuer, its business and management team; and
- The security audit results carried out on the underlying protocol, network and application.
Enhanced disclosures shall also be made available to users for High-Risk Digital Assets.
Ongoing Monitoring and Periodic Review
Listing is not a one-time decision. Hata conducts periodic reviews of digital assets available on its platform to ensure they continue to meet Hata’s governance, risk, and regulatory standards.
Reviews may also be triggered by significant project, market, security, or regulatory developments. Higher-Risk Digital Assets are generally subject to more frequent review.
Crypto-to-Crypto (Crypto/Crypto) Offerings
Hata may offer Digital Assets for trading via crypto-to-crypto (“crypto/crypto”) trading pairs.
Where Hata offers crypto/crypto pairs, these pairs are subject to the same listing, disclosure, investor protection, operational controls, reconciliation, periodic review, and market surveillance requirements as other listed Digital Assets.
10.1 Crypto/Crypto Risk Acknowledgement
While crypto/crypto trading pairs may be made available to all users, Hata will require users to accept a specific risk acknowledgement prior to accessing crypto/crypto trading pairs.
The crypto/crypto risk acknowledgement shall include, at minimum, disclosures that:
- crypto/crypto pairs are quoted in digital assets and not fiat currency;
- users may be exposed to compounded price volatility (i.e. both the base and quote asset may fluctuate materially);
- execution risks may be heightened including slippage, spread widening and low liquidity; and
- the value of the user’s holdings may change significantly even if the user does not convert to fiat currency.
Notwithstanding the above, Hata may apply investor access restrictions to crypto/crypto pairs involving High Risk Digital Assets, where necessary, to safeguard investor protection.
Delisting Decision & Process
Hata may decide to delist a digital asset where it no longer meets Hata’s governance, risk, or regulatory standards, or where continued listing may pose risks to users or market integrity or to the Hata platform.
Management of Delisting & Public Announcement
Where a decision to delist is made, Hata will:
- Provide advance notice to affected users
- Specify the date and time when trading will be suspended
- Remove relevant trading pairs
Provide a withdrawal window (subject to network availability) to allow users to transfer their digital assets to an external wallet after trading ceases
Review of this Disclosure
This Customer Disclosure Framework is reviewed periodically to ensure continued alignment with regulatory expectations, market developments, and Hata’s internal governance standards.