Singapore Digital Payment Token Listing and Delisting Procedure
Introduction
Objectives
The objective of this token listing and delisting procedure (“Procedure”) is to provide existing and prospective Revolut users with insights on our approach to (i) selecting, assessing and listing new tokens, and (ii) monitoring and delisting existing tokens.
Scope
Legal entity applicability
This Procedure applies to Revolut Technologies Singapore Pte Ltd (“Revolut”, “we”, “us” or “our”) and all of Revolut’s employees. Future listings/delistings of tokens on the Platform will be based on the guidelines and criteria set out in this Procedure. Revolut will consider how each prospective token complies with the principles below, and whether it should be delisted from the Platform for prescribed reasons. This Procedure is to be read together with our Crypto Terms and the disclosures therein.
Revolut is a company incorporated in Singapore (UEN 201721013G) and is regulated as a Major Payment Institution by the Monetary Authority of Singapore ("MAS") under the Payment Services Act 2019 to carry on the business of providing Account Issuance Service, Domestic Money Transfer Service, Cross-border Money Transfer Service, E-money Issuance Service, Merchant Acquisition Service and Digital Payment Token ("DPT") Service.
It is important to note that the conclusion reached by Revolut Group for other Revolut entities may not be the same as in Singapore.
Before you:
(a) pay Revolut any money or DPT; or
(b) pay a third party any money or DPT under an arrangement by Revolut,
you should be aware of the following.
- Revolut is licensed by MAS to provide DPT services. Please note that this does not mean you will be able to recover all the money or DPTs you paid to Revolut or any other third party referred to above, if Revolut’s or the third party’s business fails.
- You should be aware that MAS does not supervise or regulate Revolut for the provision of unregulated services*. This includes any service of trading digital payment token derivatives such as futures.
- You should not transact in the DPT if you are not familiar with this DPT. This includes how the DPT is created, and how the DPT you intend to transact is transferred or held by Revolut.
- You should be aware that the value of DPTs may fluctuate greatly. You should buy DPTs only if you are prepared to accept the risk of losing all of the money you put into such tokens.
- You should be aware that Revolut, as part of its licence to provide DPT services, may offer services related to DPTs which are promoted as having a stable value, commonly known as “stablecoin”.
* Please refer to Section 2.3.1 of the Guide to the Payment Services Act 2019 (which can be found on the MAS website) for the types of payment services which are regulated under the Payment Services Act. Services which do not fall within the list of services in Section 2.3.1 are unregulated services.
We do not provide any personal financial advice relating to any of our DPT services. You should carefully consider your personal situation and the financial risks you are willing to take before buying cryptocurrencies. You may want to speak to a qualified financial adviser before making any decision regarding the DPT services. You must be at least 18 years old to use the DPT services.
Token Due Diligence
Token Selection (Pre-Scoring stage)
On a monthly basis, the Revolut Group’s Crypto Team (“Crypto Team”) tracks information about tokens online to identify those that may be suitable for listing on the Platform.
The Crypto Team may also conduct surveys to evaluate customer demand, and monitor token purchase volumes on different exchanges to evaluate community demand for specific tokens. Evaluating customer/community demand allows Revolut to offer customers the benefits of the tokens that they demand.
In sum, the more trading volume and partners available to support a token, and the more customer/community demand for a token, the more chances it has to progress to the scoring stage. Before progressing to the scoring stage, the Crypto Team performs checks on blockchain compatibility and determines whether the tokens are subject to any georestrictions.
Token Scoring (Scoring Stage)
Tokens that are selected for scoring then undergo a thorough review performed by the Crypto Team. The review is built on criteria which assess tokens against key risks and/or considerations that include but are not limited to:
- Liquidity Risk
- Technical and Network Risk (i.e. robustness against attacks and hacks)
- Privacy Risk (i.e. indicators of privacy-enhancing features)
- Presence of Adverse Media
- Risk of token being deemed as a “capital markets product” regulated by MAS
- Whether a token has undergone a security audit
- Recency and/or survivorship of the token
- Whether a token has been the subject of sanction(s)
Approval Process for Crypto Tokens Launch
Compliance Review
As part of the approval process, the relevant token(s) undergo a compliance review (which includes reviews by the Revolut Group and the Singapore team). The Singapore team will complete a review of the token as per local regulations before approving. If a token passes the Group’s acceptance criteria but fails any local selection criteria then it will not be launched in Singapore.
An executive decision may also be made to not go ahead with the listing even if the token passes the Token Scoring methodology for various reasons.
As the regulatory landscape for cryptocurrencies and digital assets is rapidly evolving worldwide, any new tokens in Singapore need to incorporate specific considerations. At a minimum these include:
- The requirements set by the Monetary Authority of Singapore (MAS)
- The Payment Services Act 2019 and relevant subsidiary legislation
Token Listing Process
Once all reviewers have completed their assessment and provided the relevant approvals, the Crypto Team follows the internal processes for launching new tokens in the app.
Ongoing Monitoring
As highlighted above in sections 2.2-2.3, tokens undergo a thorough review by the Crypto Team and the relevant Group and local teams before they go live. Once onboarded, tokens are also subjected to ongoing monitoring.
Annual Attestation
Once a year, and after reviewing the market conditions and the regulatory environment, the Crypto team will provide attestation regarding the risk profile of the onboarded tokens. This process might highlight worsening risk profile for specific tokens which could lead to further actions (see section 2.5.3).
Ad-hoc reviews
Reviews of tokens may also be required if material events occur, including one-off events such as hacks, forks, upgrades, regulatory changes, enforcement actions, and more.
At any point in time, if the facts or circumstances surrounding a token change materially, the Crypto Team will perform a review.
Revolut uses a combination of tools and strategies to monitor the occurrence of material events, which includes dedicated media monitoring channels on Slack, information sharing activities across different teams and horizon scanning solutions.
Token Delisting / Halting
As part of the above processes (or for any other reason), a token may be deemed no longer suitable for Revolut to support. Such withdrawal of support may be permanent or temporary. In such cases, after consultation with the various teams, we will proceed to delist such token / halt the trading of such token (where applicable).
Examples of scenarios in which Revolut may consider delisting a token / halting the trading of token include, but are not limited to:
- Implementation of new regulatory standards and other compliance issues;
- Blockchain or related technology becomes compromised, defective, outdated and/or unusable;
- Token no longer supported by the token issuer or Partner Exchanges;
- Limited trading volume on the Platform or potentially suspicious trading activity;
- Complaints, concerns or negative feedback by users of the token;
- Detection of other risks related to the listing (e.g. liquidity risks).
When a token is going to be delisted, we will endeavour to give you the opportunity to sell that token. Once the delisting is announced, you will no longer be able to buy that cryptocurrency on the app, and any buy limit orders that you have placed may be cancelled.
On the day the delisting takes effect, the relevant token will be removed from the Revolut app. If you still hold any relevant token(s) being delisted on that date, you agree that we may, and instruct us to, convert them on your behalf to the base currency of your Revolut account at the exchange rate that applies at the time we make that conversion in accordance with our Crypto Terms.
We will do our best to give you advance notice of a token delisting, although this might not always be possible where, for example:
- There is a sudden change in laws or regulations that impacts the regulatory status of a cryptocurrency, or which means we can no longer support that cryptocurrency.
- A cryptocurrency changes the way it functions or its name.
- The third parties we work with to provide our DPT services stop supporting the cryptocurrency.
Where advance notice is given, we will endeavour to provide customers of our intention to delist or halt the trading of the relevant token(s) through the following communication means:
- In-app banner;
- Push notification;
- In-app inbox;
- Email; and/or
- Product Article.
Token Settlement Procedures
Registration of Orders
Orders placed via Revolut platforms are registered automatically in our systems. These systems immediately capture the following data about the orders placed via Revolut platforms such as:
- date and exact time of the order;
- client identification data;
- crypto asset identification data in relation to placed order;
- order direction (buy, sell);
- order type (e.g. market, stop order, etc.).
Orders placed via Revolut platforms can be retrieved by users in-app. These statements will show overall value per token held as well as a breakdown of transactions made in the requested period and can be made available for transactions dating back to at least 5 years.
Settlement of Orders
All successful market orders received from you are settled on your account on a near real-time basis. Standing orders (Recurring buy, limit and stop orders) will be settled in the same way should the conditions of the order be met.
Once orders are received by Revolut, they will be transmitted promptly to Revolut Ltd, who will execute them, acting as a principal. However, there are exceptions and some orders might be refused to be executed if identified to harm market integrity.
All orders we receive are transmitted promptly, are stored in the order they are received by Revolut Ltd and each transmission indicates that it is a transmission of an order received from you.
Market orders are settled on a near real-time basis and cannot be reverted once placed. However, for recurring buys, stop and limit orders, you will have the option to cancel these order types by selecting the "cancel" button in the respective order screen. Once the “cancel” button is hit, you will receive a warning describing the consequence of such cancellation with the option to either reject or accept it. Once the cancellation request is accepted, the order will be deemed to be not placed and will not be transmitted for execution. Information on the cancellation of the order will be provided via the relevant Revolut platform.
For recurring buy orders, only future, non-executed orders can be canceled. Orders completed in the past cannot be reversed.
For limit and stop orders, canceling of orders is only available when the order has not been executed.
Management of disorderly trading of DPTs
Please refer to Sections 13 and 14 of our Crypto Terms.
Key definitions
Adverse Media: any kind of unfavourable information found across a wide variety of sources, such as newspapers, social media platforms, online forums, databases maintained by regulatory bodies etc.
Token: means a peer-to-peer decentralised digital representation of value (e.g. bitcoin, ethereum, etc.).
Delisting: means ceasing to support a particular token by Revolut, disabling the token's buy/sell functions as well as any other functionality, such as deposit/ withdrawal (if applicable).
Fork: when a blockchain diverges into two potential paths forward, one that follows the previous protocol and one that follows the new version (for example, in the context of protocol upgrades).
Partner Exchanges: refers to Revolut's partnered cryptocurrency exchanges or custodians which provide crypto liquidity for Revolut's crypto offering
Platform: refers to the environment created by Revolut that allows customers to trade cryptocurrencies on the Revolut app.
User: means a person or a legal entity that has an account on the Platform and has completed the crypto onboarding, agreeing to Revolut's Crypto Terms.